It’s easy to hear “certification paused” and think “I can relax.” That would be a mistake, for three reasons.

1. You’re now grading your own homework, which is riskier, not safer.
   Every score you submit is something the government can hold you accountable for. Without an outside assessor double-checking your work, the accuracy of your own self-assessment matters even more, not less.
2. Your prime contractor may not care what the Pentagon paused.
   Large defense contractors (the “primes” who often hire smaller companies as subcontractors) have kept requiring outside certification anyway, because it protects them too. If your prime still requires it, the federal pause doesn’t help you.
3. This is a memo, not a law.
   A memo can be reversed just as fast as it was issued. The task force’s report is due around mid-September 2026, and the certification requirement could come right back, get revised, or get replaced with something new. If you let your security work slide now, you may be scrambling again in the fall, with less time to catch up than you have today.

Here’s the simplest way to think about it: CMMC was never its own separate rulebook. It’s a way of checking whether you’re following NIST’s rules. The security checks a CMMC assessor looks for, all 110 of them at the mid level, are NIST requirements. Take away the audit, and the actual requirement, protecting sensitive data the way NIST says to, is still sitting right there.

That’s why we build client security programs on the NIST framework itself, not on chasing whatever CMMC’s audit process looks like this year:

• NIST doesn’t change every time a policy does. CMMC’s rules and deadlines have shifted several times since 2020. NIST’s core requirements have stayed steady through all of it.
• Doing NIST right covers you in multiple places at once. The same security work satisfies your breach-reporting rule, your self-assessment, and, if outside certification comes back, that audit too. You’re not starting over each time.
• It protects you no matter who’s asking. Prime contractors, contract officers, your cyber insurance company, and any future auditor all point back to the same NIST baseline. Build to that standard, not to whatever the audit process happens to require this year, and you’re ready regardless of what changes next.

The pause changes who’s checking your work. It doesn’t change what the work is. Here’s what to focus on:

1. Keep your self-assessment score up to date. Don’t let it go stale just because the outside audit deadline moved.
2. Watch your remediation deadlines. If you have open items you promised to fix, that clock is still running, pause or no pause.
3. Check on your subcontractors. If companies you work with handle sensitive data, you’re still responsible for confirming they’re doing things right before you bring them onto a project.
4. Keep documenting your security work now. If outside certification comes back this fall, companies with good records will be able to get certified fastest and cheapest.
5. Keep an eye on the task force report. It’s expected around mid-September 2026 and will shape what comes next. Don’t bet your whole plan on one specific outcome.

Tech River builds security programs around NIST guidelines and best practices, so our clients stay protected and compliant no matter what happens with CMMC next. If you’d like help understanding where your business stands