DFARS for DoD Contractors

DFARS regulations include provisions related to cybersecurity to protect covered defense information (CDI) and maintain the integrity of the defense supply chain. The specific cybersecurity requirements are outlined in DFARS Clause 252.204-7012, “Safeguarding Covered Defense Information and Cyber Incident Reporting.”

Under this clause, contractors that handle CDI are required to implement specific security controls to protect the confidentiality, integrity, and availability of this information. The controls are based on the security requirements outlined in the National Institute of Standards and Technology (NIST) Special Publication 800-171, which provides a framework for protecting Controlled Unclassified Information (CUI).

Here are some key points regarding DFARS and cybersecurity:

1. System Security Plan (SSP): Contractors must develop and maintain an SSP that describes the security controls in place to protect CDI. The SSP outlines how the contractor implements the security requirements specified in NIST SP 800-171.

2. Security Assessment: Contractors must conduct a security assessment to evaluate the effectiveness of their implemented security controls. This assessment may include internal or third-party audits or penetration testing.

3. Plan of Action and Milestones (POA&M): If security vulnerabilities or deficiencies are identified during the assessment, contractors must develop a POA&M. It outlines the specific actions the contractor will take to address and mitigate the identified vulnerabilities.

4. Reporting Cyber Incidents: Contractors must report any cyber incidents to the DoD within a specified timeframe. This includes incidents that result in the loss, compromise, or unauthorized access to CDI.

5. Flow Down Requirements: Contractors must flow down these cybersecurity requirements to their subcontractors and suppliers that handle CDI. This ensures that the entire supply chain follows the necessary security controls.

Compliance with DFARS cybersecurity requirements is crucial for contractors seeking to win and maintain DoD contracts. Failure to comply may result in contract termination, loss of future business opportunities, or potential legal consequences.

It’s worth noting that these regulations are subject to updates and changes. Contractors should regularly review DFARS and any related updates to ensure ongoing compliance with the latest requirements.