CMMC Phase 2 Is Suspended... But Contractor Liability Just Went UP

Episode notes

Miss the CUI Hotline Telethon? Watch it on-demand: The DoD has suspended the November 2026 transition to Phase 2 of CMMC implementation, but that doesn't mean cybersecurity requirements have been relaxed. In this episode, we explain what actually changed, what didn't, why Level 2 self-assessments now matter more than ever, and how contractors could expose themselves to significant False Claims Act liability if they misunderstand the news. We also discuss the 60-day CMMC program review, the DoD's Request for Information, and what defense contractors should focus on moving forward. Phase 2 Announcement: Phase 2 Blog: 32 CFR 170.16: 32 CFR 170.22: False Claims Act:

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