Law · DFARS 252.204-7012
DFARS 252.204-7012 for legal AI workflows
DFARS 252.204-7012 in legal AI workflows: what compliance requires, who asks for evidence, and the records to keep.
01 / The rule
What DFARS 252.204-7012 requires
DoD contractors and subcontractors whose information systems process, store or transmit covered defense information, or that provide operationally critical support.
- 01Implement NIST SP 800-171 on covered contractor systems; DoD's class deviation holding contractors to Rev. 2 (2024-O0013, Revision 1) says it stays in effect until rescinded.
- 02Ensure external cloud providers storing covered defense information meet security equivalent to the FedRAMP Moderate baseline.
- 03Report cyber incidents to DoD via DIBNet within 72 hours of discovery.
- 04Submit discovered malicious software to the DoD Cyber Crime Center (DC3).
- 05Preserve images of affected systems and relevant monitoring data for at least 90 days after reporting.
- 06Flow the clause down unaltered to subcontractors handling covered defense information.
02 / In this sector
In a legal AI workflow
Applies to AI systems as to any system: putting covered defense information into an AI tool or external AI cloud service brings that service into scope, including the FedRAMP Moderate equivalency requirement for cloud providers.
General counsel and litigation support.
FRE 702 · ABA Model Rules.
03 / Records
Records to keep
- 01System security plan and NIST SP 800-171 assessment
- 02SPRS basic assessment score
- 03Cloud provider FedRAMP Moderate (or equivalent) documentation
- 04Incident reports, DIBNet report numbers and 90-day image retention logs
Optional evidence · where Planisphere fits
Keep a record anyone can check
When your team meets a duty, Planisphere can seal the event it reports as a receipt.
A disclosure shown, a review signed, a model change approved: the event your system reports.
The event becomes a sealed receipt, dated and attributed to whoever is signed in.
Paste the receipt into Verify. No account or key.
A record supports your compliance evidence process. It is not a legal finding or a certification. Systems that call Planisphere's gate API can also hold or refuse an action before it runs.
SOURCES
Go back to the source
Holland & Knight
RELATED
Related: DFARS 252.204-7012: the full guide · DFARS 252.204-7012 for defense · DFARS 252.204-7012 for medicine · DFARS 252.204-7012 for education