Which elements must a DoD contract require for CUI protection?

Safeguarding only.

Marking only.

Flow-down only.

Safeguarding, marking, flow-down, and incident reporting.

Protecting CUI in DoD contracts requires four interconnected protections. Safeguarding means applying the appropriate security controls to prevent unauthorized access or disclosure, typically aligning with NIST SP 800-171 requirements such as access controls, encryption, incident response, and monitoring. Marking ensures CUI is clearly labeled so everyone handling it understands the required handling and restrictions. Flow-down makes sure that these protections are extended to any subcontractors or service providers in the supply chain, so protections aren’t limited to prime contractors alone. Incident reporting requires timely notification to the DoD of any cyber incidents involving CUI, with the information DoD needs to respond and recover.

Only one of these elements by itself doesn’t cover all obligations; safeguarding, marking, flow-down, and incident reporting together provide comprehensive protection.

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