On August 25th, 2025, the Office of Information and Regulatory Affairs (OIRA) completed its review of the long-awaited CMMC Defense Federal Acquisition Regulation Supplement (DFARS) Proposed Rule—giving clearance to the new FAR rule that codifies the new CMMC contract clause, and marking the final regulatory hurdle before implementation. This expedited review, completed in just over 34 days rather than the typical 90-day timeline, sends a clear signal: cybersecurity in the defense supply chain is now a top federal priority.
For defense contractors, subcontractors, and suppliers across the Defense Industrial Base (DIB), this development transforms CMMC from a future consideration into an immediate business imperative. The rule now awaits publication in the Federal Register, which could happen within days, not months.
The accelerated OIRA review suggests the Department of Defense isn't wasting time. Here's the timeline defense contractors are facing:
Immediate Next Steps:
The Reality Check:
Unlike previous cybersecurity requirements that offered extended implementation periods, CMMC's Phase 1 rollout means contractors handling Controlled Unclassified Information (CUI) must demonstrate compliance or risk immediate exclusion from contract opportunities. There's no grace period, no extensions, and no exceptions.
For the vast majority of defense contractors operating at CMMC Level 1 or 2, protecting CUI is going to be the foundation of your continued participation in the defense supply chain. The 110 controls required under NIST SP 800-171 represent a comprehensive security framework, but implementing them effectively requires strategic focus on the most critical elements.
Here's what many contractors are discovering: prime contractors aren't waiting for the official implementation date. They're already requiring CMMC readiness attestations from their subcontractors, creating a ripple effect throughout the supply chain. If you're not ready when the rule takes effect, you're not just risking future contracts—you're potentially losing current partnerships.
Recommended Reading: Virtru Shared Responsibility Matrix for CMMC 2.0
As defense contractors scramble to meet the looming deadline, Virtru’s FedRAMP Moderate authorized platform addresses 27 of the 110 CMMC Level 2 controls—nearly 25% of your compliance requirements—through a single, integrated solution.
Rapid Email Security Implementation
Deploy FIPS 140-2 validated encryption for Gmail and Outlook in days, not months. Our seamless integration means your teams can start protecting CUI immediately without workflow disruption or extensive training.
Supply Chain Collaboration Without Compromise
Enable secure information sharing via email, file sharing, and apps between primes, subs, and mission partners while maintaining complete control. Set expiration dates, revoke access instantly, and track every interaction with CUI—capabilities essential for demonstrating compliance during assessments.
Zero Trust Architecture Alignment
Virtru doesn't just meet current requirements; we align with the DoD's Zero Trust mandate, positioning you for both immediate compliance and future security evolution. Our data-centric approach protects CUI wherever it travels, whether to subcontractors, government partners, or cloud environments.
Sovereign Key Management
With Virtru Private Keystore, maintain complete control over your encryption keys—a critical requirement for organizations handling sensitive defense information. Host keys on-premises or in your preferred cloud environment while benefiting from Virtru's robust encryption infrastructure.
Frictionless File Sharing at Scale
Virtru Secure Share enables protected file transfers up to 15GB without requiring recipients to create accounts or install software. This eliminates the common excuse of "encryption is too hard" that often leads to non-compliant workarounds.
With OIRA's approval complete, every day of delay compounds your compliance risk. Consider the contrast:
Organizations acting now:
Organizations still waiting:
Virtru's platform can have you operational with 27 critical controls within days, not months. Our proven solutions are already helping defense contractors pass CMMC Level 2 assessments, providing the confidence and capability you need to maintain your position in the defense industrial base.
The deadline isn't approaching—it's here. Contact Virtru today to implement nearly 25% of your CMMC Level 2 controls before the final rule drops. Because in the race for CMMC compliance, second place means no contracts.