Is your GRC Platform ready for CMMC Phase 2?

Under CMMC 2.0, every cloud tool that touches Controlled Unclassified Information, including your GRC platform, must meet FedRAMP Certified Class C (Rev5) standards. Hyperproof Gov is already there.

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Where things actually stand

On July 13, 2026, the DoW suspended mandatory third-party C3PAO certification for Level 2, pending a 60-day Reform Task Force review due mid-September 2026. Self-assessment is now the only path a contracting officer can designate. But that’s not the lower-stakes option it sounds like: you’re now the one attesting to your own SPRS score, and DOJ’s Civil Cyber-Fraud Initiative doesn’t distinguish a false third-party attestation from a false self-attestation.

What CMMC looks like in 2026

CMMC 2.0 is no longer something that’s on the horizon. The 32 CFR rule took effect December 2024. The 48 CFR DFARS acquisition rule went live in September 2025. Phase 1 is active now, requiring Level 1 and Level 2 self-assessments in applicable DoD solicitations.

Source: https://dodcio.defense.gov/CMMC/about/

1 Phase 1

Active Now

Nov 10, 2025

Applicable solicitations require Level 1 or Level 2 self-assessment.

2 Phase 2

TBD – Suspended July 13th, 2026

Would have required Level 2 certification for applicable solicitations.

3 Phase 3

Status tied to Phase 2 outcome

Would require Level 3 certification for applicable solicitations.

4 Phase 4

Full Implementation

Nov 10, 2028

All solicitations and contracts will include applicable CMMC Level requirements as a condition of contract award.

What didn’t change

1 NIST SP 800-171 Rev. 2’s requirements

2 DFARS 252.204-7012 and your annual affirmation obligation

3 False Claims Act liability for inaccurate self reporting

4 Prime contractor flow-down clauses requiring self-reported CMMC posture

5 FedRAMP Certified Class C (Rev5) as the hosting standard for any tool touching CUI

The numbers don’t lie

CMMC has become a contract eligibility filter

~ 100

Authorized C3PAOs available

Serving an estimated 118,000 organizations seeking Level 2 certification

18 mo

Projected C3PAO wait times due to increased demand

Expected rise in assessment fees

By late 2026, as demand overwhelms supply.

33–44k

Companies projected to exit

Leaving the defense market by 2027.

15–20%

Of the entire Defense Industrial Base priced out or pushed out of the defense market by 2027.

Why your GRC platform must be FedRAMP Certified Class C (Rev5)

Here is where most organizations get surprised.

Under DFARS 252.204-7012 and the CMMC rules, any cloud services that are used to process, store, or transmit CUI must meet FedRAMP Certified Class C (Rev5) OR pass the DoD’s equivalency standard. That requirement applies to your GRC platform and cannot be met with a FedRAMP-certified Class C (20x) tool.

What if I use a non-FedRAMP GRC tool?

Using a non-FedRAMP GRC tool to manage your CMMC process creates a gap in your own assessment boundary. During a C3PAO evaluation, assessors verify the authorization status of every in-scope cloud service. A tool that fails this check doesn’t just create a finding; it can derail the entire certification.

What if I pursue DoD equivalency?

Pursuing DoD equivalency is harder than it looks. It requires 100% control implementation with zero POA&Ms, a full 3PAO-assessed Body of Evidence, monthly vulnerability scans, and annual reassessments. For a GRC platform, the far simpler, lower-risk path is selecting one that already has FedRAMP Moderate authorization.

How does Hyperproof solve the CMMC compliance problem?

Hyperproof achieved FedRAMP Certification Class C (Rev5) in March 2026

Available now as Hyperproof Gov, it brings everything you rely on in Hyperproof’s GRC platform, plus capabilities purpose-built to meet FedRAMP’s elevated security requirements.

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Core capabilities

Compliance automation

Centralizes GRC workflows across 160+ pre-built frameworks with cross-framework mapping, satisfying multiple requirements with a single control.

Deep integrations

Hypersyncs automatically pull evidence from cloud and identity platforms while native integrations keep workflows connected.

Risk and vendor management

A centralized system to identify, score, and remediate organizational risk.

Audit readiness

Streamlines audits by linking evidence to requests, automates trust center operations, and accelerates questionnaire responses with verified control data.

Additional capabilities

Malware protection

Files scanned on upload / download.

System use notification

On login or after a set number of days, consent of terms of system use.

Deactivate inactive users

Automatic user deactivation on a schedule.

User change notifications

Get notified when a user has been added, deactivated, or a role has changed.

Sanitized email notifications

User provided information is not included to meet FedRAMP requirements.

Event logging

Ability to stream system events for monitoring.

Hyperproof is the only GRC platform that is both FedRAMP Class C Certified (Rev5) and purpose-built for the operational complexity of enterprise-grade CMMC programs

If your organization handles CUI and plans to bid on DoD contracts beyond November 2025, the time to act is now.

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Frequently asked questions

DoW suspended mandatory C3PAO certification on July 13, 2026 pending a 60-day review due mid-September 2026. Until then, contractors can carry Level 1 (Self) or Level 2 (Self).

No — and this is where many organizations underestimate the work. CMMC readiness isn’t just about having the right controls in place. It’s about documenting them in a system that holds up to assessor scrutiny. Every cloud service used to process or store CUI must be FedRAMP Certified Class C (Rev5) — formerly known as FedRAMP Moderate Authorized. That requirement includes your GRC platform.

It creates a gap in your assessment boundary. During a C3PAO evaluation, assessors verify the certification status of every in-scope cloud service. A non-FedRAMP GRC tool doesn’t just generate a finding — it can derail your entire certification. Assessors don’t make exceptions for tools that are “close” or “in progress.”

FedRAMP Certified Class C (Rev5) is the current designation for what was formerly called FedRAMP Moderate Authorization. It’s the minimum standard required for cloud services that process, store, or transmit CUI under DFARS 252.204-7012 and CMMC rules. This certification is stricter than Class C (20x) and is the only Class C certification that satisfies CMMC L2 requirements. Hyperproof achieved this certification in March 2026 and is available as Hyperproof Gov.

Hyperproof Gov is Hyperproof’s FedRAMP Certified Class C (Rev5) GRC platform and is purpose-built to meet the compliance requirements of defense contractors managing CMMC programs. It includes all the core capabilities of the Hyperproof platform plus additional controls required under FedRAMP, including malware protection, event logging, inactive user deactivation, sanitized email notifications, and more.

Get CMMC ready with Hyperproof Gov.