NISPOM establishes guidelines for Personnel Security Clearances (PCLs) and Facility Security Clearances (FCLs). These clearances determine who can access classified information and ensure that only vetted individuals and organizations are entrusted with national security materials.

Classified Information Handling

The manual defines how classified information should be marked, stored, transmitted, and destroyed. It categorizes classified data into three levels: Top Secret, Secret, and Confidential, each requiring different levels of protection.

Insider Threat Program (ITP)

A core element of NISPOM is the Insider Threat Program (ITP), which mandates organizations to detect, prevent, and mitigate potential threats posed by employees or contractors. This includes monitoring for suspicious behavior and ensuring employees report security concerns.

Security Training and Awareness

All personnel handling classified information must receive initial and annual training on security protocols. This training covers topics such as threat recognition, proper handling of classified materials, and reporting procedures for security violations.

Self-Inspections and Compliance Reviews

Contractors must conduct self-inspections to assess their adherence to NISPOM regulations. Additionally, the Defense Counterintelligence and Security Agency (DCSA) performs routine security reviews and audits to ensure compliance.

Cybersecurity and Information Systems Security

With the growing cyber threat landscape, NISPOM includes provisions for protecting classified and controlled unclassified information (CUI) in digital environments. It aligns with cybersecurity frameworks like DFARS 7012 and the Cybersecurity Maturity Model Certification (CMMC) to ensure that contractors secure their IT infrastructure against cyber threats.

Classified Contracts and DD Form 254

When a contractor is awarded a classified contract, DD Form 254 outlines the specific security requirements that must be followed. This ensures that all parties involved in handling classified information understand their obligations.

The National Industrial Security Program Operating Manual (NISPOM) is a set of regulations issued by the Department of Defense (DoD) to safeguard classified information within the defense industrial base. It outlines security requirements for companies working with classified data and ensures they maintain appropriate protections in areas such as employee clearances, physical security, and information system security.

What’s the difference between NISPOM and NIST?

NISPOM (National Industrial Security Program Operating Manual) provides guidelines for safeguarding classified information within defense contractor organizations, focusing on physical security, personnel clearances, and facility requirements. In contrast, NIST (National Institute of Standards and Technology) develops standards and frameworks for information security, such as NIST SP 800-171, which outlines controls for protecting sensitive but unclassified information (CUI) in federal systems and defense contracts. While NISPOM governs classified information security, NIST focuses on cybersecurity best practices for both classified and unclassified data.

Who is responsible for NISPOM compliance within an organization?

Facility Security Officers (FSOs) are primarily responsible for ensuring compliance with NISPOM within an organization. They oversee security clearance processes, training programs, physical security, and compliance with other NISPOM guidelines. However, executive leadership plays a key role by providing the resources and support necessary for a robust security program.

How do security clearances work under NISPOM?

Under NISPOM, security clearances are required for individuals who have access to classified information. The process involves a thorough background check, including criminal history, financial standing, and foreign contacts, to assess the person’s trustworthiness. Clearances must be maintained with periodic reinvestigations, and individuals must report any incidents that could affect their eligibility.

What are the key components of a security training program?

A comprehensive security training program under NISPOM must include ongoing education on classified information handling, security protocols, recognizing insider threats, and reporting incidents. It should be mandatory for all personnel, with regular updates to address changes in regulations, threats, and security best practices. The training ensures employees understand their roles in safeguarding sensitive data and facilities.

How does NISPOM address insider threats?

NISPOM emphasizes the importance of identifying and mitigating insider threats. It recommends implementing monitoring programs that assess behavior, conduct background checks, and establish clear reporting structures. Employees and contractors must be educated on recognizing red flags and know how to report suspicious activity to prevent internal threats that could jeopardize sensitive information.

What is the role of information classification in NISPOM?

Information classification is crucial under NISPOM, as it defines how sensitive information should be categorized and handled. Classified data must be labeled according to its sensitivity level—Confidential, Secret, or Top Secret—and handled using specific security protocols, including secure storage, access controls, and encryption, to prevent unauthorized access and misuse.

