What is DFARS 252.204-7012?

DFARS 252.204-7012 requires DoD contractors to implement NIST 800-171 security requirements, report cyber incidents to DC3 within 72 hours, preserve forensic images for 90 days, and flow down requirements to subcontractors handling CUI.

What is the difference between DFARS 7012, 7020, and 7021?

Clause 7012 sets the NIST 800-171 requirement. Clause 7020 enables DoD assessments and SPRS scoring. Clause 7021 mandates CMMC certification. Together they form the DoD's layered cybersecurity compliance approach.

What happens if we are not DFARS compliant?

Consequences include loss of contract eligibility, contract termination, False Claims Act liability with treble damages, removal from prime contractor supply chains, and reputational harm.

What is Controlled Unclassified Information (CUI)?

CUI is government information requiring safeguarding under law or policy. Common defense CUI includes technical data, export-controlled information, proprietary manufacturing processes, and contract performance data.

How does DFARS flow down to subcontractors?

DFARS 7012 requires flow-down to all subcontractor tiers handling CUI. Subcontractors must implement NIST 800-171, report incidents, and under CMMC achieve the specified certification level.

How long does DFARS compliance take?

Organizations with existing security programs typically achieve compliance in 3-6 months. Those starting from scratch may need 6-12 months. Scoping takes 1-2 weeks, assessment 2-3 weeks, and remediation 8-16 weeks.

Can we use a cloud enclave for CUI processing?

Yes, but the cloud must meet FedRAMP Moderate or equivalent requirements. Options include Microsoft GCC High, AWS GovCloud, and Google Assured Workloads. Shared responsibility documentation is required for assessors.

What is the False Claims Act risk for DFARS non-compliance?

The DOJ Civil Cyber-Fraud Initiative pursues contractors who misrepresent compliance. Risks include treble damages, per-claim penalties exceeding $11,000, and exclusion from government contracting.

DFARS Compliance

DFARS Compliance For Defense Contractors

Every DoD contractor handling Controlled Unclassified Information must implement NIST SP 800-171 controls under DFARS clause 252.204-7012. Non-compliance means contract loss and False Claims Act liability.

CMMC Registered Practitioner Org | BBB A+ Since 2003 | 23+ Years Experience

Get a Free DFARS Assessment Call 919-348-4912

Requirements

What DFARS Demands

Three interconnected DFARS clauses govern CUI protection for defense contractors.

Technical Controls (NIST 800-171)

110 security controls across 14 families for CUI protection
Encryption, MFA, access controls, and audit logging
CUI boundary definition and data flow mapping
72-hour cyber incident reporting to DoD

Compliance Process

SPRS score calculation and submission (clause 7020)
System Security Plan and POA&M development
CMMC certification preparation (clause 7021)
Subcontractor flow-down compliance verification

Services

DFARS Compliance Services

NIST 800-171 Assessment

Thorough evaluation of all 110 controls with accurate SPRS score calculation and prioritized remediation plan.

CUI Boundary Definition

Map CUI data flows, define system boundaries, and build genuine protection programs for controlled information.

SSP and POA&M Development

Create the System Security Plan and Plan of Action and Milestones that DoD contracting officers review during source selection.

CMMC Readiness

Prepare for upcoming CMMC third-party assessments with control implementation, evidence packages, and mock assessments.

SPRS Submission

Calculate your accurate score and guide you through the Supplier Performance Risk System submission process.

Incident Response

Build and test the 72-hour cyber incident reporting capability DFARS requires for CUI breaches.

FAQ

Frequently Asked Questions

What is the relationship between DFARS and CMMC?

DFARS clause 252.204-7021 requires CMMC certification at the level specified in the contract. CMMC formalizes the NIST 800-171 self-assessment into a third-party verified certification.

What is a SPRS score?

Your Supplier Performance Risk System score reflects your self-assessed implementation of NIST 800-171 controls. It ranges from -203 to 110, and DoD contracting officers review it during source selection.

What are the False Claims Act risks?

DoJ has pursued cases against contractors who misrepresent their DFARS compliance status. Inaccurate SPRS scores or false compliance certifications can trigger treble damages and per-claim penalties.

Do subcontractors need DFARS compliance?

Yes. DFARS requires prime contractors to flow down CUI protection requirements to all subcontractors handling controlled information.

Protect Your DoD Contracts

Contact Petronella Technology Group for a free DFARS compliance assessment and SPRS score review.

Schedule a Consultation Call 919-348-4912