CMMC Ready Now
Back to Knowledge Center
DFARS & Legal4 min read

DFARS 252.204-7021: The CMMC Contract Clause

The CMMC clause itself — making certification a condition of contract award. Went into effect in June 2025. If this clause is in your solicitation, you must be CMMC-certified to win the work.

DFARS 252.204-7021 is the CMMC contract clause — the mechanism by which a specific CMMC level becomes a condition of contract award. When this clause appears in a solicitation, it specifies the required CMMC level (1, 2, or 3) that the awardee and relevant subcontractors must hold at time of award.

What 7021 actually says

  • The contractor shall have, and maintain during contract performance, a CMMC certificate at the level specified in the contract
  • The contractor shall not award a subcontract if the subcontractor is required to handle CUI, unless the subcontractor has the appropriate CMMC level
  • Annual affirmations are required — a senior official must affirm that the certification remains accurate
  • Conditional certifications (with an active POA&M) are valid for award purposes under specific conditions

Timeline: when 7021 started appearing in contracts

Phase 1 (December 2024) allowed 7021 to appear in contracts with Level 1 and conditional Level 2 self-assessment requirements. Phase 2 (June 11, 2025) expanded this to require C3PAO-assessed Level 2 certifications in new contracts for prioritized acquisitions.

False Claims Act exposure

Senior officials who affirm compliance with CMMC requirements while knowing the organization does not actually meet them face liability under the False Claims Act (31 U.S.C. § 3729). Affirmations must be honest.

Ready to start your CMMC journey?

Book a free 30-minute call with Rick to get a straight answer on where you stand and what to do next.