What are the security measures required for physical facilities under NISPOM?

NISPOM requires that facilities housing classified information be protected by physical security measures such as GSA-approved safes, controlled access, alarm systems, surveillance cameras, and on-site security personnel. Secure areas must be established, and contractors are required to conduct regular security checks to ensure compliance with these protective measures.

How can companies stay up-to-date with NISPOM changes?

To stay up-to-date with NISPOM changes, companies should regularly monitor updates from the Defense Counterintelligence and Security Agency (DCSA) and other relevant government agencies. Subscribing to agency alerts, monitoring DCSA’s website, attending industry events and webinars, and engaging in networking opportunities with security professionals can also help ensure compliance with new revisions and emerging security standards.

Understanding NISPOM

What is NISPOM? Understanding Its Role in Security

NISPOM stands for the National Industrial Security Program Operating Manual. It’s a comprehensive set of guidelines and requirements issued by the U.S. Department of Defense (DoD) to protect classified information shared with contractors, licensees, and grantees in private industry. NISPOM governs how such entities access, store, and safeguard this information to maintain national security.

NISPOM applies to all government contractors handling classified information under the NISP. This not only includes contractors working with the DoD, but with other federal agencies that share classified data with industry partners, such as the Department of Energy. Regardless of the federal agency, if your organization works with classified contracts, NISPOM compliance is essential to meet your legal obligations and maintain eligibility for future contract awards.

NISPOM and 32 CFR Part 117

In 2021, the DoD transitioned NISPOM from its long-standing DoD 5220.22-M format into Title 32 of the Code of Federal Regulations (CFR), Part 117. Why this matters:

NISPOM is officially known as 32 CFR Part 117 (“The Rule”), as this is its formal designation under federal regulations.
This shift made NISPOM a formal federal regulation rather than just a DoD manual, thereby strengthening its legal authority and further ensuring consistency across agencies.
The updated NISPOM also placed greater emphasis on cybersecurity measures in response to increasing cyber threats, aligning with broader government efforts to secure sensitive information in the digital age.

Today, NISPOM remains a cornerstone of industrial security. In the future, NISPOM will likely expand its focus on cybersecurity compliance, artificial intelligence security, and insider threat detection to ensure the protection of national security information in an increasingly complex global environment.

How NISPOM Shaped Industrial Security Standards

NISPOM has a long and evolving history tied to the United States’ efforts to safeguard classified information within the defense industry. It was first issued in 1995 as DoD 5220.22-M under the authority of Executive Order 12829, which established the National Industrial Security Program (NISP). The program was designed to provide a unified structure for protecting classified information held by contractors, licensees, and grantees of the U.S. government.

Before NISPOM, security regulations varied across different agencies, leading to inconsistencies and inefficiencies in classified information protection. By standardizing security protocols, NISPOM aimed to ensure that defense contractors all followed the same stringent guidelines when handling classified materials.

NISPOM has undergone multiple revisions to adapt to emerging security threats and technological advancements. These updates incorporated new requirements for cybersecurity, insider threat mitigation, and foreign ownership, control, or influence (FOCI) concerns.

