During the Department of Defense's "Industry Information Day" this summer, DoD leaders attempted to give clarity on the DFARS 252.204-7012 clause on CDI/CUI protection and the requirements.
Compliance to DFARS can be difficult even for those contractors who are more experienced. For companies in defense supply chain or subcontractors, the scale of the project can be overwhelming when resources are limited. However, taking the System Security Plan and Plan of Action & Milestones approach (two documents easily created and documented in the CyberStrong platform among other DFARS compliance capabilities) is a preferable path to take for those who are lagging or who are moving through the project at a slower pace than a company with endless resources.
Many contractors hoped that the deadline would be extended, but on Industry Day, the DoD said otherwise - that the December 31st deadline is a hard deadline for reporting compliance or submitting your documents to the appropriate stakeholder. The DoD recommended that those interested in keeping their eligibility for future contracts should complete DFARS implementation by the end of the year.
Contractors are Requiring Their Supply Chains to Comply
Contractors like Raytheon and others are requiring their supply chains to comply to the regulation as detailed on their website.
Raytheon: "Contractors must provide adequate security for covered contractor information systems," to include implementing the security controls of National Institute of Standards and Technology (NIST) SP 800-171, as soon as practical but no later than Dec 31, 2017".
Additionally, companies like Raytheon have specified that flow down is inevitable "This DFARS clause must be flowed down in any subcontracts or similar contractual instruments in which subcontract performance will involve covered defense information or operationally critical support". Ultimately, whether you work directly with a prime contractor or contribute to a part of their efforts, your progress on DFARS by December 31st, 2017 could easily help you win or lose future contracts.