CMMC Certification Timing for DoD Contract Awards in 2025

Do You Need CMMC Certification at Contract Award or Just Before Work Begins?

Key Takeaways

• CMMC certification is generally required at the time of contract award, not merely before starting performance.

• Conditional certification can satisfy award requirements temporarily, provided it is properly documented.

• Subcontractors handling Controlled Unclassified Information (CUI) often must have certification before subcontract award due to prime contractor requirements.

Introduction

In today's defense contracting landscape, one pressing question often arises: 'When do I need to have my Cybersecurity Maturity Model Certification (CMMC)-at contract award or is it enough to have it before work starts?' The timing of your certification can dramatically affect your ability to win contracts and maintain compliance.

In short, contractors almost always must hold the required CMMC status when the contract is awarded. Waiting until the last minute is a risky gamble that could cost you valuable opportunities.

This article explains the regulatory requirements, timing nuances, and practical strategies to ensure your certification aligns with DoD contract demands.

Understanding the Regulatory Requirements

What the Federal Acquisition Regulations Require

Contracts that reference CMMC under the Defense Federal Acquisition Regulation Supplement (DFARS) explicitly state the required certification level, such as Level 1, 2, or 3, and define this as a contract award condition. This means you must demonstrate your compliance before you can legally be awarded the contract. There is no clause allowing 'win now, certify later.'

The Critical Role of DFARS Clause 252.204-7021

The Defense Federal Acquisition Regulation Supplement (DFARS) clause 252.204-7021 spells out these requirements clearly. Before contract award, your active CMMC certification or conditional status must be recorded in SPRS (Supplier Performance Risk System). Contracting officers have explicit instructions not to award contracts to firms missing this certification.

If this clause is not included in a solicitation, CMMC may not presently apply - but with DoD expanding CMMC efforts, expect the clause in more solicitations.

"You can't 'win first, certify later.' Certification at award is the rule, not the exception."

For further insights on conditional certification and award eligibility, see our post on conditional CMMC status for DoD contracts.

Award Timing Versus Performance Start

How Contracting Officers Enforce Compliance

Contracting officers treat CMMC certification much like any other award eligibility criterion. No valid certification before award means no contract. Extensions or allowances to certify after award are generally not granted.

Conditional Certification as a Bridge

To account for certification process timelines, DoD introduced a conditional certification option in the final rule. This status can temporarily satisfy award requirements if properly documented in SPRS, but it remains a limited mechanism and is subject to DoD policy updates.

However, this is not automatic. Contractors must complete assessments with a C3PAO (Certified Third Party Assessment Organization) and have their results adjudicated to gain conditional status.

It remains a narrow pathway and not a substitute for final certification.

Learn more about how C3PAOs evaluate compliance and conduct assessments in our article on the CMMC assessment process.

How Subcontractors Should Approach CMMC Timing

Requirements Flow Down to Subcontractors Handling CUI

Subcontractors often ask whether their certification timing matches the prime contract. The answer depends on the subcontract terms, but generally: if a subcontract entails handling Controlled Unclassified Information (CUI), primes may require CMMC certification before awarding the subcontract to reduce risk and ensure compliance.

Why Primes Insist on Early Certification from Subcontractors

Prime contractors want to minimize risks and avoid last-minute compliance scrambles. As a result, many embed CMMC requirements in their subcontract bids, making certification a de facto eligibility condition even if the DoD's direct enforcement might be looser.

Explore how subcontractors can meet these requirements by understanding CMMC 2.0 compliance strategies.

Practical Guidance for Navigating Certification Timing

Scheduling Your C3PAO Assessment

Given current demand and assessment turnarounds, schedule your C3PAO audit at least six to nine months before your intended contract award date.

Allow for CyberAB Review After Assessment

Post-assessment, CyberAB (Cyber Accreditation Body) review and certificate issuance can take 30 to 90 days depending on backlog and submission quality. Factor this window into your planning.

Risks of Delayed Certification

• Losing contracts despite strong technical proposals if certification is missing at award.

• Interruptions in your business pipeline due to awaiting approvals.

• Competitors with current certification gain an advantage with primes and the DoD.

Frequently Asked Questions

Conclusion

CMMC certification is rarely a task to postpone until just before starting work. For most Department of Defense contracts, it stands as a firm eligibility gate at the moment of award. Waiting too long can cost you contracts and cause costly delays.

Conditional certification provides a limited safeguard but is no replacement for thorough, timely preparation. Begin your certification journey early by engaging a C3PAO, plan for CyberAB review timelines, and expect prime contractors to demand proof sooner rather than later.

The most strategic choice? Start your CMMC certification well ahead of potential contract awards to avoid missing out when opportunities arise.

Simplify tracking your compliance status and deadlines by signing up for the CMMC dashboard. The dashboard helps you monitor your certification progress, document expirations, and key dates, so you remain audit-ready and competitive.