Security Clearances: NISPOM establishes guidelines for Personnel Security Clearances (PCLs) and Facility Security Clearances (FCLs). These clearances determine who can access classified information and ensure that only vetted individuals and organizations are entrusted with national security materials.
Classified Information Handling: The manual defines how classified information should be marked, stored, transmitted, and destroyed. It categorizes classified data into three levels: Top Secret, Secret, and Confidential, each requiring different levels of protection.
Insider Threat Program (ITP): A core element of NISPOM is the Insider Threat Program (ITP), which mandates organizations to detect, prevent, and mitigate potential threats posed by employees or contractors. This includes monitoring for suspicious behavior and ensuring employees report security concerns.
Foreign Ownership, Control, or Influence (FOCI): Given the risks associated with foreign investments in U.S. companies, NISPOM outlines requirements for identifying and mitigating foreign influence on defense contractors. Companies under FOCI must implement mitigation measures such as voting trusts, proxy agreements, or Special Security Agreements (SSAs) to protect classified information. Dig Deeper
Security Training and Awareness: All personnel handling classified information must receive initial and annual training on security protocols. This training covers topics such as threat recognition, proper handling of classified materials, and reporting procedures for security violations.
Self-Inspections and Compliance Reviews: Contractors must conduct self-inspections to assess their adherence to NISPOM regulations. Additionally, the Defense Counterintelligence and Security Agency (DCSA) performs routine security reviews and audits to ensure compliance.
Cybersecurity and Information Systems Security: With the growing cyber threat landscape, NISPOM includes provisions for protecting classified and controlled unclassified information (CUI) in digital environments. It aligns with cybersecurity frameworks like DFARS 7012 and the Cybersecurity Maturity Model Certification (CMMC) to ensure that contractors secure their IT infrastructure against cyber threats.
Reporting Requirements: Organizations are required to immediately report security incidents, suspicious foreign contacts, unauthorized disclosures, and cyber breaches. This ensures that threats are quickly identified and mitigated to prevent further damage.
Classified Contracts and DD Form 254: When a contractor is awarded a classified contract, DD Form 254 outlines the specific security requirements that must be followed. This ensures that all parties involved in handling classified information understand their obligations.

Importance of NISPOM Compliance for Contractors:

NISPOM compliance matters not only because it’s critical to protecting classified information and thereby safeguarding national security, but to maintaining your eligibility to work on contracts involving sensitive information. Here are some key reasons why compliance with the NISPOM is essential:

NISPOM Protects National Security: NISPOM sets clear standards for handling classified information, ensuring that sensitive government data is safeguarded against unauthorized access, theft, or misuse.
Compliance Maintains Your Contract Eligibility: Defense contractors must adhere to NISPOM requirements to remain eligible for contracts involving classified work. Non-compliance can lead to disqualifications or revoked facility clearances.
Compliance Supports Your Business Reputation: Organizations that demonstrate compliance build trust with government agencies and industry partners, solidifying their reputation as reliable and responsible.
NISPOM Aligns with Broader Compliance Initiatives: Adhering to NISPOM often overlaps with other compliance standards, such as CMMC or NIST 800-171, streamlining efforts to meet multiple security requirements.
It Future-Proofs Your Business Operations: With the increasing sophistication of cyber threats, following NISPOM helps organizations adapt to evolving security challenges, ensuring long-term business viability in the defense industrial base (DIB).

What Our Customers Say

ISI has provided my company with outstanding FSO support, keeping us in compliance with DCSA and helping ensure that our employees understand the responsibilities and reporting requirements associated with their security clearances.
Chris Bock CEO, 540.co

ISI is a perfect fit for very small businesses in the Defense industry. They provide outstanding security services at a very affordable price. We simply would not be able to satisfy all of our customers' security requirements without ISI!
Craig Yantiss President, The Probitas Project, Inc.

As a company, we've been involved in deeply complicated negotiations with DCSA, and meeting the compliance requirements has been the duty of ISI. They have literally saved us from losing our FCL. I applaud ISI's efforts loudly and give credit to their incredibly knowledgeable staff
Matthew Moore Government Contracts and Compliance Director, Luna Innovations

Facility Clearance (FCL)

A Facility Clearance (FCL) is granted to an organization or company, allowing it to access classified information. An FCL ensures that the organization meets the security requirements necessary to safeguard classified information. The level of the facility clearance (Confidential, Secret, or Top Secret) corresponds to the highest level of classified information the organization will handle.

To obtain an FCL, contractors are required to implement comprehensive strategies for safeguarding their physical premises, ensuring the protection of documents, systems, and personnel from any malicious intent or vulnerabilities.

Personnel Security Clearance (PCL)

Personnel Security Clearances (PCLs) are granted to individual employees within an organization, allowing them to access classified information based on the level of their clearance. PCLs also come in levels (Confidential, Secret, Top Secret) and are issued after a thorough background investigation confirms the individual's eligibility to handle classified information.

