CMMC Is Now Real: What DIB Contractors, RPOs, and C3PAOs Need to Do in 2026 and How Summit Cyber Supports Each Role

For years, CMMC was a moving target. That era is over. The CMMC final rule is now baked into DFARS, and contracting officers have started inserting CMMC clauses into new solicitations as part of a phased rollout that runs through November 10, 2028. For Registered Provider Organizations (RPOs), C3PAOs, and small to mid‑size defense contractors, this shift changes how you scope work, win business, and manage risk.​

What changed with the final rule:

The updated DFARS 252.204‑7021 clause makes CMMC requirements a condition of award and imposes ongoing obligations, including maintaining current CMMC status, flowing requirements to subcontractors, and filing annual affirmations of continuous compliance in SPRS. A companion solicitation provision, DFARS 252.204‑7025, serves as a notice that CMMC status will be checked as part of source selection, no longer treated as a “future requirement.”​

In practice, this means eligibility to win or even keep covered contracts now depends on demonstrable, continuously maintained compliance at the required CMMC level. For DIB owners, this is fundamentally a revenue protection issue, not just an IT problem.​

The phased rollout for CMMC: 2025–2028:

DoD is implementing CMMC over four phases between November 10, 2025, and November 10, 2028.​

• Phase 1 (Nov 10, 2025 – Nov 10, 2026): Level 1 self‑assessments become mandatory for covered contracts, and some Level 2 programs begin requiring self‑assessment or certification.​

• Phase 2 (Nov 10, 2026 – Nov 10, 2027): Level 2 C3PAO‑led certifications will be required for a growing set of contracts involving CUI.​

• Phase 3 (Nov 10, 2027 – Nov 10, 2028): Level 3 requirements come online for select high‑risk programs.​

• Phase 4 (after Nov 10, 2028): Full implementation; all applicable solicitations and contracts must include CMMC requirements, including options.​

  
  

The takeaway: 2026 and 2027 are the critical execution years for RPOs, C3PAOs, and DIB owners to build repeatable, scalable approaches to CMMC work.​

Roles of RPOs, C3PAOs, and OSCs:

RPOs and C3PAOs are now central pillars in the CMMC ecosystem, with clearly separated responsibilities.

• Organizations Seeking Compliance (OSC) are accountable for risk, budget, and culture. They own scoping decisions, resourcing for remediation, and selecting the right partners across RPOs, C3PAOs, MSPs, and cloud providers.​

• Registered Provider Organizations (RPO) provide advisory and implementation support: gap assessments, scoping, documentation, and remediation aligned to CMMC and NIST SP 800‑171. RPOs cannot issue certifications and must stop short of performing official CMMC assessments.​

• Certified Third-Party Assessor Organizations (C3PAO) conduct formal third‑party Level 2 assessments, reviewing evidence, interviewing staff, and recommending certification status to the Cyber AB. They must maintain independence and are prohibited from delivering remediation for the same organizations they assess.​

  
  

This structural separation creates both collaboration opportunities and handoff risks between advisory, assessment, and the business.

How Summit Cyber supports OSCs:

For small and mid‑size DIB contractors, the core questions are: “What level do we need, what will it cost, and how do we get there without breaking the business?” Summit Cyber is built around answering those questions in practical terms.

• Business‑first roadmapping: mapping contract portfolio, data flows, and growth plans to CMMC level requirements, then prioritizing controls and investments by revenue and risk impact.​

• Turnkey CMMC readiness: environment scoping, NIST 800‑171 gap assessment, policy and SSP development, technical remediation, and evidence collection, delivered in partnership with RPOs and, when appropriate, your chosen C3PAO.​

• Ongoing governance: virtual ISSM/vCISO support, continuous monitoring, configuration management, and annual affirmation support to keep CMMC status current between assessments.​

  
  

Summit Cyber’s goal is to give contractors a clear, budget‑anchored path from “concerned” to “audit‑ready” and then help them stay that way as requirements evolve.

How Summit Cyber supports RPOs:

RPOs need scalable, repeatable technical depth and documentation muscle to deliver consistent outcomes. Summit Cyber acts as a behind‑the‑scenes technical and delivery partner to help you execute.

• White‑label or co‑branded readiness assessments, NIST 800‑171 gap analyses, and SPRS‑aligned scoring with defensible evidence packages you can fold into your own deliverables.​

• Design and implementation support for secure enclaves, GCC High or commercial Microsoft 365 architectures, and control implementations that you, as the RPO, position and manage from a client‑facing standpoint.​

• Playbooks, reusable artifacts, and policy templates tuned for SMB DIB environments, allowing your consultants to focus on strategy and client relationships while Summit Cyber handles technical lift.

  
  

Summit Cyber does not compete with you for advisory branding; the focus is enabling your RPO practice to deliver high‑quality, CMMC‑aligned results more efficiently.

How Summit Cyber supports C3PAOs:

C3PAOs must protect independence and avoid conflicts of interest, yet still need clients to come to the assessment “audit‑ready.” Summit Cyber helps on the preparation side; either directly or in partnership with RPOs, before you engage as assessor.​

• Pre‑assessment readiness engagements that align evidence, artifacts, and control implementations to how C3PAOs actually test requirements, reducing time spent clarifying basics during formal reviews.​

• Objective, evidence‑driven self‑assessments and POA&M strategies that prepare organizations to close out issues before they appear in your findings, improving throughput and assessment quality.​

• For C3PAOs, the value is a pipeline of better‑prepared candidates, clearer scoping, and fewer contentious assessment cycles without compromising your independence model.

• Summit Cyber maintains a vetted pool of CCAs and CCPs available to augment C3PAO assessment teams during assessment surges; subject to independence rules.