In business, timing often matters more than perfection. The companies that recognize emerging opportunities and act decisively while competitors hesitate typically capture and enjoy a larger piece of the pie. This principle has played out repeatedly across industries, from Amazon’s early investment in e-commerce infrastructure to Lockheed Martin’s commitment to hypersonic systems.
Today, defense contractors face a similar moment with Cybersecurity Maturity Model Certification (CMMC). The recent OIRA approval of the DFARS rule has started a clock that will separate industry winners from those left behind.
CMMC Dates to Remember
September 10, 2025: – Federal Register 48 CFR CMMC rule publication
60 day public notice period
November 10, 2025: 48 CFR CMMC Rule goes into effect
What Just Changed
On August 25, 2025, the Office of Information and Regulatory Affairs completed its review of the Defense Department’s proposed CMMC rule in just over 30 days … a process that typically takes 60 to 90 days. The urgency with which the rule was approved reflects the federal government’s prioritization of critical infrastructure and national defense cybersecurity.
The practical impact is immediate: CMMC compliance became required November 9, 2025, creating a first-mover advantage for companies that began preparation during the brief window between OIRA approval and implementation.
Translation: no certification means no contract access.
But here’s the opportunity many are missing: this isn’t just about avoiding exclusion. It’s about becoming a first mover in a changed marketplace.
Why First Movers Win
When regulatory requirements create new market divisions, early adopters consistently outperform late adopters in three key areas:
Preferred Partner Status: Prime contractors are already identifying CMMC-ready suppliers to avoid supply chain risks. Companies that achieve certification first become the go-to partners for major defense contractors who eliminate non-compliant suppliers from consideration. This preference often persists long after certification becomes commonplace.
Premium Pricing Power: Early certified companies can command higher margins because they offer something competitors cannot: immediate contract access. Late adopters will find themselves competing mainly on price within a smaller pool of certified vendors.
Operational Advantages: The certification process itself creates improvements that go beyond compliance. Companies that complete CMMC certification typically report better data governance, streamlined security processes, and reduced insurance premiums … benefits that build over time.
The Bottleneck That’s Forming Now
There is already a bottleneck for scheduling third-party Level 2 certifications with approved CMMC Third Party Assessment Organizations (C3PAOs). Companies beginning their CMMC journey today face compressed timelines and limited assessment availability, while firms that started preparation months ago have secured optimal scheduling and implementation windows.
This bottleneck will only grow as the deadline approaches. Early movers get the best assessment partners and flexible timelines. Late movers face limited availability, rushed implementations, and higher costs as demand exceeds supply.
Your CMMC Requirements
The Department of Defense designed CMMC to be achievable, especially for small and medium-sized businesses. Understanding the levels helps clarify your path:
Level 1: Companies handling only Federal Contract Information complete a self-assessment covering 17 basic cybersecurity practices. Most businesses can complete this level within 30 to 60 days.
Level 2: Companies handling Controlled Unclassified Information (CUI) must achieve Level 2 certification, aligning with the 110 security requirements of NIST SP 800-171. While self-assessment may be permitted in rare, low-risk circumstances (subject to DoD waiver approval), most contracts will mandate third-party certification by a C3PAO for independent assurance. Preparation typically takes 3 to 6 months, including gap analysis, implementation, and documentation.
Level 3: Companies handling the most sensitive CUI must meet 24 additional requirements from NIST SP 800-172. Level 3 assessments are conducted by the DoD’s DIBCAC at no charge.
Defense contractors handling Controlled Unclassified Information will need Level 2 certification, which requires third-party validation following established NIST SP 800-171 standards that many companies have already begun implementing.
The Smart CMMC Approach
Rather than viewing CMMC as a compliance burden, successful companies are treating it as an infrastructure investment that will pay off for years. The smart approach involves four phases:
Phase 1: Quick Assessment (1-2 weeks): Review your current contracts to determine whether you handle Federal Contract Information (FC)I or CUI, and identify your required CMMC level. This clarity drives all later decisions.
Phase 2: Gap Analysis (2-4 weeks): Check your current cybersecurity against CMMC requirements. Focus on identifying quick wins that can be done immediately alongside longer-term investments.
Phase 3: Strategic Implementation (3-6 months): Address gaps step by step, focusing on controls that offer both compliance value and business benefits. This isn’t about checking boxes; it’s about building security that strengthens your entire operation.
Phase 4: Certification and Maintenance (1-3 months): Complete the formal assessment and establish ongoing compliance procedures. Certifications last three years, with annual updates ensuring continued compliance.
Companies that begin this process now will complete certification before the marketplace becomes crowded, securing first mover advantages that last long after certification becomes required.
Beyond Compliance: How Certification Becomes a Business Enabler
The most successful CMMC implementations go beyond meeting minimum requirements to create lasting competitive advantages:
Enhanced Due Diligence: Certified companies often become preferred partners not just for defense contracts but for commercial work where cybersecurity matters. The discipline required for CMMC certification translates to overall operational excellence.
Supply Chain Leadership: First mover companies can be selective about their own suppliers and partners, building certified supply chains that provide additional competitive advantages.
Innovation Capacity: With cybersecurity frameworks in place, certified companies can pursue advanced opportunities like AI integration and cloud modernization without compliance distractions.
Act While the Window Is Open
The defense contracting landscape is about to change permanently. Companies that achieve CMMC certification in the next 9 to 12 months will enter a select group of contractors eligible for the full range of DoD opportunities. Those who delay will find themselves competing within a crowded pool of late adopters.
The choice isn’t between compliance and non-compliance. The choice is between capturing first mover advantages and accepting commodity status in a compliance-driven market.
As a CMMC Registered Practitioner Organization, Richey May has guided companies through this change, helping them see beyond regulatory requirements to the business opportunities CMMC certification creates. Our experience with complex regulatory frameworks in financial services and media translates directly to defense contracting challenges.
The window for first mover advantage is open, but it won’t stay that way. Companies that begin their CMMC certification process now will be industry leaders when their competitors are still figuring out where to start.
If you’re ready to transform CMMC compliance from a regulatory requirement into a competitive advantage, contact our cybersecurity experts today for a complimentary readiness consultation.