PCLs must be maintained through periodic reinvestigations and proper reporting of any incidents/events that could affect an individual's eligibility. FCLs must be maintained through security audits conducted by DCSA to ensure the facility is in compliance. Understanding these requirements is crucial for contractors seeking to hire personnel in sensitive roles and safeguard national security interests.

Information Systems Security

Guidelines for safeguarding digital information are a vital aspect of NISPOM, emphasizing the security of information systems used in managing classified data. These standards dictate how contractors must protect their digital infrastructure through encryption, access control measures, and regular audits. With cyber threats on the rise, these protocols ensure that sensitive digital data remains secure from intrusion, loss, or theft. By following NISPOM guidelines, organizations can create a safe and secure digital environment, which plays a pivotal role in maintaining the integrity of national security initiatives.

Industrial Security Education

NISPOM mandates ongoing industrial security education for employees and contractors. Continuous training ensures that all personnel are up to date with the latest security regulations, procedures, and threats. By offering comprehensive education programs, companies can. Proper training minimizes human error, instills a broader culture of security awareness, and enables staff to identify potential risks and take proactive measures in advance.

Roles and Responsibilities

The ultimate responsibility for complying with NISPOM’s requirements falls with the Facility Security Officer (FSO). FSOs oversee security clearances, employee vetting, physical security measures, and information protection procedures. They act as the main point of contact with the government on security matters and ensure that proper security training is provided to all personnel.

FSOs must be highly knowledgeable about security regulations and best practices, continuously monitoring and adjusting the facility’s security posture to mitigate risks and ensure the safety of classified information.

Executive leadership is essential in setting the tone for security and compliance at every level of an organization. Senior executives are responsible for allocating resources, establishing company-wide security policies, and ensuring the alignment of organizational strategies with NISPOM requirements. Their leadership and commitment to security culture are vital for securing buy-in across the company, fostering accountability, and managing risk effectively. By supporting FSOs and other security teams, executives ensure that security compliance is not just a responsibility but a core value driving operational excellence and safeguarding sensitive data.

Navigating NISPOM Changes

NISPOM compliance is constantly evolving. Stay ahead of regulatory changes that could impact your operations by regularly monitoring updates from the Defense Counterintelligence and Security Agency (DCSA) and other relevant government agencies. Keeping abreast of these shifts will help you avoid any potential compliance gaps. DCSA publications and official communication channels are a primary resource, offering in-depth analysis of regulatory updates and providing detailed guidance for implementation.

Proactive Monitoring

Being proactive in navigating NISPOM changes can give your organization an edge in compliance. Subscribe to agency alerts, newsletters, and publications from trusted sources in the defense and industrial security sectors to stay ahead of regulatory shifts and new standards. Attend industry events, conferences, and webinars to gain first-hand insights from industry leaders, peers, and government representatives. Engage with the security community to build valuable networks and stay informed about emerging trends, technologies, and security challenges. Taking these steps will help you adapt quickly to changes before they pose a risk to your operations.

Building a Strong Security Program

A strong security program is vital for ensuring NISPOM compliance and protecting sensitive information. Key elements include thorough employee training, insider threat programs, and proper information classification. Regular training educates personnel on security protocols and the importance of safeguarding data. Insider threat programs help identify and mitigate risks posed by internal actors, while information classification ensures sensitive data is handled securely. These components work together to create a robust security framework that protects both physical and digital assets from internal and external threats.

An FSO Checklist

FSOs conduct regular self-assessments to evaluate an organization’s security posture. These assessments help identify areas for improvement and ensure compliance with the latest NISPOM revisions. FSOs are also responsible for updating policies and verifying that physical and digital security measures—such as access controls and encryption—are effectively in place. By following this checklist, FSOs ensure a proactive and compliant security strategy.

