The Defence Federal Acquisition Regulation Supplement (DFARS) is a set of cybersecurity regulations that the Department of Defence (DoD) now imposes on external contractors and suppliers. As cyber threats become more serious, cybersecurity technology continues to expand and evolve. Therefore, addressing security threats has become an ever-increasing priority for the federal government. Enforcement of “Controlled Unclassified Information” (CUI) protection continues to intensify as private government contractors and other non-federal organisations are continually required to update their security systems and procedures to meet the threats of the day. In December 2015, the U.S. Department of Defence (DoD) published a FAR (Federal Acquisition Regulations) supplement referred to as the Defence Acquisition Federal Regulation Supplement (DFARS). The DFARS is intended to maintain cybersecurity standards according to requirements laid out by the National Institute of Standards and Technology (NIST), specifically NIST SP 800-171.
Key Takeaways
- The Defence Federal Acquisition Regulation Supplement (DFARS) is a set of cybersecurity regulations imposed by the Department of Defence (DoD) on external contractors and suppliers.
- DFARS is designed to maintain cybersecurity standards according to the requirements outlined in NIST SP 800-171.
- Enforcement of “Controlled Unclassified Information” (CUI) protection is a key focus of the DFARS regulations.
- Private government contractors and non-federal organisations must continuously update their security systems and procedures to meet evolving cyber threats.
- Failure to comply with DFARS requirements could result in the loss of current DoD contracts for defence contractors.
Introduction to DFARS Compliance
DFARS compliance is crucial for defence contractors to secure controlled unclassified information and adhere to stringent cybersecurity requirements mandated by the Department of Defence. The DFARS regulations were constructed to protect the confidentiality of CUI and had given DoD contractors until December 31, 2017 to meet the requirements necessary to be classified as DFARS compliant. Failure to meet these requirements could have resulted in the loss of current DoD contracts. With the deadline now past, all DoD contractors must meet the minimum requirements and show proof to the Department of Defence for all contracts moving forward.
Definition and Significance of DFARS Compliance
DFARS compliance is a crucial aspect for defence contractors to secure controlled unclassified information and adhere to the stringent cybersecurity requirements mandated by the Department of Defence. The DFARS regulations were designed to protect the confidentiality of CUI, and DoD contractors were given until December 31, 2017 to meet the necessary requirements to be classified as DFARS compliant. Failure to do so could have led to the loss of current DoD contracts.
Cybersecurity Threats and the Need for Compliance
As cyber threats become more serious, cybersecurity technology continues to expand and evolve. Therefore, addressing security threats has become an ever-increasing priority for the federal government. Enforcement of “Controlled Unclassified Information” (CUI) protection continues to intensify as private government contractors and other non-federal organisations are continually required to update their security systems and procedures to meet the threats of the day.
Overview of DFARS Regulations
The DFARS regulations were constructed to protect the confidentiality of CUI (Controlled Unclassified Information) and had given DoD contractors until December 31, 2017 to meet the requirements necessary to be classified as DFARS compliant. These standards were constructed to protect the confidentiality of CUI and had given DoD contractors until December 31, 2017 to meet the requirements necessary to be classified as DFARS compliant.
The DFARS regulations detail the security requirements that DoD contractors must implement to safeguard CUI in their unclassified information systems. This includes adhering to the guidelines set forth in NIST SP 800-171, which outlines 14 families of security controls to protect the confidentiality of CUI. Compliance with these regulations is essential for DoD contractors to maintain their government contracts and avoid potential penalties for non-compliance.
To be considered DFARS compliant, non-federal and contractor information systems/organisations must pass a readiness assessment following the NIST SP 800-171 guidelines. This ensures that appropriate security measures are in place to safeguard CUI from unauthorised access and disclosure, meeting the stringent cybersecurity requirements mandated by the Department of Defence.
NIST SP 800-171 Requirements
To meet the minimum requirements, DoD contractors must provide adequate security to safeguard covered defence information that resides in or transits through their internal unclassified information systems from unauthorized access and disclosure. DFARS details fourteen groups of security requirements, which affect numerous aspects of IT information security. In order to be considered DFARS compliant, non-federal and contractor information systems/organisations must pass a readiness assessment following NIST SP 800-171 guidelines.
