The CMMC Final Rule went into effect on November 10, 2025. Many suppliers, especially those at Level 1, are either not prepared despite the interim rule that has been in effect or completely caught off guard by the requirement. Level 1 requirements are simple but still mandatory. Whether you’re a prime contractor or a subcontractor, knowing exactly what is required will save time, prevent delays, and keep your awards on track.
This quick guide breaks it down from both sides:
✓ What primes must request from vendors
✓ What vendors must prepare to comply
✓ How to get started with SPRS
Why Level 1 Is Important (and Why It’s Showing Up Now)
CMMC Level 1 applies to contractors that handle Federal Contract Information (FCI) only. FCI is information not intended for public release that is provided by, or generated for, the Government under a contract to develop or deliver a product or service to the Government, but not including information provided by the Government to the public (such as that on public Web sites) or simple transactional information, such as that necessary to process payments. Level 1 does not involve CUI (Controlled Unclassified Information) and does not require third-party audits. However, it is required whenever the Prime Contract includes the applicable CMMC clauses.
Prime contractors only need to flow down CMMC Level 1 when a subcontractor will handle Federal Contract Information (FCI). Primes are responsible for confirming that those vendors are compliant. Primes should also be ready to substantiate when Level 1 does not apply, for example, when a subcontractor will not receive or generate FCI. Before the award is issued, vendors should be prepared to provide the Prime evidence of::
· A self-assessment
· Posting that assessment in SPRS
· Maintaining basic cybersecurity hygiene policies.
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What Primes Need to Request From Their Vendors (Level 1)
When issuing a subcontract or PO under a Level 1 requirement, primes should request three items:
1. SPRS Assessment Screenshot:
Contractors do not have access to vendors’ SPRS scores. Vendors must provide a screenshot showing their posted assessment, score, and data in the Supplier Performance Risk System (SPRS).
2. System Security Plan (SSP):
Even at Level 1, vendors must have a written cybersecurity plan describing how they meet the 15 basic safeguarding requirements in FAR 52.204-21.
Primes should request evidence of an SSP but are not entitled to receive the full plan (it may be sensitive).
Vendors can provide:
a. A sanitized copy, or
b. A confirmation letter summarizing or evidence of their cybersecurity posture
3. Self-Assessment Score:
For most vendors, this will be included in the SPRS screenshot.
Primes should verify:· The score exists in SPRS
· It is less than 12 months old
· The vendor has an annual affirmation process in place
What Vendors Need to Do to Comply with Level 1
1. Perform a Level 1 Self-Assessment
This covers 15 basic security practices (antivirus, access control, patching, etc.). The DoD provides a simple checklist which can be found at dodcio.defense.gov/resources-documentation.
2. Create or Update the SSP
For Level 1, the SSP should map only to the 15 FAR 52.204-21 safeguarding requirements—not the full NIST 800-171 controls used at Level 2.
At a minimum, the SSP should include:
· A written plan (required even at Level 1)
o Describing how each of the 15 practices is implemented.
3. Upload the Score to SPRS
Vendors need:
· A CAC or log-in through PIEE
· The “SPRS Cyber Vendor User” role
Once approved, they can enter:
· Assessment score
· Date of assessment
· System security plan scope
Note: The SPRS score must be updated annually.
4. Keep Documentation Ready for Primes
· To streamline subcontract awards, vendors should prepare a small “CMMC Level 1 Package” to send when asked: SPRS screenshot
· SSP summary or sanitized SSP
· Self-assessment date & score
· Contact info for verification
How to Get Started in SPRS
Step 1: Go to PIEE (https://piee.eb.mil/)
Step 2: Request the “SPRS Cyber Vendor User” role
Step 3: After approval, log into SPRS
Step 4: Navigate to Cyber Vendor Summary
Step 5: Enter your self-assessment score
Step 6: Take a screenshot for your records and for any Prime requestsThe DoD’s official SPRS quick-start guide is short and easy to follow.
Bringing It All Together
Level 1 compliance isn’t complicated, but not having the right documents in place will hold up contract awards.
· Primes: Start collecting documentation now to avoid delays from auditors and contracting officers.
· Vendors: Make sure your assessment is complete, your SPRS score is posted, and your SSP summary is ready to go.
CMMC is now officially in DFARS. The Final Rule became effective on November 10, so these requirements are active and will start showing up as contracts are modified or awarded. Having documentation ready on both sides will make subcontract releases smoother and avoid surprises during review.
SpendLogic Clients
SpendLogic already supports CMMC compliance requirements within the procurement workflow. When a Prime Contract is modified to include CMMC clauses, our system automatically triggers the additional documentation requirements, ensuring your purchasing files stay complete, consistent, and audit-ready.
As your organization updates its CMMC policies and procedures, the SpendLogic team will incorporate those requirements directly into your existing toolset. This allows your procurement teams to collect Level 1 vendor documentation (SPRS screenshots, scores, and SPP/SSP summaries) without adding new steps to your process.
If you’re not currently using SpendLogic and want to see how we can simplify CMMC compliance and streamline documentation across your supply chain, you can schedule a quick 30-minute demo with our team here.