The generation, collection, processing, storage, usage, archiving, and destruction of data has become a massive concern for government entities in what seems like no time. Online privacy and data protection regulations were almost non-existent just a few years ago. Fast forward to today, and personal data management is becoming a massive concern.
One type of data that is increasingly under the regulatory spotlight is CUI, which can be dangerous if unsecured because it can affect warfighters and national security. Many companies working toward a DoD contract don't realize they are already handling Controlled Unclassified Information (CUI). The most common type of CUI contractors will encounter is CUI Basic, which is information that isn't classified, but still falls under strict federal rules the moment it enters your environment. If CUI Basic is mishandled, it can lead to failed audits, loss of current work, or being ruled ineligible for future contracts.
The Government Accountability Office (GAO) has reported that the DoD expects contractors to meet 100% compliance with CUI cybersecurity requirements. That's complete adherence to 110 security controls, with no partial credit given, in the case of the DoD’s Cybersecurity Maturity Model Certification (CMMC) 2.0. There is no leeway for "almost done" or "in progress" when an auditor reviews your program.
If you are bidding on or supporting a DoD contract today, the federal clauses that govern CUI Basic already apply. Understanding what it is, how it differs from other information categories, and the steps needed to meet the compliance standard are essential to staying eligible for DoD work.
What is Controlled Unclassified Information (CUI)?
Controlled Unclassified Information (CUI) is a federal label for sensitive data that does not meet the criteria for classification but still requires strict protection. It was established under Executive Order 13556 and is managed by NARA, the National Archives and Records Administration. The purpose is to create a consistent approach for how agencies and their contractors safeguard information that could cause harm if it became public.
In Department of Defense contracts, CUI rarely stays with the prime contractor. It often flows through the Defense Industrial Base, which includes subcontractors, parts manufacturers, software providers, logistics companies, and professional service firms. Any organization that receives CUI takes on the same legal and security responsibilities for protecting it, no matter how far down the supply chain they sit.
CUI is not limited to defense. Federal agencies in healthcare, law enforcement, and infrastructure projects also use the designation. But for defense contractors, it is a constant presence in contract performance, and improper handling of it can shut the door on future awards.
What is CUI Basic?
CUI Basic is the baseline category used when information needs to be protected, but there is no specific statute or government-wide policy that spells out the exact safeguards. The protection rules instead come from one source, the National Institute of Standards and Technology's (NIST) Special Publication 800-171, which defines the complete set of security controls.
When a defense contract involves CUI and the documentation does not call out any other legal requirements, that information is almost always treated as CUI Basic. This is the form of information most companies in the defense supply chain handle every day. It differs from CUI Specified, which applies when a law or regulation sets additional, non-negotiable rules, such as export control laws under International Traffic in Arms Regulation (ITAR) or patient privacy requirements under HIPAA.
In real terms, CUI Basic can cover a wide range of information, such as:
- Maintenance instructions and technical manuals for defense equipment
- Engineering drawings or product blueprints
- Inspection records and production test data
- Internal emails or reports exchanged with DoD program staff
- Project schedules and progress updates that are not public
Despite the name, CUI Basic carries a significant compliance load. Federal agencies expect the same level of diligence and proof of protection with CUI Basic as they do for any other CUI category.
Who is responsible for protecting CUI?
The responsibility for protecting CUI, including CUI Basic, sits with your company from the moment it enters your environment, whether you are the prime contractor or three tiers down the supply chain. Federal contract clauses, such as DFARS 252.204-7012, push these obligations to every organization that handles the information. That flowdown exists because a single noncompliant entity in the supply chain could put the entire contract at risk.
For many small and mid-sized businesses, this means that even if you never work directly with the DoD, you may still be bound by its CUI rules because a customer higher in the chain has passed them down. Manufacturers, software developers, law firms, call centers, and logistics providers all fall under the same expectation once CUI is in play.
There is no shared liability model, so each organization is accountable for its own compliance. If your systems are not protecting CUI to the required standard, a prime contractor can remove you from the project to preserve their own standing. The DoD can also act directly, including disqualifying your company from future bids.
How do you protect CUI Basic?
Safeguarding CUI Basic requires meeting every security requirement outlined in NIST Special Publication 800-171. This standard defines 110 individual controls grouped into 14 families. It addresses not only technical defenses but also policies, procedures, and day-to-day operational practices.
The scope of SP 800-171 is broad, and includes:
- Managing who can access CUI
- Encrypting it in storage and during transmission
- Maintaining audit trails
- Preparing for and responding to security incidents
- Keeping systems configured and maintained in a secure state
Any control you cannot meet immediately needs to be logged with a plan and timeline for remediation.
Two documents are required to prove compliance with SP 800-171:
- System Security Plan (SSP): A detailed description of how your company meets each of the 110 controls, including the people, processes, and technologies involved.
- Plan of Action and Milestones (POA&M): A tracked list of any unmet controls, how you plan to address them, and the timeline for completion.
Once CUI Basic is part of your operations, the controls and documentation must be maintained. Federal auditors and contracting officers expect to see that your safeguards are active, current, and verifiable at any point in the contract lifecycle.