Access Control
The NIST SP 800-171 Access Control guidelines stipulate that DoD contractors must implement effective controls to manage and restrict access to their information systems and the data they contain. This includes establishing user identification and authentication procedures, implementing least privilege and role-based access principles, and regularly reviewing and updating access privileges.
Awareness and Training
The NIST SP 800-171 Awareness and Training requirements focus on ensuring that all personnel with access to controlled unclassified information (CUI) are properly trained on their responsibilities and the procedures for protecting this data. This includes conducting regular security awareness training, as well as providing more specialised training for system administrators and other key personnel.
Audit and Accountability
The NIST SP 800-171 Audit and Accountability guidelines require DoD contractors to implement comprehensive logging and auditing mechanisms to track user activities, system events, and security incidents. This data must be regularly reviewed and analysed to detect and respond to potential security breaches.
Configuration Management
The NIST SP 800-171 Configuration Management requirements mandate that DoD contractors establish and maintain effective controls over the configuration of their information systems. This includes managing system changes, maintaining baseline configurations, and implementing secure configuration settings to mitigate vulnerabilities and reduce the risk of unauthorised access or data compromise.
Implementing DFARS Compliance
Gap Analysis and Risk Assessment
The first step towards DFARS compliance will require the Managed Security Service Provider (MSSP) to assess how close or far the DoD contractor is from meeting the minimum requirements outlined in DFARS. This process is called the Gap Analysis. Gap Analyses are designed to identify inadequate system setups and processes that may not meet the DFARS regulations. Taking a close look at a company’s network and procedures is the first step to ensuring DFARS compliance. The results of the gap analyses may reveal issues related to access control, awareness and training, audit and accountability, and configuration management.
Developing a Compliance Strategy
An MSSP will develop a remediation plan based on the findings of the gap analysis. The remediation plan may involve small, relatively inexpensive fixes to a network and/or its processes, or it may require more extensive development of compliant networks and processes that meet today’s NIST cybersecurity standards. Remediation plans provide detailed documentation of processes that don’t meet current standards, making it easier for DoD Contractors to implement necessary changes to their systems.
Implementing Security Controls
Once the remediation plan is complete and a DoD Contractor’s systems and procedures are DFARS compliant, an MSSP will have the tools and processes in place to monitor, detect, and report on cybersecurity breaches within the DoD Contractor’s systems in accordance with DFARS policy section 204.7302. If the DoD Contractor is not outsourcing compliance to an MSSP, they have the option to report cyber incidents themselves, provided they have the necessary tools to monitor and detect such incidents.
Roles and Responsibilities
DoD Contractors remain ultimately responsible for ensuring that their company meets the DFARS requirements, so it is essential to choose a Managed Security Service Provider (MSSP) you are sure you can trust. By outsourcing the DFARS Compliance work to a qualified provider, DoD contractors should save a lot of time and money getting and staying compliant. An outsourced provider will have all of the required document templates for the Gap Analysis and the System Security Plan as well as the advanced tools required to monitor and respond to security incidents.
Senior Management’s Role
DoD Contractors remain ultimately responsible for ensuring that their company meets the DFARS requirements, so it is essential to choose an MSSP you are sure you can trust. By outsourcing the DFARS Compliance work to a qualified provider, DoD contractors should save a lot of time and money getting and staying compliant. An outsourced provider will have all of the required document templates for the Gap Analysis and the System Security Plan as well as the advanced tools required to monitor and respond to security incidents.
Information Security Team’s Role
DoD Contractors remain ultimately responsible for ensuring that their company meets the DFARS requirements, so it is essential to choose an MSSP you are sure you can trust. By outsourcing the DFARS Compliance work to a qualified provider, DoD contractors should save a lot of time and money getting and staying compliant. An outsourced provider will have all of the required document templates for the Gap Analysis and the System Security Plan as well as the advanced tools required to monitor and respond to security incidents.
