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DFARS ClauseCybersecurity

DFARS 252.204-7021Cybersecurity Maturity Model Certification Requirements

Implements the CMMC program — requires contractors handling FCI or CDI to achieve and maintain a CMMC certification at the level specified in the solicitation.

When This Clause Applies

Phased rollout — applies to DoD solicitations starting in the CMMC implementation period (currently rolling out 2025-2028). Level 1 (FCI), Level 2 (CDI), or Level 3 (high-priority CDI) per solicitation.

What This Means for Contractors

Contractors must achieve CMMC certification at the required level before award. Level 1 is annual self-assessment. Level 2 requires C3PAO third-party assessment every 3 years. Level 3 requires DIBCAC-led government assessment. Subcontractors must be certified at the appropriate level for the CUI/FCI they handle.

Common Pitfalls

  • 1Delaying preparation — Level 2 assessments take 6-12 months
  • 2Treating CMMC as IT-only — it includes physical, personnel, and process controls
  • 3Choosing the wrong CMMC level — under-certification means lost bids
  • 4Not scoping CUI/FCI accurately, leading to oversized assessment scope

Related Topics

DFARS 252.204-7021CMMC certificationCMMC Level 2C3PAO assessmentCMMC implementation

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