DFARS Cybersecurity & Incident Reporting Compliance for DoD Contractors

DFARS cyber clauses define how DoD contractors must safeguard Controlled Unclassified Information (CUI) and report cyber incidents. They are the legal backbone that underpins many of your cybersecurity obligations.

Key DFARS Clauses

• DFARS 252.204-7012: Safeguarding CUI and reporting cyber incidents within 72 hours.
• DFARS 252.204-7019: NIST SP 800-171 DoD Assessment Requirements and SPRS scores.
• DFARS 252.204-7020: DoD access to your systems and records to verify assessment scores.

DFARS and NIST 800-171

DFARS clauses require implementation of NIST 800-171 controls to protect CUI. Your System Security Plan (SSP) and Plan of Action and Milestones (POA&M) document how you meet or plan to meet those controls.

DFARS and CMMC

CMMC builds on DFARS requirements by introducing a certification regime. If you are serious about DFARS compliance, you are already part-way toward CMMC readiness.

Practical DFARS Compliance Checklist

• Implement NIST 800-171 controls across in-scope systems
• Maintain an SSP and POA&M
• Establish incident response capabilities and a 72-hour reporting process
• Track and maintain your SPRS score
• Flow down relevant clauses to subcontractors

Operational DFARS compliance is about more than box-checking. It requires an architecture, an incident response capability, and evidence that your controls actually work.