Continuous Monitoring and Incident Response
Ensuring ongoing DFARS compliance is a critical aspect of protecting sensitive information and preventing cyber incidents. Once the Managed Security Service Provider (MSSP) helps clients meet DFARS/NIST SP 800-171 standards, they will provide legal documentation that proves compliance. This documentation provides legal protection from potential fines. Instead of taking risks, companies should make sure they have the proper safeguards and documentation in place to avoid penalties for non-compliance.
Monitoring for DFARS Compliance
Once the remediation plan is complete and a DoD Contractor’s systems and procedures are DFARS compliant, an MSSP will have the tools and processes in place to monitor, detect, and report on cybersecurity breaches within the DoD Contractor’s systems in accordance with DFARS policy section 204.7302. If the DoD Contractor is not outsourcing compliance to an MSSP, they have the option to report cyber incidences themselves, given they have tools to monitor and detect such incidents.
Incident Response Plan
Once the remediation plan is complete and a DoD Contractor’s systems and procedures are DFARS compliant, an MSSP will have the tools and processes in place to monitor, detect, and report on cybersecurity breaches within the DoD Contractor’s systems in accordance with DFARS policy section 204.7302. If the DoD Contractor is not outsourcing compliance to an MSSP, they have the option to report cyber incidences themselves, given they have tools to monitor and detect such incidents.
Reporting Cyber Incidents
Once the remediation plan is complete and a DoD Contractor’s systems and procedures are DFARS compliant, an MSSP will have the tools and processes in place to monitor, detect, and report on cybersecurity breaches within the DoD Contractor’s systems in accordance with DFARS policy section 204.7302. If the DoD Contractor is not outsourcing compliance to an MSSP, they have the option to report cyber incidences themselves, given they have tools to monitor and detect such incidents.
DFARS Compliance, Defense Contractors
DFARS compliance is crucial for defence contractors to secure controlled unclassified information and adhere to stringent cybersecurity requirements mandated by the Department of Defence. The DFARS regulations were constructed to protect the confidentiality of CUI and had given DoD contractors until December 31, 2017 to meet the requirements necessary to be classified as DFARS compliant. Failure to meet these requirements could have resulted in the loss of current DoD contracts. With the deadline now past, all DoD contractors must meet the minimum requirements and show proof to the Department of Defence for all contracts moving forward.
Challenges in Achieving DFARS Compliance
For many small DoD contractors, the most effective way to meet the requirements of DFARS is to outsource the task to a Managed Security Service Provider (MSSP) that specialises in DFARS consulting, or IT Risk Management and Compliance. While data security is an increasingly complex field, the DoD has kept the requirements on contractors straightforward and reasonable. However, meeting the SP 800-171 is not a one-time fix, rather it is a continuous assessment, monitoring and improvement process. That means that a DoD contractor will have to allocate a considerable number of man-hours devoted solely to ensuring that its business remains compliant with constantly evolving security requirements.
Resource Constraints
For many small DoD contractors, the most effective way to meet the requirements of DFARS is to outsource the task to a Managed Security Service Provider (MSSP) that specialises in DFARS consulting, or IT Risk Management and Compliance. While data security is an increasingly complex field, the DoD has kept the requirements on contractors straightforward and reasonable. However, meeting the SP 800-171 is not a one-time fix, rather it is a continuous assessment, monitoring and improvement process. Interpreting and implementing these requirements can be a daunting task for organisations that do not have in-house cybersecurity expertise.
Lack of Expertise
For many small DoD contractors, the most effective way to meet the requirements of DFARS is to outsource the task to a Managed Security Service Provider (MSSP) that specialises in DFARS consulting, or IT Risk Management and Compliance. While data security is an increasingly complex field, the DoD has kept the requirements on contractors straightforward and reasonable. However, meeting the SP 800-171 is not a one-time fix, rather it is a continuous assessment, monitoring and improvement process. Implementing the required security controls may necessitate significant adjustments to existing workflows, processes, and even company culture. Defence contractors must be prepared to effectively manage this resistance and foster a culture of cybersecurity awareness and compliance across all levels of the organisation.
Organisational Resistance
Best Practices for DFARS Compliance
There are several steps defence contractors can take to facilitate a smooth DFARS 7019 compliance process. First, it is crucial to understand the DFARS 7019 requirements and what they mean for the organisation. Ensure that all relevant stakeholders in the organisation are aware of these compliance requirements.
