{"asOf":"2026-09-05","merchant":"SSDF INC","kind":"event","id":"phase-2-pause","date":"2026-07-13","title":"CMMC Phase 2 paused","kicker":"C3PAO-at-award on hold","status":"paused","body":"DoW CIO paused Phase 2 (C3PAO certification as a condition of award, which had been set for 10 November 2026) and froze later milestones pending a 60-day reform review. Phase 1 self-assessment remains. DFARS 7012 remains. Voluntary C3PAO assessments remain valid. Active solicitations that already required C3PAO/Level 3 were to be amended to remove those requirements.","clerk":"DoW CIO memo 26-P-1023 (13 Jul 2026)","cites":["DoW news release 13 Jul 2026","Crowell client alert 13 Jul 2026"],"notes":["A CMMC how-to that still treats 10 Nov 2026 as the C3PAO cliff is stale.","Task Force report was due around mid-September 2026 — re-verify this row after that date."]}