If you're a small business working with the Department of Defense, CMMC 2.0 isn't coming, it's already here. Phase 1 kicked off in November 2025, and the requirements are now showing up in contracts. The good news? You still have time to get ready. The better news? There's a straightforward path to compliance that won't drain your budget or your sanity.

Let's break down exactly what you need to know and do in 2026.

What Is CMMC 2.0, Anyway?

CMMC stands for Cybersecurity Maturity Model Certification. It's the DoD's way of making sure companies in the defense supply chain are actually protecting sensitive information: not just saying they are.

CMMC 2.0 simplifies things into three levels:

  • Level 1 (Foundational): Basic protection of Federal Contract Information (FCI). Annual self-assessments required.
  • Level 2 (Advanced): Protection of Controlled Unclassified Information (CUI). Aligns with NIST SP 800-171. Self-assessment or third-party certification required.
  • Level 3 (Expert): Enhanced protection for high-risk programs. Government-led assessments required.

Most small defense suppliers handling CUI will need Level 2. That's 110 security requirements and 320 objectives you need to meet. It sounds like a lot because it is.

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The 2026 Timeline: Where Are We Now?

Here's the deal with timing:

Phase Dates What Happens
Phase 1 Nov 2025 – Nov 2026 Level 1 and Level 2 self-assessments required in solicitations
Phase 2 Starts Nov 10, 2026 Third-party (C3PAO) certifications become mandatory for Level 2
Phase 3 Year 3+ Level 3 requirements roll out for applicable programs

Right now, in January 2026, you're in Phase 1. Self-assessments are the name of the game. But here's the catch: Phase 2 is less than 10 months away. When it hits, third-party audits become the standard for Level 2 compliance.

Translation? The clock is ticking.

How Do You Know What Level You Need?

Simple. Check your contracts.

Your Request for Proposal (RFP) or Request for Information (RFI) will specify your required CMMC level. If you're handling CUI: things like technical drawings, specifications, or other sensitive but unclassified data: you're looking at Level 2.

Not sure if you handle CUI? Ask your contracting officer or prime contractor. Better to know now than scramble later.

The Small Business Problem

Here's where things get real for small businesses.

CMMC Level 2 compliance is expensive and complicated when you go the traditional route. We're talking:

  • Hiring consultants
  • Buying new hardware and software
  • Rewriting policies and procedures
  • Training your team
  • Tracking gaps with Plans of Action & Milestones (POA&Ms)
  • Preparing for audits

For a company with 10-50 employees? That's a massive lift. Many small businesses simply don't have the IT staff, budget, or time to build a compliant environment from scratch.

This is exactly why turnkey solutions exist.

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The Turnkey Solution: CPE Level 2

Instead of building compliance piece by piece, CPE Level 2 gives you everything you need in one package.

What does that mean in plain English?

CPE Level 2 is a pre-built, fully compliant environment designed specifically for small to medium defense suppliers. It covers 100% of CMMC 2.0 Level 2 requirements: all 110 controls and 320 objectives: so you're not left guessing what's missing.

Here's What You Get:

  • Complete CMMC 2.0 Level 2 compliance out of the box
  • Audit-ready in as little as 4 weeks
  • No extra costs for hardware, licensing, or managed services
  • Integrated backup and network segmentation
  • vCISO sessions for ongoing guidance
  • Audit support when assessment time comes
  • 900+ CPE-specific cybersecurity features already configured

Starting at $1,099/month for up to 20 users, CPE Level 2 eliminates the guesswork and the massive upfront investment.

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Your 2026 Action Plan

Whether you go with CPE Level 2 or build your own compliance program, here's what you need to do:

Step 1: Determine Your Required Level

Review your active DoD contracts and upcoming solicitations. The RFP will tell you exactly what's required.

Step 2: Conduct a Gap Analysis

Compare your current cybersecurity setup against NIST SP 800-171 requirements (for Level 2). Identify what you have and what's missing.

Step 3: Choose Your Path

You have two options:

  • Build it yourself: Implement controls, write policies, train staff, track POA&Ms
  • Go turnkey: Deploy CPE Level 2 and get compliant in weeks, not months

Step 4: Document Everything

CMMC assessors want to see evidence. System Security Plans, policies, procedures, training records: document it all.

Step 5: Prepare for Assessment

  • Now through Nov 2026: Self-assessments submitted to SPRS
  • After Nov 2026: Third-party C3PAO certification for most Level 2 contractors

Critical Dates to Mark on Your Calendar

Date What's Happening
January 2026 You should be starting gap analysis and remediation NOW
November 10, 2026 Phase 2 begins: C3PAO certifications become mandatory
Annually Level 1 and some Level 2 self-assessments required
Every 3 Years Triannual third-party assessments for Level 2 (post-Phase 2)

Don't wait until October to start preparing. Third-party assessors are going to be swamped when Phase 2 hits. Get ahead of the rush.

Budget Reality Check

Compliance costs money. The good news? You can include CMMC implementation costs as a direct cost in your proposal budget with proper documentation.

Factor in:

  • Security upgrades (or a turnkey solution like CPE Level 2)
  • Staff training
  • Third-party assessment fees (when required)
  • Ongoing monitoring and maintenance

The cost of non-compliance is higher. Miss the requirements, and you're locked out of DoD contracts. Period.

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The Bottom Line

CMMC 2.0 isn't going away. It's now a contractual requirement for defense work. Small businesses that get compliant will keep winning contracts. Those that don't will watch opportunities go to competitors who did the work.

The path to compliance doesn't have to be painful. With solutions like CPE Level 2, you can be audit-ready in weeks: not years: without the massive overhead of building everything yourself.

Your next step? Determine your required level, understand your gaps, and pick your path forward. The sooner you start, the smoother 2026 will be.

Questions about CMMC 2.0 readiness or CPE Level 2? Reach out to our team at CMMC@PLANETSECURITY.NET or call 702-508-2338.

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