Conducting Gap Analysis
To identify where their information systems may be lacking in terms of security controls, defence contractors should conduct a thorough NIST SP 800-171 Gap Analysis. This assessment should involve both technical and non-technical stakeholders to ensure a comprehensive understanding of the organisation’s cybersecurity posture.
Developing a Compliance Plan
Defence contractors should create a roadmap to achieve DFARS compliance, including timelines, tasks, and responsibilities. Develop a plan for ongoing monitoring and maintenance of compliance.
Employee Training
Educate employees on the DFARS 7019 requirements and how they can contribute to compliance efforts. Ensure that all employees are aware of their roles and responsibilities in achieving DFARS compliance.
Penalties for Non-Compliance
DoD Contractors that are audited by the Department of Defence and are found to not be in compliance with DFARS Non-Compliance NIST SP 800-171 are likely to face a stop-work order. This means that their work on behalf of DoD will be suspended until they implement suitable security measures to protect CUI. In addition, the Department of Defence may impose Penalties including seeking damages for breach of contract and false claims. In the worst case scenario, DoD contractors could find that their Contract Termination with the Department of Defence are terminated. They could even face suspension or debarment from working with the Department of Defence again.
| Penalties for DFARS Non-Compliance | Impact |
|---|---|
| Stop-Work Order | Suspension of work on DoD contracts until security measures are implemented |
| Financial Penalties | Damages for breach of contract and false claims |
| Contract Termination | Contracts with DoD may be terminated; potential suspension or debarment from future work |
DCMA Audits and Assessments
The Defence Contract Management Agency (DCMA) is responsible for ensuring that contractors comply with the requirements of DFARS 7019. To achieve this, the DCMA conducts audits and assessments of contractors to ensure they are implementing appropriate controls and processes to protect unclassified controlled technical information (UCTI). The DCMA also provides guidance and training to contractors on how to comply with DFARS 7019 and assists in the development and implementation of UCTI protection plans. Additionally, the DCMA may provide support and assistance to contractors in the event of a DFARS Compliance or cybersecurity incident or breach.
The DCMA Audits and Assessments play a crucial role in verifying that DFARS Compliance measures are effectively implemented by defence contractors. These comprehensive reviews examine the contractors’ security controls, processes, and overall adherence to the NIST SP 800-171 guidelines. The audit findings are then used to provide contractors with detailed feedback and recommendations for improving their Compliance Assessments and strengthening their cybersecurity posture.
By working closely with the DCMA, defence contractors can ensure they maintain full DFARS Compliance and avoid potential penalties or contract terminations. The DCMA’s guidance and support throughout the audit process helps contractors identify and address any gaps or vulnerabilities in their information systems, ultimately enhancing the overall security of controlled unclassified information.
Outsourcing DFARS Compliance
For many small DoD contractors, the most effective way to meet the requirements of
DFARS compliance
is to outsource the task to a Managed Security Service Provider (MSSP) that specialises in DFARS consulting, or IT Risk Management and Compliance. By outsourcing the
DFARS Compliance
work to a qualified provider, DoD contractors should save a considerable amount of time and money in getting and staying compliant.
Benefits of Outsourcing
Outsourcing DFARS compliance to an experienced MSSP offers several key benefits. Firstly, the MSSP will have the necessary expertise and tools to efficiently navigate the complex DFARS compliance requirements, including conducting gap analyses, developing remediation plans, and implementing the required security controls. This can be a significant advantage for small DoD contractors who may lack in-house cybersecurity expertise.
Additionally, an MSSP can provide ongoing monitoring and incident response capabilities, ensuring that the DoD contractor remains DFARS compliant on a continuous basis. This frees up the contractor’s internal resources to focus on their core business operations. Furthermore, by outsourcing to a specialised provider, DoD contractors can benefit from economies of scale and access to the latest security technologies and best practices.
Overall, outsourcing DFARS compliance to a trusted MSSP can be a strategic move for DoD contractors, helping them to efficiently meet the stringent cybersecurity requirements while minimising the burden on their own resources and allowing them to stay focused on their core business objectives.