For years, the Cybersecurity Maturity Model Certification (CMMC) felt like a “someday” problem for the Michigan defense industrial base. Whether you are a machine shop in Novi, a fabricator in Auburn Hills, or a logistics provider in Detroit, that “someday” officially ended on November 10, 2025.
We are now in the era of enforcement. If you want to keep your DoD contracts, or win new ones in 2026, the rules of the game have changed. Here is what Michigan defense contractors need to know about the CMMC deadline 2026, enforcement timeline, and DoD contractor cybersecurity requirements for 2026.
CMMC Enforcement Timeline: Phase 1 vs Phase 2
Phase 1: The “Executive Accountability” Phase (Started Nov 10, 2025)
We are currently in Phase 1 of the CMMC enforcement timeline. Right now, CMMC requirements are being written into new DoD solicitations.
- The Requirement:To be eligible for a contract award, you must have a Level 1 or Level 2 self-assessment uploaded to the Supplier Performance Risk System (SPRS).
- The SPRS Requirement: Your score must be entered into SPRS and annually affirmed by a senior executive.
- The Local Reality: In the past, many local shops “pencil-whipped” their self-assessments to get a score on the board. In 2026, that is a dangerous legal risk.
- The Signature: A senior executive must now personally sign an annual affirmation of these scores. If you sign off on a score of 110 but haven’t actually implemented the controls, you aren’t just non-compliant, you are potentially liable for fraud under the False Claims Act.
- KML Insight: We are seeing a surge of Michigan executives looking for “homework verification.” They don’t want to sign that affirmation until a technical expert confirms their self-assessment is actually accurate.
The Phase 2 Deadline: November 10, 2026
This is the hard CMMC Phase 2 deadline that should be circled in red on your calendar.
On November 10, 2026, Phase 2 begins the transition to mandatory third-party certifications (C3PAO).
- The Rule: For any contract involving Controlled Unclassified Information (CUI), a self-assessment will no longer be enough. You will need a formal certification audit from a certified third party.
- DoD Compliance Requirement: CMMC certification will be required to bid on many DoD contracts involving CUI.
- The Timing Issue: Readiness for a Level 2 audit typically takes 6 to 12 months of remediation.
- The Math: If a Michigan defense contractor hasn’t started fixing security gaps by Spring 2026, they are statistically likely to miss the window. By the time bids open in early 2027, they won’t have the certification required to even submit a proposal.
What Happens If You Miss the CMMC Compliance Deadline?
Failing to meet the CMMC compliance deadline for DoD contracts can mean:
- Ineligibility to bid on new contracts
- Loss of existing contract opportunities
- Delayed revenue streams
- Increased legal and compliance risk
For companies that rely on defense work, missing certification can effectively shut the door on future DoD business.
Is a Self-Assessment Enough for 2026?
During Phase 1, a self-assessment uploaded to SPRS may satisfy requirements for some contracts.
However, once Phase 2 begins in November 2026:
- Self-assessments alone will not be sufficient for contracts involving CUI
- Third-party certification will be required
- Contractors must demonstrate full implementation of NIST SP 800-171 controls
Do You Need CMMC Certification to Bid on DoD Contracts?
In many cases, yes.
Beginning in Phase 2 of the CMMC enforcement timeline, certification will be required for contractors handling Controlled Unclassified Information. Without certification, your company may be disqualified before proposal review even begins.
How Long Does CMMC Readiness Take?
Most organizations require 6 to 12 months to remediate gaps and prepare for a Level 2 assessment.
Complex environments or poorly documented controls may take longer.
Starting early in 2026 significantly improves your chances of meeting the Phase 2 deadline.
3 Ways Michigan Defense Contractors Can Protect Revenue in 2026
If you feel behind, you aren’t alone, but you do need to move. Here is how we are helping clients beat the CMMC 2026 deadline:
1. The “Sanity Check” (Do This Now)
If you signed your SPRS affirmation in 2025 without a technical audit, let KML perform a sanity check. We verify your self-assessment before your 2026 renewal so you can sign with confidence and without legal liability.
2. The 6-Month Warning
Phase 2 starts November 10, 2026. If you aren’t in active remediation by June 2026, you likely won’t be ready for a C3PAO audit in time for the 2027 bidding season. Don’t let certification delays freeze your revenue stream.
3. The “Two-for-One” Strategy
Your cyber insurance renewal and your CMMC attestation are now evaluating the same 110 controls (NIST SP 800-171). We help strengthen your security posture while improving insurability and DoD eligibility.
What Should Contractors Do Right Now?
- Validate your SPRS score
- Identify gaps in NIST 800-171 compliance
- Begin remediation immediately
- Plan for third-party certification
- Establish executive accountability processes
Waiting until late 2026 will likely be too late.
Don’t Guess — Get a CMMC Roadmap
Whether you’re operating in Oakland County or anywhere in the Michigan defense industrial base, KML Computer Services understands the local manufacturing and defense landscape.
We don’t just give you a list of problems. We provide a clear roadmap to achieve CMMC compliance before the 2026 deadline through our cybersecurity and compliance services, helping you maintain eligibility for future DoD contracts.
Mark Rossi is president of KML Computer Services. Since 1996 he has been immersed in the technology field, working in various positions, from hardware technician and network manager to network engineer and IT consultant.

