DFARS Compliance Checklist: Key Steps to Protect Your DoD Contracts
February 13, 2025 at 10:00 PM
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To no-ones surprise, the Department of Defense (DoD) requires contractors to meet specific standards to protect sensitive data and ensure the security of its operations.

This is where DFARS (Defense Federal Acquisition Regulation Supplement) compliance becomes crucial. The DFARS guidelines are designed to safeguard controlled unclassified information (CUI) within the DoD supply chain. Achieving DFARS compliance is essential for contractors seeking to do business with the Department of Defense, as failure to meet these standards can result in loss of contracts and significant penalties.

In this article, we’ll walk you through the key steps to ensure your business remains DFARS compliant. We'll also provide an essential DFARS compliance checklist to help you protect your DoD contracts.

What is DFARS Compliance?

DFARS compliance refers to the requirement that contractors working with the Department of Defense adhere to the guidelines outlined in the Defense Federal Acquisition Regulation Supplement. DFARS sets forth rules regarding how contractors should handle Controlled Unclassified Information (CUI) and implement cybersecurity measures to ensure that sensitive data is properly protected.

DFARS Compliance Checklist: Key Steps to Protect Your DoD Contracts

Achieving DFARS compliance requires a combination of technical, administrative, and policy-based actions. Below is a checklist of essential tasks that will guide you through the process of becoming DFARS compliant, protecting your DoD contracts, and maintaining compliance in the long term.

1. Understand the DFARS Requirements

Ensure that you fully comprehend the specific requirements that apply to your organization, including:

  • Protection of CUI from unauthorized access
  • Incident reporting and breach notifications
  • Implementation of NIST 800-171 cybersecurity controls
  • Contractual obligations for safeguarding DoD data

2. Conduct a Security Assessment

Perform a thorough security assessment of your information systems. This should include evaluating your organization's current cybersecurity posture, identifying potential vulnerabilities, and assessing how CUI is handled.

  • Identify all systems and networks that process or store CUI
  • Evaluate existing security measures, including access controls, firewalls, encryption, and intrusion detection systems
  • Conduct penetration testing to identify weaknesses in your security infrastructure

3. Implement Security Controls for CUI

Your company must implement each of the the 110 security requirements outlined in NIST 800-171, which cover areas such as access control, incident response, audit and accountability, and system security.

Some of the key security controls include:

  • Access Control: Ensure that only authorized personnel can access CUI by implementing strong user authentication methods.
  • Incident Response: Establish an incident response plan for handling security breaches or data compromises.
  • Audit and Accountability: Regularly log and review access to CUI to detect any unusual or unauthorized activity.
  • System Security: Implement network security measures like firewalls, intrusion detection systems, and encryption protocols to protect CUI from cyber threats.

4. Monitor and Test Compliance

Achieving DFARS compliance is not a one-time task—it requires continuous monitoring and testing. Regularly audit your systems to ensure that they remain in compliance. You should also keep an eye on new regulations and updates to DFARS. Compliance requirements may evolve, so it’s important to stay current with any changes that may affect your security practices.

5. Document Policies and Procedures

Proper documentation is a critical aspect of DFARS compliance. You need to develop and maintain written policies and procedures that outline how your company handles and protects CUI. This includes the following:

  • Cybersecurity Policies: Document your cybersecurity protocols, including how you safeguard CUI, manage access control, and handle incidents.
  • Incident Response Procedures: Create a clear and detailed incident response plan that outlines how you’ll respond to security breaches.
  • Training Programs: Develop a training program for your employees to ensure they understand their roles in protecting CUI and following your security procedures.
  • Continuous Improvement Plans: Document your strategies for continuously improving your cybersecurity measures to stay compliant with DFARS and protect DoD data.

6. Report Security Incidents

DFARS requires contractors to report any security incidents involving CUI within 72 hours of discovery. It’s essential to have a clear process for reporting incidents to the DoD. Make sure your organization has an incident reporting mechanism in place, and ensure that all employees know how to identify and report potential cybersecurity incidents.

7. Prepare for Audits and Assessments

The DoD may conduct audits or assessments to verify that contractors are in compliance with DFARS. Be prepared for these evaluations by keeping your systems and policies up to date. Make sure all documentation is easily accessible, and that your security measures are fully implemented and functioning as expected.

  • Keep a record of all actions taken to address DFARS requirements.
  • Have a plan in place for responding to any audit inquiries or requests for additional documentation.

Trust the Experts in DFARS Compliance

The process of becoming DFARS compliant can seem complex, but with careful planning and attention to detail, you can ensure your business meets the security standards required to protect CUI and remain eligible for DoD contracts. Remember, cybersecurity is an ongoing process—regular assessments and updates are essential to maintaining compliance and defending against emerging threats.

By prioritizing DFARS compliance, your organization will not only meet regulatory requirements but also build trust with your DoD partners and protect the integrity of your sensitive data. Get in touch with us at It’s Just Results today to ensure that you are DFARS compliant.