We have watched three CMMC deadlines slip in three years. The behavioral pattern across the small-business defense ecosystem is, accordingly, to discount any new deadline by roughly 60 percent. We think that’s the wrong call this time.
We have spent the better part of three months running the underlying obligations data against agency strategic plans and the FY26 President’s Budget Request. The result is less a story than a pattern — and the pattern is not what the trade press has been describing.
84%
Recent DoD RFPs flowing down CMMC 2.0 clauses
— SAM.gov; author analysis of 612 solicitations
The DFARS clause activity nobody is reading
The 7012, 7019, 7020, and 7021 clauses have been flowing down at a markedly higher rate in solicitations issued since March. That is the leading indicator. Past slips were preceded by clause-flowdown stalling; current data shows the opposite.
“We told our subs the deadline would slip. It didn’t. We are now compliant on paper and operationally three months behind.”— A contracting officer at a mid-tier civilian agency, speaking on background
What that means for an operator at $5M to $50M in annual federal revenue is unambiguous: the surface area you can reasonably cover is shrinking, and the cost of being wrong about which vehicles to chase has roughly doubled since FY23.
Contrarian
The conventional advice — add more NAICS codes, get on more schedules, hire a former agency PM — is exactly the wrong response to this cycle. Concentration, not coverage, is the only durable answer.
We will keep tracking this through the end of the fiscal year. If the pattern holds through Q4, the implications for the FY27 budget cycle are larger than anything we have written about in the past twelve months.
