A Guide to DFARS Cybersecurity Requirements

EXECUTIVE BRIEF

DFARS is a critical component of the DIB setting and implementing CUI safeguarding standards. A few key cybersecurity requirements outlined in DFARS 252.204-7012 are:

• Adherence to NIST SP 800-171
• Reporting cyber incidents within 72 hours
• Prime contractor responsibilities in ensuring their supply chain adheres to requirements outlined in DFARS

Dig deeper and continue learning below!

Adhering to the Defense Federal Acquisition Regulation Supplement (DFARS) isn’t just a regulatory requirement—it’s a critical component of securing sensitive information and maintaining competitiveness within the Defense Industrial Base (DIB). Designed to protect Controlled Unclassified Information (CUI) and ensure the integrity of the defense supply chain, DFARS plays an integral role in safeguarding national security.

For defense contractors, understanding DFARS cybersecurity requirements is essential for maintaining compliance, securing contracts, and avoiding penalties. This guide will walk you through the key aspects of DFARS, its relationship with NIST SP 800-171, the Cybersecurity Maturity Model Certification (CMMC), and how compliance partners like ISI can support you every step of the way.

What Is DFARS and Why Does It Matter? 

DFARS is a set of supplemental regulations that augment the Federal Acquisition Regulation (FAR) and provide guidelines specifically for Department of Defense (DoD) contractors. Among its provisions, DFARS Clause 252.204-7012 directly addresses cybersecurity, requiring contractors to safeguard Covered Defense Information (CDI) and report cyber incidents. 

Under DFARS Clause 252.204-7012, contractors must adhere to the security controls specified in NIST SP 800-171, a framework designed for protecting CUI. These controls include 14 domains of security practices, covering everything from access control to incident response.

By meeting these requirements, contractors protect sensitive information and demonstrate their ability to handle defense contracts responsibly. This significantly enhances your standing in competitive bidding processes.

Key DFARS Cybersecurity Requirements 

To fully comply with DFARS and align with DoD expectations, contractors must address the following critical components.

NIST SP 800-171 Framework

NIST SP 800-171 outlines 110 security controls across 14 control domains, including:

• Access Control – Restrict access to authorized users.
• Incident Response – Establish procedures for detecting and responding to cyber incidents.
• System and Communications Protection – Ensure secure data transmission and mitigate threats.

And many others. Each contractor must have a System Security Plan (SSP) describing how these controls are implemented and a Plan of Action and Milestones (POA&M) to address gaps.

Cyber Incident Reporting

DFARS mandates that contractors report cyber incidents involving CDI to the DoD within 72 hours. This strict reporting timeline allows for the timely mitigation of potential damage. Contractors must also conduct damage assessments and share relevant forensic data with the DoD.

Flow-Down Requirements

Prime contractors are responsible for ensuring that all subcontractors and suppliers handling CDI meet the exact cybersecurity requirements outlined by DFARS. This ensures that risks are mitigated across the entire supply chain.

CMMC & DFARS

As the DoD prepares to roll out the revised Cybersecurity Maturity Model Certification (CMMC 2.0), it is essential to understand how these two regulations interact with each other. In short, DFARS sets NIST SP 800-171 as the cybersecurity benchmark for defense contractors; CMMC validates whether a contractor has successfully implemented these practices. 

CMMC 2.0 introduces a simplified, tiered certification system with three maturity levels:

• Level 1 | Foundational – For contractors only handling Federal Contract Information (FCI)  requiring adherence to 17 practices outlined in NIST 800-53
• Level 2 | Advanced – For contractors handling Controlled Unclassified Information,, requiring adherence to all applicable 110 NIST SP 800-171 practices
• Level 3 | Expert – For contractors handling particularly sensitive CUI requiring an additional 24 controls selected from NIST SP 800-172 controls

CMMC Level 2 assessments will be conducted by third-party assessment organizations (C3PAOs) to verify compliance.

Compliance Challenges and the Role of Partners Like ISI

DFARS compliance doesn’t have to be complicated—ISI simplifies the process, giving you clarity and confidence. Contractors often face challenges around interpreting regulatory language, implementing technical controls, and maintaining organized compliance documentation.

This is where trusted compliance partners like ISI come into play. With 300+ years of defense-specific compliance experience, ISI specializes in simplifying DFARS and CMMC compliance complexities. Here’s how ISI supports defense contractors:

• DFARS and NIST SP 800-171 Implementation – ISI provides expert support in implementing the 110 security controls and creating robust SSPs and POA&Ms.
• CMMC Preparation – ISI helps contractors achieve their desired CMMC level through comprehensive assessments, tailored remediation plans, and actionable insights.

• Continuous Monitoring and Support - Our CMMC-proven tool stack and US-based help desk monitors your systems 24/7/365, catching deficiencies and deterring cyber attacks in real-time.

How Working with ISI Benefits Defense Contractors 

Our unique strengths include:

• Trusted Expertise – ISI supports more than 900 small- and medium-sized defense contractors with their security and compliance journeys.
• Proven Tools – Having successfully achieved our CMMC Level 2 Certificate of Status, our cybersecurity tool stack is proven to help your business achieve compliance.
• Personalized Support – ISI takes a consultative approach, offering hands-on assistance tailored to each contractor’s needs.

By partnering with ISI, contractors gain confidence in their compliance processes, reduce administrative burdens, and strengthen their competitive positioning.

Take Control of Your DFARS Compliance Today

DFARS compliance is not optional for defense contractors—it’s essential for securing contracts and protecting sensitive information. By understanding and addressing cybersecurity requirements, contractors contribute to national security and position themselves for long-term success in the DIB.

Navigating these challenges alone can be overwhelming, but you don’t have to go it alone. Contact ISI today to learn how we can guide your compliance efforts and equip you with the tools and expertise needed to win and maintain DoD contracts.

» Contact ISI for Expert Guidance on Compliance Strategies

FAQs about DFARS Cybersecurity Requirements

What Is the Difference Between NIST and DFARS? 

DFARS is a regulation that mandates cybersecurity requirements for contractors, while NIST SP 800-171 provides the specific technical controls necessary to meet those requirements.

What Are the Three Essential Takeaways for DFARS Compliance? 

1.  Achieve compliance with NIST SP 800-171.
2. Ensure the cloud environment or service provider has achieved FedRAMP Moderate Baseline authorization or can prove equivalent protections.
3. Develop an incident response plan to report cyber incidents within 72 hours.

What Is the Connection Between CMMC and DFARS?

DFARS determines NIST 800-171 as the set of cybersecurity requirements contractors must follow, and it requires contract officers to include proof of CMMC Certificate of Status as a prerequisite for accepting defense contracts. DFARS is the goal, NIST is the study guide, and CMMC is the test.