November 10th, 2025 changes everything for defense contractors.
If you handle Controlled Unclassified Information (CUI), 48 CFR compliance isn't optional anymore. It's the law. And if you're reading this in late October, you have days—not months—to respond.
The question isn't "when should we start?" It's "what can we do right now?"
What Changes on November 10th
48 CFR creates new rules for CMMC compliance. Here's what happens immediately:
New Contracts Get New Rules: All DoD contracts after November 10th include CMMC requirements. If you're bidding on new work, these rules apply now.
Your Customers Will Ask Questions: Prime contractors must require CMMC from subs. They'll ask about your status right away. "We're working on it" won't be good enough.
You Need a Real Plan: You must show a clear path to certification with documented timelines, gap assessments, and proof of real progress.
More Scrutiny: Your security posture becomes either a competitive advantage or a deal-breaker.
The Q4 Reality
Here's what you're working with: 33 working days from November 10th to year-end. Most 2025 budgets are spent. Holidays slow everything down. Assessment companies are booked months out.
The truth: You can't get certified by December 31st.
But you CAN:
- Show real progress
- Build a clear roadmap
- Position for early 2026 success
- Prove to customers you're serious
Your Q4 Action Plan: Three Phases
Phase 1: Immediate Actions (November 10-30)
Find Your Gaps Review CMMC Level 2 requirements. Check what you have versus what you need. Be honest. Write down every gap.
Map Your CUI Find every system storing or processing CUI. Document where it flows. Include file shares, email, archived data. You can't protect what you can't see.
Create Your Timeline When can you finish implementations? When can you schedule assessment? Make it realistic, not wishful thinking.
Communicate Brief leadership on what's happening. Ask customers about their expectations and timelines.
Phase 2: Build Foundation (December 1-15)
Implement Quick-Win Controls
These five make the biggest immediate impact:
Multi-Factor Authentication (MFA): Add to every system touching CUI. Required for CMMC Level 2. Stops 99% of credential attacks. Deploys in weeks.
Password Policies: Require strong passwords, use password managers, enforce changes. More policy than spending.
Access Cleanup: Remove ghost accounts from former employees and old vendors. Document who needs what and why.
Backup Testing: Don't just run backups—test them. Try restoring files regularly. Untested backups aren't real backups.
Security Training: Launch training in December. Gives you January-February to see results before assessments begin.
Start Documentation Begin your System Security Plan (SSP). Write down current security practices—including gaps. Be honest. You can improve documented processes.
Phase 3: Set Up 2026 (December 16-31)
Schedule Gap Assessment Book third-party assessment for January or early February. Costs a few thousand dollars but prevents expensive surprises during certification.
Research C3PAOs Talk to assessors now. Best ones book months ahead. Ask about approach, timeline, and pricing.
Create Q1 Roadmap Build week-by-week action plan. What gaps need closing? Who owns each task? Team should know exactly what they're doing from day one.
Prepare Budget Request Build your business case for 2026. Show investment cost versus non-compliance cost. CFOs respond to clear ROI.
What Success Looks Like by Year-End
You CAN Accomplish:
- Complete gap assessment
- Implement 3-5 foundational controls
- Start System Security Plan
- Launch security training
- Schedule January assessment
- Create detailed 2026 roadmap
You Probably CAN'T:
- Full CMMC Level 2 certification
- Complete all 110 practices
- Full documentation ready
The goal is real progress and clear direction—not perfection.
Common Objections
"We're waiting to see enforcement" 48 CFR is law. Primes can't work with non-compliant subs—it risks their compliance. Waiting is gambling.
"Requirements will change" Maybe. But basic security controls are fundamentals every company needs regardless of framework.
"We can't afford this" Compliance costs thousands. Non-compliance costs lost contracts. Many controls here need time more than money.
Your Action Steps This Week
Day 1-2: Review CMMC requirements. Document what you have and what's missing.
Day 3: Create simple timeline. Identify quick wins versus long projects.
Day 4: Brief leadership. Request resources. Assign ownership.
Day 5: Take first action—implement one control, schedule January assessment, or start documenting CUI.
One week moves you from "we need to do something" to "we've started."
The Bottom Line
48 CFR takes effect November 10th. You can't change that date. You can control your response.
Successful contractors face reality quickly, prioritize smartly, and take consistent action with available resources.
Q4 will pass whether you use it strategically or not. Where will you be January 1st, 2026? With measurable progress and clear plans? Or still figuring out where to start?
The deadline isn't coming. It's here.
Need help creating your 48 CFR compliance roadmap? Prescott specializes in guiding defense contractors through CMMC compliance. Schedule a consultation to discuss your specific situation.
