Subcontractor CMMC Tracker
Findings · finding 8 of 12

Subcontractor CMMC assessment or affirmation expiring in 90 days

The SPRS assessment, the CMMC status, the affirmation or the POA&M window lapses within 90 days of the as-at date. Ninety days is a window this register sets for chasing, not a legal deadline.

What the register reads

a date to chase

Chase the renewal before the date shown.

The rule sentences behind it

4 cited
DFARS 252.204-7021, "current" (2)(ii)codified text, eCFR current to 24 Sep 2026; the same text is carried in Class Deviation 2026-O0025, effective 1 Feb 2026

Not older than 3 years for Final Level 2 (Self) assessments and Final Level 2 (C3PAO) assessments, with (A) No changes in compliance with the requirements at 32 CFR part 170 since the Final CMMC Status date (see 32 CFR 170.16 and 170.17); and (B) A corresponding affirmation of continuous compliance, not older than 1 year, by an affirming official

Threshold read: Final Level 2: not older than 3 years, affirmation not older than 1 year. Source
DFARS 252.204-7021, "current" (2)(i)codified text, eCFR current to 24 Sep 2026; the same text is carried in Class Deviation 2026-O0025, effective 1 Feb 2026

Not older than 1 year for Final Level 1 (Self), with (A) No changes in compliance with the requirements at 32 CFR part 170 since the Final CMMC Status date (see 32 CFR 170.15); and (B) A corresponding affirmation of continuous compliance, not older than 1 year, by an affirming official

Threshold read: Final Level 1: not older than 1 year. Source
32 CFR 170.22(a)codified text, eCFR current to 24 Sep 2026

An Affirming Official from each OSA, whether a prime or subcontractor, must affirm the continuing compliance of their respective organizations with the specified security requirement after every assessment, including POA&M closeout, and annually thereafter.

Threshold read: affirmation after every assessment and annually thereafter. Source
32 CFR 170.21(b)codified text, eCFR current to 24 Sep 2026

The closing of a POA&M must be confirmed by a POA&M closeout assessment within 180-days of the Conditional CMMC Status Date. If the POA&M is not successfully closed out within the 180-day timeframe, the Conditional CMMC Status for the information system will expire.

Threshold read: POA&M closeout within 180 days of the Conditional CMMC Status Date. Source

A line that raises it

invented

Saltmarsh Electronics | 1SE52 | 105 | 2023-12-01 | Level 2 (Self) | 2026-06-01 | yes | no | yes

See it in the specimen