6 Steps in CUI Basic Compliance
If your company stores, processes, or transmits CUI Basic for a DoD contract, these steps outline the path to compliance. Each step builds on the last and requires both technical and procedural actions:
Step 1: Confirm Whether You Handle CUI Basic
Begin by reviewing prime contracts, subcontracts, and any Defense Federal Acquisition Regulation Supplement (DFARS) flowdown clauses from higher-tier contractors. Search for terms like "Controlled Unclassified Information," "DFARS 252.204-7012," or "CUI." If the material you receive or create does not have specific safeguarding rules under a statute or regulation but still requires protection, it will default to CUI Basic.
This step is critical because misclassifying the data can cause either under-protection that risks a breach or over-protection that wastes resources. Mapping where CUI enters, moves through, and leaves your systems will clarify its scope and exposure points before you start implementing controls.
Step 2: Implement NIST SP 800-171 Controls
Deploy all 110 controls across your environment. These are divided into 14 families, like Access Control, Incident Response, and System and Communications Protection. The controls apply to every system that stores, processes, or transmits CUI, whether it is hosted on-premises, in the cloud, or on portable devices.
Putting the controls in place means addressing both the technical and procedural sides of security:
- On the technical side, that could be enforcing multi-factor authentication, encrypting data in storage and in transit, and setting up monitoring that alerts you to unusual activity.
- Procedural measures include how physical media is handled, how staff are vetted, and how access is approved or revoked.
Perform a detailed gap analysis against these controls to help you prioritize high-impact changes first and plan for full compliance over time.
Step 3: Develop the Required Documentation
Create a System Security Plan (SSP) that explains how your organization meets each NIST 800-171 control, with details on the technology in use, the policies in place, and who is responsible for carrying them out.
If any controls are not yet in place, document them in a Plan of Action and Milestones (POA&M) with specific remediation steps and deadlines.
These documents are required for both self-assessments and future audits, and must be updated whenever systems, processes, or security measures change.
Step 4: Perform a Self-assessment
Use the Department of Defense's assessment methodology to evaluate your implementation. The process starts with a perfect score of 110 and deducts points for each unmet control, with more points lost for higher-impact requirements. There is no partial credit, so a control is either entirely in place or it is not. The score goes into the government's Supplier Performance Risk System (SPRS) and can influence contract award decisions.
Involve both IT and compliance personnel in the self-assessment to ensure that technical safeguards and policy-driven measures are evaluated accurately. Keep evidence, such as logs, screenshots, or policy excerpts, ready for each control to support your score during an audit or contract review.
Step 5: Submit Your Score to SPRS
Once your self-assessment is complete, submit the score to the Supplier Performance Risk System (SPRS) via the Procurement Integrated Enterprise Environment (PIEE) portal, as required by DFARS 252.204-7012.
Your submission must include your SPRS score, the date of assessment, and your SSP. If you have a POA&M, be prepared to share it with contracting officers upon request.
Be aware that submitting an inflated score can carry legal risk under the False Claims Act, so accuracy is critical. Establish an internal process to re-assess periodically and update your SPRS entry to reflect any changes.
Step 6: Prepare for CMMC Level 2 Audits
CMMC 2.0 Level 2 takes the requirements of NIST 800-171 and adds a formal third-party certification for contracts where the Department of Defense wants extra assurance that CUI is protected. If your contract falls into that category, you will not be able to start work or win the bid without passing the audit.
Even if Level 2 is not yet in your contract, the DoD plans to roll it out more widely, and preparation now prevents last-minute scrambles that can cost you time and opportunities.
You should be able to prove, on demand, that each control is active and enforced.
That requires an up-to-date evidence library, internal reviews that mimic the audit process, and offensive cybersecurity exercises such as simulated attacks to validate real-world readiness.
How Vistrada Positions You to Handle CUI Basic with Confidence
CUI Basic requirements are written into your contract the moment you agree to handle the data. They are not a separate compliance project you can address later. They are part of day-to-day operations from the first file you receive. The challenge for many companies is that these rules demand both deep technical implementation and continuous proof that safeguards are in place.
This is where turning to Vistrada’s experienced consultancy will support you with every stage of meeting and sustaining CUI Basic compliance, including:
- Running full NIST 800-171 assessments and gap analyses that pinpoint missing or weak controls, with clear prioritization for remediation.
- Developing complete, audit-ready documentation, including detailed SSPs, current POA&Ms, and practical incident response plans that can be put into action.
- Guiding accurate SPRS scoring with evidence-backed self-assessments and remediation strategies that strengthen your position before contract reviews.
- Updating or adding your SPRS score in the PIEE system.
- Preparing for CMMC Level 2 audits through targeted pre-audit readiness checks, scenario-based tabletop exercises, and thorough documentation reviews.
- Addressing flowdown compliance and subcontractor risk so third-party gaps do not jeopardize your eligibility.
- Delivering vCISO support from a team of specialists who can handle the technical, procedural, and strategic demands of ongoing CUI Basic protection.
If your contracts involve CUI Basic, the clock is already running.
Engage Vistrada's vCISO team to close your CUI Basic compliance gaps, avoid audit failures, and stay eligible for future DoD contracts. Schedule a consultation today.
