DCSA Extends Facility Clearance ‘Cliff’: What the New 5-Year Window Means

Executive Summary

Did you know that a 24-month break in access can end clearance eligibility for companies and cleared personnel?

The Department of Defense (DoD) is working to change that. A rewrite of DoD Manual (DoDM) 5220.32 would extend the administrative termination window from 24 months to five years, giving returning companies and their people far more room to re-engage.

• The current rule: Entity and personnel eligibility terminate administratively after a 24-month break in access, often called the "two-year cliff."
• Who it affects: Entities and personnel who go 24 months without access. A cleared defense contractor with an active Facility Security Clearance (FCL) and completed, updated Personnel Security Clearances (PCLs) for its Key Management Personnel (KMP) is not subject to the cliff.
• The proposed change: A five-year eligibility window, aligned with continuous vetting standards.
• Who is driving it: The Office of the Under Secretary of War for Intelligence and Security (OUSW(I&S)) presented the change at the 2026 Virtual Defense Counterintelligence and Security Agency (DCSA) Security Conference, based on a Fast-Tracking Acquisition Security Transformation (FAST) study recommendation.
• Why it matters: Fewer reinvestigations, lower re-entry friction, and better retention of cleared talent across contract cycles.
• Status: The rewrite remains in formal coordination with no publication date announced, so the 24-month rule applies today.

Dig deeper below to learn more.

What the Two-Year Cliff Is

• The rule: Current policy forces administrative termination of entity and personnel eligibility after a 24-month break in access.
• The impact: Entities and personnel face reinvestigations and a restart of the clearance process when they re-engage after a gap.
• Active cleared contractors: Completed and updated KMP PCLs are a key component of clearing a company for an FCL, so a cleared defense contractor with an active FCL is not subject to the cliff.
• The friction: The FAST study identified severe friction when re-engaging proven commercial innovators, who often move between government and commercial work.
• The context: The FCL process already involves sponsorship, DCSA review, KMP background investigations, and a Foreign Ownership, Control, or Influence (FOCI) assessment. Our guide to obtaining a facility security clearance covers those stages.

What the Five-Year Window Would Change

• Longer runway: Eligibility stays intact across five years of no access, up from two.
• Aligned standards: The window matches entity lifecycle rules to continuous vetting standards.
• Less administrative churn: DCSA handles fewer reinvestigations and restarts.
• Lower re-entry costs: Industry avoids repeating work for companies and personnel already vetted.
• Preserved capacity: Cleared talent and vendor capacity carry across contract cycles.

Implications for Contractors

• Returning contractors: Companies without active access that pursue a new award would have a longer period to re-engage before eligibility ends.
• Active cleared contractors: Companies with an active FCL and current KMP PCLs are not subject to the cliff, and keeping KMP PCLs updated maintains that position.
• Cleared personnel: Individuals without current access can remain eligible longer, which supports hiring and retention planning.
• Small and non-traditional firms: Commercial innovators that work with the government intermittently face fewer penalties for stepping away and returning.
• Subcontractors and teaming partners: Primes could draw on a deeper pool of previously vetted partners.
• Planning: Business development timelines can account for a wider window when sequencing classified work.
• Ongoing obligations: Eligibility timing is one piece of the picture. Reporting changes and maintaining the program still apply, as covered in Change Conditions that Affect an Entity's Facility Clearance.

How it Connects to Terminology Changes

• Same manual rewrite: The five-year window sits alongside the shift from FCL to Entity Eligibility Determination (EED) and a 36-month review cycle for lower-risk facilities.
• Entity focus: The window applies to entity and personnel eligibility, which fits the EED emphasis on the organization and its KMP.
• CAGE codes: Commercial and Government Entity (CAGE) codes are unchanged. Only associated terminology and status labels are updated.

Where the Rewrite Stands

• In progress: Presenters described adjudicating several hundred comments, with no firm publication date.
• Draft details: These points reflect the conference briefing. Final language and timing may shift at publication.
• Open channels: Presenters encouraged proactive outreach. Questions can go to your Industrial Security Representative (ISR), your Facility Security Officer (FSO) network, or contacts at the National Classification Management Society (NCMS) and the National Defense Industrial Association (NDIA).

What Cleared Contractors Can Do Now

• Follow current rules: The 24-month window applies until the manual publishes.
• Track access dates: Record the last date of access for your entity and cleared personnel so you know where each stands.
• Confirm with your ISR: Ask how current policy applies to your situation before a gap begins.
• Confirm KMP PCL status: Completed, updated KMP PCLs support your active FCL and keep your company outside the cliff.
• Keep your KMP roster current: Entity eligibility depends on accurate KMP information. See how to maintain a facility clearance.
• Check inspection readiness: Take the Industrial Security Readiness Quiz for a quick view of your posture.
• Brief leadership and contracts teams: Share the proposed change so planning discussions reflect where policy is heading.

FAQs

Is the five-year window in effect today?

No. The extension is part of the DoDM 5220.32 rewrite, which remains in formal coordination. Until the manual is published, the 24-month window applies.

Does the two-year cliff apply to my cleared company?

No. A cleared defense contractor with an active FCL and completed, updated KMP PCLs is not subject to the cliff. It applies to entities and personnel who go 24 months without access.

What is the two-year cliff?

Current policy terminates entity and personnel eligibility administratively after a 24-month break in access. The proposed change extends that window to five years.

Does the change cover personnel as well as companies?

Yes. The briefing describes the window for both entity and personnel eligibility.

Where did the five-year recommendation come from?

It is a FAST study recommendation, and OUSW(I&S) presented it at the 2026 Virtual DCSA Security Conference as part of the manual rewrite.

Does my CAGE code change?

No. Presenters stated that CAGE codes are unchanged.

Helpful ISI Links

• A Guide to Obtaining a Facility Security Clearance
• How to Maintain a Facility Clearance
• Change Conditions that Affect an Entity's Facility Clearance
• Who Is Responsible for Protecting CUI
• Determine Your Industrial Security Check

Reference Resources

• OUSW(I&S) Acquisition and Industrial Security Policy Update Brief, 2026 Virtual DCSA Security Conference, September 14, 2026
• 32 CFR Part 117 | eCFR
• Defense Counterintelligence and Security Agency