What Changed in Feb 2026: SPRS + Annual Affirmations Are Now Non-Negotiable
If you’re a DoW subcontractor, the biggest CMMC risk in 2026 isn’t “we’re not perfect yet.”
It’s being not current in SPRS when a prime (or contracting officer) needs proof fast.
In Feb 2026, the U.S. Department of Defense issued a class deviation (DARS 2026-O0025) tied to the DFARS Revolutionary FAR Overhaul, updating DFARS Part 240 and creating/using the clause 252.240-7997 for how DoW handles NIST SP 800-171 DoW assessments and SPRS posting.
Here’s the practical takeaway for subcontractors: SPRS is now the “system of record” that the government and primes rely on. If your records/affirmations aren’t current, you can get treated like you’re not eligible – even if you’re doing the work.
No “Current” Status = Slowdowns, Lost Awards, or Getting Dropped
The DFARS CMMC clause already requires contractors to:
Maintain a current CMMC status at the required level for systems used on the contract
Provide the CMMC UID(s) for systems that will touch FCI/CUI
Complete and keep a current annual affirmation in SPRS (this is critical)
Ensure subcontractors also affirm annually before subcontract award
So what changed in Feb 2026?
This deviation strengthens the operational side: DoW’s Medium/High NIST SP 800-171 assessments (run by Defense Contract Management Agency personnel) take precedence over other assessments and the summary scores get posted in SPRS for DoW visibility. In plain English: your SPRS footprint matters more than ever—because that’s what gets checked and referenced.
The Real Change (Feb 2026): SPRS Becomes the “Source of Truth” Faster
Before
Many subcontractors focused on “doing CMMC work” but didn’t treat SPRS + UID + annual affirmation as an always-on requirement.
If something was missing, it often got discovered late—during onboarding, teaming, or award.
Now
DoW is tightening how assessments are handled and standardizing SPRS posting/precedence for NIST SP 800-171 DoW assessments.
Meanwhile, DoW CIO is explicitly reminding contractors to submit affirmations with CMMC assessments in SPRS during Phase 1.
Why This Hits Small DoW Subcontractors the Hardest
Small teams usually struggle with:
Scoping (what’s actually in/out of the environment)
SPRS/PIEE access + roles
Knowing what a CMMC UID is and why it matters
Keeping up with “maintenance tasks” like annual affirmations
What To Do Now (Practical Steps You Can Take This Month)
Confirm whether you handle CUI (or are about to)
If you’re touching CUI – or bidding into programs likely to involve CUI – assume Level 2 is coming.
Scope your environment the right way
Identify where contract data lives:
endpoints, email, file storage, cloud apps, remote access
Identify your CMMC UID(s)
A CMMC UID is a 10-character identifier tied to each contractor information system’s assessment record in SPRS.
Make sure required results are in SPRS
Calendar the annual affirmation (do not let it expire)
How Cyber Security Solutions Helps Contractors Stay “Bid-Ready”
We help subcontractors move from “we’re working on it” to “we can prove it”:
Scope correctly (avoid over-scoping and wasted spend)
Build a clean Level 1 / Level 2 path aligned to what you actually handle
Prepare your assessment evidence in the format auditors/primes expect
Get you SPRS-ready: UID mapping + documentation + a cadence so affirmations never lapse
Ongoing support so your status stays current year-round
CMMC Enforcement: The Timeline Hasn’t Changed
DoW CIO states Phase 1 is active (Nov 10, 2025 – Nov 9, 2026) and focuses primarily on Level 1 and Level 2 self-assessments, with a clear reminder about SPRS affirmations.
Our pricing is fully transparent and scales with your team size and compliance scope:
Startup Plan — $200 / month / device (Level 1)
For small business teams. Covers up to 3 devices with managed firewall, VPN, SOC monitoring, encryption, and compliance dashboard.
CSS Enclave Plan — $1,250 / month (Level 1 & 2)
For growing teams (4–10 devices) needing full Level 2 alignment and 24/7 U.S.-based SOC support.
CSS Net Plan — $2,100 / month (Level 2 readiness)
For larger organizations (11–25 devices) needing continuous monitoring, documentation management, and enterprise-level control.
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