The DoD’s CMMC program has taken another step forward with today’s release of Proposed Final Rule CFR Title 48 in the Federal Register.
This is the rule required to implement the CMMC program into DFARS and it signifies continued progress, with the CMMC program still on track to be finalized by the end of 2024 and to appear in contracts by early-mid 2025.
There are two rules related to the CMMC program:
CFR Title 32 Final Rule
This is the rule that defines the CMMC program. It continues to be reviewed by OIRA and we expect it to be released no later than October 26th, 2024 but quite possibly several weeks sooner.
CFR Title 48 Rule
This is being issued as a Proposed Rule, which means it still has to go through public comment period, comment adjudication and OIRA review before it can become final.
However, it was already based off the DFARS 7021 interim final rule, and is a much narrower scoped proposed rule than the Title 32, so we don’t expect it to have a material change on the CMMC program. We still believe that the CMMC program is on track to be finalized by end of FY 2024 and to begin to appear in contracts by early-mid 2025, consistent with the DOD’s comments.
CMMC Summit
We hope you join us for our CMMC day virtual Summit on October 30th when we will be sure to cover this in significantly more detail.