Ensure your company policies and procedures are up-to-date and available for your cleared employees to review.
Conduct annual refresher training to include special access briefings or trainings required by the customer.
Review all facility documentation for accuracy and completion.
Run reports in DISS to ensure all clearances are enrolled into continuous evaluation (CE) and are within the 5-year timeframe.
Conduct thorough reviews of all safeguarding material (if applicable).
Review all DD-254's to ensure your company is following the security guidance provided by the customer.

NISPOM FAQs

What is NISPOM?: The National Industrial Security Program Operating Manual (NISPOM) is a set of regulations issued by the Department of Defense (DoD) to safeguard classified information within the defense industrial base. It outlines security requirements for companies working with classified data and ensures they maintain appropriate protections in areas such as employee clearances, physical security, and information system security.
What’s the difference between NISPOM and NIST?: NISPOM (National Industrial Security Program Operating Manual) provides guidelines for safeguarding classified information within defense contractor organizations, focusing on physical security, personnel clearances, and facility requirements. In contrast, NIST (National Institute of Standards and Technology) develops standards and frameworks for information security, such as NIST SP 800-171, which outlines controls for protecting sensitive but unclassified information (CUI) in federal systems and defense contracts. While NISPOM governs classified information security, NIST focuses on cybersecurity best practices for both classified and unclassified data.
Who is responsible for NISPOM compliance within an organization?: Facility Security Officers (FSOs) are primarily responsible for ensuring compliance with NISPOM within an organization. They oversee security clearance processes, training programs, physical security, and compliance with other NISPOM guidelines. However, executive leadership plays a key role by providing the resources and support necessary for a robust security program.
How do security clearances work under NISPOM?: Under NISPOM, security clearances are required for individuals who have access to classified information. The process involves a thorough background check, including criminal history, financial standing, and foreign contacts, to assess the person’s trustworthiness. Clearances must be maintained with periodic reinvestigations, and individuals must report any incidents that could affect their eligibility.
What are the key components of a security training program?: A comprehensive security training program under NISPOM must include ongoing education on classified information handling, security protocols, recognizing insider threats, and reporting incidents. It should be mandatory for all personnel, with regular updates to address changes in regulations, threats, and security best practices. The training ensures employees understand their roles in safeguarding sensitive data and facilities.
How does NISPOM address insider threats?: NISPOM emphasizes the importance of identifying and mitigating insider threats. It recommends implementing monitoring programs that assess behavior, conduct background checks, and establish clear reporting structures. Employees and contractors must be educated on recognizing red flags and know how to report suspicious activity to prevent internal threats that could jeopardize sensitive information.
What is the role of information classification in NISPOM?: Information classification is crucial under NISPOM, as it defines how sensitive information should be categorized and handled. Classified data must be labeled according to its sensitivity level—Confidential, Secret, or Top Secret—and handled using specific security protocols, including secure storage, access controls, and encryption, to prevent unauthorized access and misuse.
What are the security measures required for physical facilities under NISPOM?: NISPOM requires that facilities housing classified information be protected by physical security measures such as GSA-approved safes, controlled access, alarm systems, surveillance cameras, and on-site security personnel. Secure areas must be established, and contractors are required to conduct regular security checks to ensure compliance with these protective measures.
How can companies stay up-to-date with NISPOM changes?: To stay up-to-date with NISPOM changes, companies should regularly monitor updates from the Defense Counterintelligence and Security Agency (DCSA) and other relevant government agencies. Subscribing to agency alerts, monitoring DCSA’s website, attending industry events and webinars, and engaging in networking opportunities with security professionals can also help ensure compliance with new revisions and emerging security standards.

Understanding Nispom: A Comprehensive Guide

What is NISPOM? Understanding Its Role in Security

NISPOM and 32 CFR Part 117

How NISPOM Shaped Industrial Security Standards

The Key Elements of NISPOM Compliance

Importance of NISPOM Compliance for Contractors:

Consequences of Non-Compliance

Loss of FCL

Contract Termination

Financial Penalties

Reputational Damage

Legal
Consequences

Increased Security Risks

Disqualification from Future Work

Operational Disruptions

What Our Customers Say