Requirement guide Bid eligibility
Can I bid without CMMC?
A missing CMMC status does not produce one answer for every opportunity. Some packages specify no CMMC requirement; others require a stated level before award and request identifiers with the proposal. Check whether you can meet the actual access, submission and award conditions before committing resources. The July 2026 Phase II suspension does not end Phase I or remove separate safeguarding and NIST SP 800-171 assessment obligations where they apply. An absence of CMMC language also does not establish technical qualification or entitlement to award.
Decision basis: DFARS 252.204-7021DFARS 252.204-7025 (November 2025)DFARS 252.204-7020CMMC Phase II suspension implementation direction
What to confirm
The governing solicitation, contract, or flowdown establishes the requirement. Company leadership authorizes the bid. Only the contracting parties can change the stated requirement.
Continue the review
- Use the pursuit decision checklist
Identify supported conditions, unresolved work and the decision owner.
- Review source approval
Investigate a separate technical qualification condition.
Organize the requirement, work, and evidence.
Deep Fathom records the source requirement, accountable owner, assigned work, supporting evidence, and review history. The team can then review the specific requirement instead of searching across disconnected documents.
Review bid requirementsSources
- DFARS 252.204-7021Current CMMC status, annual affirmation, and CMMC flowdown requirements where the clause applies.Official source ↗
- DFARS 252.204-7025 (November 2025)Solicitation level, award eligibility, affirmation and proposal identifiers.Official source ↗
- DFARS 252.204-7020NIST SP 800-171 DoD assessment requirements, including Basic Assessment and subcontract provisions.Official source ↗
- CMMC Phase II suspension implementation directionJuly 2026 direction: Phase I continues; solicitation amendments and contract modifications have different timing. Reviewed September 7, 2026.Official source ↗