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What are the latest requirements for CMMC Level 2 certification assessments by a C3PAO in 2026?

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My firm is bidding on a federal Department of Defense contract for IT services, NAICS 541519, which requires CMMC Level 2 certification. We saw the requirement in the solicitation, and the due date is in May 2026. I know the 32 CFR CMMC Program rule took effect in December 2024 and the DFARS acquisition rule in November 2025. I also saw the notice that Phase II was suspended in July 2026, but the Level 1 self-assessment requirements remain. This has me confused about Level 2.

What are the specific requirements for a CMMC Level 2 certification assessment by a C3PAO in 2026? What exactly does a C3PAO look for during the assessment process?

asked Priya S. Verified vendorCapture manager, IT services · Herndon, VA · 594 rep

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The specific requirements for a CMMC Level 2 certification assessment by a C3PAO in 2026 are the 110 requirements of NIST SP 800-171 Revision 2. The CMMC Program rule, 32 CFR 170.4, details that Level 2 is either a self-assessment or a certification assessment by a C3PAO. Even though the Department suspended Phase II of CMMC implementation in July 2026, all Phase 1 self-assessment requirements remain in place. This means the underlying security practices for Level 2 are still in effect. A C3PAO would look for your firm's implementation of each of the 110 NIST SP 800-171 Revision 2 requirements during the assessment process. This includes examining policies, procedures, and technical controls to ensure they are in place and operating effectively to protect controlled unclassified information.

answered Marcus T. Verified vendorOwner, janitorial and facilities firm · Columbus, OH · 1113 rep
Thanks, Marcus. My firm is starting to look into the cost and timeline for a C3PAO assessment now that we know the specific requirements. The 110 controls are a lot to get through. · Priya S. ·

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Sign up to answerCite the FAR clause or procurement code where you can.