If you're a defense contractor who's been putting off CMMC compliance, your grace period officially ends today. Title 48 takes effect this morning, marking the most significant shift in defense contracting cybersecurity requirements in nearly a decade.

To understand what this means for the Defense Industrial Base, we recently spoke with Joe Devine, President of AXIOTROP and one of only 82 certified C3PAO assessors in the country. With nearly two decades of NIST-based cybersecurity expertise and five years focused exclusively on CMMC compliance, Devine has been preparing organizations for this exact moment.

"This is not stuff that your average company can do on their own," Devine warns, and the stakes couldn't be higher.

The Reality Check: What Today Really Means

1. The Waiting Game Is Over

After a 60-day implementation period following its September 10th publication, Title 48 transforms CMMC from a future requirement into present reality. Starting today, the Department of Defense can officially include CMMC requirements in new contracts involving Controlled Unclassified Information (CUI).

Devine explains the significance: "Title 48 gives the DOD the opportunity to implement CMMC in contracts. And there's a couple of things that are probably important to understand about that."

The phased approach might seem generous at first glance, but as Devine's insights reveal, the timeline is tighter than it appears.

2. The Self-Assessment Year: A Double-Edged Sword

While contractors have one year of self-assessments before third-party evaluations become mandatory, Devine cautions against viewing this as a free pass. "For the first year, the standard is going to be a self assessment... but their plan, as they demonstrated in Title 48 eight, is one full year self attestation. You post your own score. You attest to your score."

But here's the catch that many contractors miss: preparing for the November 10, 2026 third-party assessment deadline needs to start now. Devine breaks down the harsh reality: "Even for a small organization, it's not likely to take less than four to six months for you to get your work done."

Add to that the need for what CMMC calls "habitual and persistent" implementation, essentially proving you've been living with these security controls, not just checking boxes, and suddenly that year-long buffer shrinks dramatically.

3. The Assessor Crisis Nobody's Talking About

The most alarming revelation from our conversation with Devine involves simple math that should terrify any procrastinating contractor.

"There's right at as of a couple weeks ago, there was, like, eighty two of us, that are C3PAOs," Devine reveals. "When you look at level two and level three combined... we're talking about a hundred and twenty plus thousand companies that have to be assessed."

Devine's own schedule tells the story: "Schedules are already filling up. I mean... ours is already filling up fast. And I would expect it's not gonna be easy to schedule a Q2 or 32 assessment for next year."

This isn't a warning about some distant future. it's happening right now. Companies that don't secure their assessment slots soon may find themselves unable to bid on contracts simply because they couldn't get on an assessor's calendar.

4. Why "Starting Tomorrow" Is Already Too Late

When asked about realistic timelines for achieving compliance, Devine painted a sobering picture that goes beyond just technical implementation.

"There's really two things that are driving that to be a true statement," he explains. First is the implementation time itself, those four to six months minimum. But the second factor is what catches organizations off-guard: "You wanna live in that system for a while. You don't wanna just jump from, okay, great, we got our one ten score. Let's get our assessor in tomorrow. It's not gonna go well for you."

Devine emphasizes that assessors will be looking for evidence of "habitual and persistent" implementation. "They're gonna wanna look that you've been... living in this. It's a habitual thing for you, and you're persistent with doing the things you say you're gonna do."

His recommendation? Live with your implemented controls for at least four months before attempting an assessment. When you do the math, organizations need to start their journey immediately to meet the 2026 deadline.

5. The Hidden Opportunity: Strategic Scope Reduction

While the challenges are real, Devine offers a lifeline for organizations worried about costs and complexity: strategic scope reduction.

"There's no reason to have unless you have... eighty, ninety percent... of your business in the defense industrial base, then maybe you want an enterprise solution," Devine advises. "But for many, many customers, many OSCs, they also do commercial work."

He shared a concrete example that resonated: A 16-person machine shop reduced their required licenses from sixteen to seven or eight by restructuring their workflows. "We talked about why not have a couple of people that do programming for you that see that. And then when you send the G code out to be processed at that machine... this person doesn't have to see the digital CUI anymore."

The lesson: Smart scoping isn't about cutting corners; it's about intelligent design. Devine's advice is practical: "If you can eliminate printing, then do it." Removing physical CUI handling alone can dramatically reduce your compliance burden and costs.

CMMC 2.0... and Beyond

As our conversation with Devine made clear, Title 48's implementation today is a watershed moment that will separate prepared contractors from those who may find themselves locked out of defense contracts.

Devine's parting wisdom carries particular weight given his experience: "We tell them... you need to be thinking about, if not working with us, doing something on your own, or working with another consultant to get ready for this because this is not stuff that your average company can do on their own."

For the 120,000+ companies in the Defense Industrial Base, today marks the beginning of a new era. The question isn't whether you need to comply. It's whether you'll secure your assessment slot and complete your journey before your competitors do.

As Devine reminds us, "A long journey takes one... your first step, right? You get to do something first... and then you can move forward."

That first step needs to happen today.

For more information about CMMC compliance and assessments, organizations can visit cyberab.org to find certified C3PAO assessors in their area.