After years of delays and revisions, CMMC 2.0 is finally here. The Department of Defense published the final rule in the Federal Register on September 10, 2025, triggering a 60-day countdown. On November 10, CMMC requirements will begin appearing in DoD contracts, turning the streamlined certification framework from proposal to contractual reality.
For those tracking this saga since the original five-level CMMC was introduced in 2020, then simplified to three levels in 2021, the wait is over. No more speculation about timelines.
“We expect our vendors to put U.S. national security at the top of their priority list,” said Katie Arrington, currently performing the duties of the DOW chief information officer (via GovConWire).
No more "coming soon." November 10 marks the beginning of Phase 1 implementation.
Here's the irony: After years of preparation time, many defense contractors still haven't implemented the most basic—and most critical—security controls.
Assessment experts report that fundamental protections like encryption remain surprisingly absent across the defense industrial base. As Joe Devine, President of Axiotrop, recently noted: "Of all those 110 controls, the most important thing is trying to make the data not obtainable... If all those other things fail and our adversary gets access to our data, we at least want it to be encrypted so they can't use it. That, surprisingly, is the number-one unmet control."
The disconnect is striking. The controls that can be implemented fastest with modern solutions—encryption and granular access controls—are exactly what's missing. While organizations spend months on complex implementations, they're overlooking the quick wins that could immediately protect Controlled Unclassified Information (CUI).
The 60-day effective date is not a grace period. Starting November 10:
Summit 7 warns that most contractors need 9-12 months to fully implement NIST 800-171 and validate compliance. With 60 days remaining, traditional approaches won't work. You need solutions that deploy now, not next quarter.
While others scramble to address all 110 Level 2 controls at once, Virtru's FedRAMP Moderate authorized data security platform knocks out 27 of them—nearly 25% of your requirements—with deployment in days.
What You Get Immediately:
This isn't theoretical. Master Electronics implemented Virtru in weeks and immediately secured their CUI while meeting nearly a quarter of their CMMC requirements.
Forget perfect. Focus on practical:
CMMC 2.0 has been years in the making—streamlined from five levels to three, adjusted to reduce burden on small businesses, refined through countless comment periods. But all that preparation time ends November 10.
The winners won't be those who implemented all 110 controls perfectly. They'll be those who secured their CUI first with deployable solutions, then built from there. Because when contracts start including CMMC requirements, "we're working on it" won't be enough.
The defense industrial base is about to split: those who picked the low-hanging fruit and those who got overwhelmed trying to do everything at once.
Contact Virtru today to implement nearly 25% of your CMMC Level 2 controls before November 10. Start where it matters most—encryption that deploys in days, not months.