[Open — title card: "Is it still binding?"]
If your company handles non-public DoD contract information on its own systems — and you're not selling purely off-the-shelf products F29 — CMMC is already built to reach you: DoD's stated Phase 1 intent is self-assessment as a condition of award, and where a solicitation carries the requirement, there's no award without your current status in SPRS F22F23F28. And in July, the ground moved: on July 13, 2026, the Pentagon suspended the Phase 2 requirements scheduled for November 2026 — and every pending and future milestone with them F31.
[Beat — "What did NOT change"]
Here's what the headlines miss: the suspension is administrative. The regulations were never amended F24F31. And every independent report of the memo agrees: your self-assessments, your SPRS score, and your DFARS clause obligations continue to apply F31F30F37.
[Beat — "The two kinds of information"]
Everything keys off two terms. Federal Contract Information — non-public information from your government contract work F33. Controlled Unclassified Information — information the government requires safeguarded F34. Hold only FCI and no CUI? For subcontractors, that means Level 1 F12: fifteen safeguarding requirements, self-assessed annually, no POA&Ms allowed, ever F06F07. Any CUI? Level 2 minimum — the 110 requirements of NIST SP 800-171 Revision 2 F12F05. And if you're a prime, the solicitation sets your level F23F25. Don't guess which information you hold — ask your contracting officer or your prime, in writing.
[Beat — "The trap"]
That annual affirmation a senior representative signs in SPRS F17F18? Legal analysts warn a false certification is a False Claims Act problem — treble-damages territory F35. One contractor self-scored a perfect 110; the government's assessors scored them at negative 170. That settlement cost $507,144 F39.
[Close — card: stillbinding.com]
Rules move by memo now, not just by rulemaking. We verify every claim to a citation, a verbatim quote, and a date — and tell you honestly what's still binding. The full lesson and the fact store are at stillbinding.com.