DFARS 252.204-7025 is titled “Notice of Cybersecurity Maturity Model Certification Level Requirements”. It is a solicitation provision, not a contract clause. It appears when the government adds DFARS 252.204-7021 to the resulting contract.In plain terms, 7025:
- Tells you which CMMC level the solicitation requires.
- Tells you that you must have a current CMMC status in SPRS at that level for each in-scope system.
- Tells you that you must have a current affirmation of continuous compliance in SPRS.
- Makes both of those a condition of award eligibility.
If those items are not current and correct, the government cannot legally award the contract to you.
Your CMMC award eligibility checklist for DFARS 252.204-7025
Use this checklist before you commit to a CMMC related bid. Treat it like a short pre-bid gate review.
1. Read the exact CMMC level in the solicitation
In the 7025 provision, the contracting officer fills in one required level:
- CMMC Level 1 (Self) for FCI only
- CMMC Level 2 (Self) for limited CUI cases
- CMMC Level 2 (C3PAO) for most CUI contracts
- CMMC Level 3 (DIBCAC) for the most sensitive CUI
First step: confirm that your current or planned CMMC status actually matches that level for the systems you will use on this contract.
Quick check
- If you only have a NIST SP 800 171 self assessment on file but the box says Level 2 (C3PAO), you have a gap.
- If you have a Level 2 certificate but the work will touch systems not covered by that assessment, you also have a gap.
2. Map the bid to in scope systems, not just your company
CMMC and 7025 do not care about your company in general. They care about the specific systems that will process, store, or transmit FCI or CUI for this contract.
For each bid:
- List the systems that will touch FCI or CUI.
- Mark which ones are inside your CMMC boundary.
- Confirm that each system has or will have the required CMMC level.
If you are a prime, include major subs that will handle CUI. DFARS 252.204-7021 and the final rule expect subcontractors to have their own status and entries in SPRS, even though you cannot see their scores directly.
3. Verify your CMMC status in SPRS
Next, move from paper to the real system the government checks: SPRS.
For each in scope system, confirm that:
- There is a CMMC status posted in SPRS at the required level.
- The status is current. Under the final rule, a status is generally valid for three years from the assessment date.
- The status is recorded under the correct CAGE code and environment.
If you went through a third party assessment, confirm that the C3PAO completed the process and that the record shows as final, not just “in progress”.
4. Confirm your annual affirmation is up to date
The rule introduces an “affirming official” who must make an annual affirmation in SPRS that you are meeting your CMMC requirements. The term replaces older “senior company official” language, but the intent is the same.
Ask three simple questions:
- Who is our affirming official of record for this environment
- When was the last affirmation submitted in SPRS
- Does that affirmation clearly cover the systems and level we will use on this bid
If the affirmation is older than one year on the date of award or covers the wrong scope, your eligibility is at risk even if the CMMC status itself is still within the three year window.
5. Handle conditional CMMC status and POA&M deadlines
Under the final rule, you can be awarded a contract based on a conditional CMMC status if certain gaps are documented in a POA&M. You then have 180 days to close those items and reach full status.
For each contract you are bidding:
- Confirm whether any in scope system will rely on a conditional status.
- Review the POA&M items and confirm they meet the rule’s limits on what can be deferred.
- Make sure the 180 day timeline fits your real plan, including holidays and vendor lead times.
This is a good place to pull in lessons from your outage or drill work. If patch cycles, vendor upgrades, or network changes are slow during peak periods, plan those POA&M items earlier in the year.
6. Check your subs early
Many contractors are surprised when a strong proposal fails because a critical subcontractor is not ready.
For any sub that will process FCI or CUI for this contract:
- Confirm which CMMC level and scope they are using.
- Ask them to confirm that they have a current status and affirmation in SPRS.
- Align your teaming agreements or flowdowns with those expectations.
You will not see their SPRS details, but you can still make “award readiness” part of your partner selection and capture process.
7. Align your story: SSP, boundary, and bid language
DFARS 252.204-7025 is short, but it hooks into a larger story that includes your:
- System Security Plan (SSP)
- CMMC assessment results
- Diagrams that define your boundary
- Incident response and continuity procedures
Make sure the way you describe your environment and controls in the proposal matches what sits in SPRS and in your SSP. Misalignment here can lead to tense questions in negotiations or during later assessments.
If you recently walked through outage drills, Cloudflare style resilience checks, or tabletop exercises, pull those notes into your evidence set. They support the idea that your security program is real, tested, and tied to your policies.
A 30 day CMMC award readiness sprint
If you want a simple path between now and your next CMMC related bid, use this short sprint.
1st Week: Get clear on your current state
- Pull your latest CMMC reports and SPRS entries.
- List systems that will support your top target opportunities.
- Confirm the required CMMC levels from recent or upcoming solicitations.
2nd Week: Fix obvious blockers
- Update or complete CMMC self assessments where allowed.
- Schedule any needed C3PAO work for Level 2 or 3.
- Correct CAGE codes, system names, or scope issues in your internal records.
3rd Week: Clean up SPRS and affirmations
- Make sure each in scope system has a current status in SPRS.
- Submit or renew affirmations where required.
- Document who owns ongoing updates.
4th Week: Bake eligibility checks into your capture process
- Add a short “7025 gate check” to bid reviews.
- Define who signs off that CMMC status and affirmations are ready for each opportunity.
- Capture lessons and adjust your internal checklist.
By the end of this sprint, your team can answer a simple but powerful question before every proposal:
“If the contracting officer checked DFARS 252.204-7025 and SPRS right now, would we be clearly eligible for award”
How Centrend can help your team move faster
CMMC and DFARS 252.204-7025 are not just more paperwork. They are now part of the basic gate that decides who can win and who never makes it to evaluation.
Centrend can help your team:
- Map contracts to CMMC levels and in scope systems.
- Review your CMMC and SPRS posture against the new rule.
- Build a simple, repeatable CMMC award eligibility checklist into your capture and proposal reviews.
If you want a quick outside view of where you stand, Centrend can lead a short DFARS 252.204-7025 Award Readiness Assesment Call so your next CMMC bid starts from a stronger position.