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180-Day Rule
Also known as: 180-day window · POA&M 180-day rule
Under CMMC 2.0, a contractor receiving conditional Level 2 certification must close all open POA&M items within 180 days or lose the certification.
The 180-day rule is a key operational constraint introduced by the CMMC 2.0 Final Rule. When a contractor undergoes a CMMC Level 2 assessment and the C3PAO identifies a limited number of unmet requirements that are eligible to be on a Plan of Action and Milestones (POA&M), the contractor can receive a conditional certification — but only if all those POA&M items are closed within 180 days of the assessment.
If the contractor closes all POA&M items within the window and the closures are validated, the certification converts from conditional to final. If the contractor fails to close all items within 180 days, the conditional certification lapses and the contractor must undergo a full re-assessment.
Not every requirement is eligible to be on a POA&M. Higher-weighted requirements (3 or 5 points in the DoD Assessment Methodology) generally must be fully met at assessment time. A POA&M-eligible item that is not closed in time can disqualify the contractor from contracts that require Level 2 certification.
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