Controlspan / Field notes   Enterprise GRC intelligenceResearch edition · October 2026 · US market
Regulatory news and changes / RESEARCH NOTE 09

Is CMMC Phase II still a 10 November 2026 procurement deadline?

CONTROLSPAN RESEARCH DESKSECTION 04 · PAGE 9 OF 16Last updated 28 October 2026

No: the July 2026 suspension changes that planning assumption. The official CMMC page says Phase II was suspended on 13 July 2026, while Phase I self-assessment requirements remain in place. The SBA’s Office of Advocacy separately documented the suspension and reform review. (dodcio.defense.gov)

What should defence suppliers and service providers do now?

Recommended action: separate the programme-level implementation pause from the obligations in each solicitation, contract and subcontract. Have the contracting owner verify the actual current requirements and any amendments.

For the GRC programme:

  • Preserve existing self-assessment evidence and remediation records.
  • Link obligations to the relevant contract, entity and system boundary.
  • Mark suspended milestones as suspended—not completed or deleted.
  • Keep proposed future requirements separate from applicable requirements.
  • Revisit assessment-related services expenditure against the revised programme status.

Contracting test for a platform supplier: ask what happens if an external standard or programme date changes after implementation begins. Require pricing and acceptance terms that distinguish reusable control work from abandoned, date-specific configuration.

No replacement Phase II launch date was verified in the official material reviewed. Do not substitute a speculative restart date in the compliance calendar.

Sources cited on this page

  1. dodcio.defense.gov ↗dodcio.defense.gov
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