Compliance Framework

DFARS

Defense Federal Acquisition Regulation Supplement - The Cybersecurity Contractual Mandates for DoD Supply Chain Partners

DFARS is the Defense Federal Acquisition Regulation Supplement, the set of regulations that governs Department of Defense procurement. Of particular relevance to cybersecurity, DFARS 252.204-7012 (Safeguarding Covered Defense Information and Cyber Incident Reporting) mandates that DoD contractors implement NIST SP 800-171 security controls to protect Covered Defense Information (CDI) and Controlled Unclassified Information (CUI). DFARS 252.204-7019 and 7020 add requirements for contractor self-assessment and NIST SP 800-171 score submission via the Supplier Performance Risk System (SPRS). Non-compliance with DFARS cybersecurity clauses can result in contract termination, suspension of payments, and debarment from future DoD contracts.

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Key Requirements

DFARS Requirements

What you need to know about DFARS compliance. Need help getting started?

Implement NIST SP 800-171 security requirements across all 14 control families with proper documentation
Submit NIST SP 800-171 self-assessment score to the Supplier Performance Risk System (SPRS) as required by DFARS 7019
Conduct annual NIST SP 800-171 self-assessments with documented evidence for each control (DFARS 7020)
Report cyber incidents affecting Covered Defense Information to DoD within 72 hours of discovery
Preserve and provide forensic evidence and damage assessment information to DoD upon request following an incident
Flow down DFARS 7012 requirements to subcontractors that will receive CDI or CUI
Maintain a current System Security Plan (SSP) and Plan of Action and Milestones (POA&M) for all applicable NIST 800-171 controls
Prepare for transition from self-assessment to C3PAO assessment as CMMC requirements are phased in
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Why It Matters

Key Benefits

Why DFARS compliance matters for your business and how it protects your operations, customers, and growth.

Maintain eligibility for DoD contracts that include DFARS 7012, 7019, and 7020 clauses. These clauses are now standard in virtually all DoD contracts and subcontracts involving CDI or CUI. Compliance is a contractual requirement, not optional.

Satisfy NIST SP 800-171 requirements as a strategic step toward CMMC certification. DFARS 7012 already requires NIST 800-171 implementation, and CMMC Level 2 certification builds directly on this foundation. DFARS compliance preps you for mandatory certification.

Demonstrate cybersecurity maturity to DoD contracting officers through SPRS scores. DFARS 7019 requires contractors to submit their NIST SP 800-171 self-assessment score to SPRS. Higher scores make you more competitive for contracts and demonstrate program maturity.

Avoid severe contract consequences including payment withholding, termination, and suspension/debarment. DoD contracting officers actively verify DFARS cybersecurity compliance through contract clauses, and non-compliance is grounds for adverse action.

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Who It's For

Who Needs DFARS?

Any organization that is a prime contractor or subcontractor on a DoD contract that includes DFARS 252.204-7012 requires DFARS compliance. This includes virtually all DoD contractors handling Covered Defense Information (CDI) or Controlled Unclassified Information (CUI). The DFARS cybersecurity clauses flow down to subcontractors of all tiers, so even small subcontractors that handle protected information need compliance. Organizations in the defense supply chain, from prime defense contractors to component manufacturers and IT service providers, are affected.

How We Help

Our Approach to DFARS

We guide you through the entire compliance lifecycle. From gap analysis to audit support, we make compliance manageable.

01

DFARS 7012 compliance assessment including NIST SP 800-171 gap analysis against all 110 security requirements. We assess your current implementation, identify gaps, and build a prioritized remediation plan with realistic timelines for full compliance.

02

SPRS self-assessment score submission support. We help you complete the NIST SP 800-171 self-assessment accurately, determine your Basic, Medium, or High score level, and prepare and submit the score via the SPRS portal.

03

System Security Plan (SSP) and POA&M development and maintenance. We create comprehensive documentation covering all NIST 800-171 controls and families, establishing your SSP and maintaining your POA&M with current milestones and remediation status.

04

Cyber incident response procedures specific to DFARS 7012 requirements. We establish incident response procedures that meet the 72-hour reporting requirement, forensic evidence preservation requirements, and DoD coordination procedures.

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FAQ

Frequently Asked Questions

What is the difference between DFARS 7012 and CMMC?
DFARS 252.204-7012 requires contractors to implement NIST SP 800-171 and report cyber incidents. It relies on self-assessment. CMMC adds independent, third-party assessment of those same controls (for Level 2) plus maturity process requirements. CMMC is being phased in to replace self-attestation for most contractors.
What is an SPRS score and why does it matter?
SPRS (Supplier Performance Risk System) is where DoD contractors submit their NIST SP 800-171 self-assessment scores. The score (ranging from -203 to 110) reflects your implementation level across the 110 requirements. Higher scores demonstrate better security posture. DoD contracting officers use SPRS scores to evaluate contractor risk during procurements.
What happens if we do not comply with DFARS 7012?
Non-compliance with DFARS 7012 is a breach of your DoD contract. Consequences include withholding of contract payments, contract termination for default, suspension or debarment from future DoD contracts, and potential False Claims Act liability for knowingly providing non-compliant systems. We have seen contractors suspended for non-compliance.
Does DFARS apply to subcontractors?
Yes. DFARS 7012 requires prime contractors to flow down the clause to all subcontractors that will receive Covered Defense Information or CUI. This means subcontractors at every tier must implement NIST SP 800-171 and report cyber incidents. Subcontractor compliance is the prime contractor responsibility.

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