DFARS, NIST, and CMMC: What’s the Difference, and Why It Matters for Your Business

Cybersecurity compliance has become one of the most important parts of Department of Defense (DoD) contracts. With cyber attacks rising in frequency and sophistication, all parties handling sensitive government information must stay vigilant and implement proper protections.

For this reason, the DoD is locking down on standards like DFARS, NIST, and CMMC 2.0. But what do all these acronyms really mean? Are they all the same thing? What do they mean for your business? We're answering all of these questions and more in this basic guide to DoD regulatory compliance.

What Is DFARS?

The Defense Federal Acquisition Regulation Supplement (DFARS) is a subset of the Federal Acquisition Regulation (FAR) that provides specific requirements and rules for defense contractors and subcontractors to maintain regulatory compliance.

The ultimate goal of DFARS is to create a standard for contractors to protect sensitive government data, specifically controlled unclassified information (CUI), which is data that is sensitive and relevant to national security but not technically classified.

DFARS 252.204-7012 outlines specific cybersecurity requirements contractors must meet to effectively protect CUI, including implementing the controls outlined in NIST SP 800-171 and reporting cybersecurity incidents to the DoD within 72 hours.

What Is NIST 800-171?

The National Institute of Standards and Technology (NIST) is responsible for developing guidelines to help businesses protect their technology and sensitive data. NIST's Special Publication (SP) 800-171 specifically outlines how to protect CUI within non-federal systems.

It defines best cybersecurity practices for contractors working with CUI by organizing 110 controls into 14 families (i.e., categories), such as access controls, incident response, and awareness and training.

So how does this relate to DFARS? NIST SP 800-171 serves as the basis or core standard for DFARS regulatory compliance. If DFARS 252.204-7012 is the "what" (protect CUI), then NIST SP 800-171 is the "how" (a detailed framework of how to do so).

What Is CMMC?

The Cybersecurity Maturity Model Certification (CMMC) outlines comprehensive instructions for protecting CUI, helping DoD contractors maintain sufficient cybersecurity and safeguard sensitive government information. The certification outlines clear expectations and gives the DoD a way to distinguish which companies meet the standards for protecting CUI.

The requirements in NIST SP 800-171 are part of the CMMC regulations, but CMMC includes additional guidance about specific types of contracts and data. The newest version of CMMC, CMMC 2.0, is organized into three maturity levels to help clarify the differentiation between contracts and data classification levels:

• Level 1: Foundational is for contractors working with federal contract information (FCI), which is less sensitive than CUI, and requires annual self-assessments.

• Level 2: Advanced is for businesses that handle CUI. It aligns with NIST 800-171. Contractors may need annual self-assessments or triennial third-party audits, depending on their contract.

• Level 3: Expert aligns with NIST 800-172 and is designed to protect highly-sensitive CUI. This level requires triennial government-led audits.

CMMC 2.0 was recently approved and will start becoming a mandatory part of DoD contracts in mid-2025. This more stringent regulatory compliance is intended to strengthen cybersecurity protocols among contractors and ensure FCI and CUI are safe and secure.

How Do These Frameworks Work Together?

Trying to keep all of the acronyms and numbers straight can be confusing, but now that you have a basic understanding of DFARS, NIST 800-171, and CMMC 2.0, let's summarize how they're all connected:

• DFARS - sets the regulatory compliance rules for DoD contracts and, specifically, for protecting CUI.

• NIST 800-171 - provides detailed guidelines for meeting the rules set by DFARS. 

• CMMC 2.0 - outlines a clear structure for implementing these controls and verifies a contractor's compliance with them through a certification.

What's Next?

What does all of this mean for your business? If you're hoping to secure or maintain a DoD contract, here are the basic steps you need to take to align with all three of these regulatory compliance standards:

1. Hire a Compliance Specialist: An MSP that has experience with DoD contractors can help you ensure you're meeting standards and launch new tools and controls seamlessly.

2. Conduct a Gap Analysis: Run an in-house audit to identify gaps in your current cybersecurity infrastructure and what requirements of CMMC 2.0 you aren't meeting.

3. Implement NIST SP 800-171 Controls: Focus on incorporating these foundational controls into your existing cybersecurity framework.

4. Document Cybersecurity Protocols: If you don't already, start carefully recording all of your cybersecurity policies, controls, protocols, etc., as documentation is required for CMMC 2.0 compliance.

5. Prepare for Your Audit and Certification: Consult with your IT company for specific advice on how you can prepare for your CMMC audit. They can help you organize documentation, run test audits, and provide detailed feedback on room for improvement.

Why Does Regulatory Compliance Matter for My Business?

When you don't prioritize regulatory compliance in your business, you put a lot at risk—including failed audits, lost contracts, legal penalties, non-compliance fines, and vulnerability to cyber threats.

On the flip side, when you make an active effort to stay compliant, you can build trust with government clients and demonstrate your dedication to protecting crucial national data. You'll be able to secure contracts, avoid dangerous breaches, and set yourself apart as a contractor.

Make Compliance a Breeze with ICS

Keeping track of the complex ins and outs of compliance can be overwhelming, especially when you're already busy with your business's core operations. But when you partner with ICS, compliance becomes stress-free. We'll use our expertise and experience to take care of the compliance details while you focus on your work.

You can always count on our help to protect sensitive data, avoid cyber threats, build trust, and secure contracts seamlessly. Reach out to learn more about regulatory compliance or schedule your gap assessment.