Question · DFARS 252.204-7012

Does DFARS 252.204-7012 apply to AI systems handling CUI?

The clause requires 'adequate security' for covered defense information, meaning NIST SP 800-171 on contractor systems, and rapid reporting of cyber incidents to DoD.

AboutDFARS 252.204-7012
Legal forceBinding on DoD contractors through contract
Applies from31 Dec 2017
Checked21 Oct 2026

01 / The answer

The short answer

Yes. If a contractor's AI system processes, stores or transmits covered defense information, it is a covered contractor information system under DFARS 252.204-7012. It must meet NIST SP 800-171 (DoD's 2024 class deviation specifies Rev. 2), and cyber incidents affecting it must be reported to DoD through DIBNet within 72 hours, with affected images kept for at least 90 days. If the AI runs as an external cloud service, the provider must meet security equivalent to the FedRAMP Moderate baseline. The July 2026 CMMC Phase 2 suspension did not change these duties.
DFARS 252.204-7012 · checked 21 Oct 2026

02 / The rule

What DFARS 252.204-7012 requires

The clause requires 'adequate security' for covered defense information, meaning NIST SP 800-171 on contractor systems, and rapid reporting of cyber incidents to DoD. It is the baseline that CMMC assesses and it stayed in force when CMMC Phase 2 was suspended in July 2026.

  1. 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systems; DoD's class deviation holding contractors to Rev. 2 (2024-O0013, Revision 1) says it stays in effect until rescinded.
  2. 02Ensure external cloud providers storing covered defense information meet security equivalent to the FedRAMP Moderate baseline.
  3. 03Report cyber incidents to DoD via DIBNet within 72 hours of discovery.
  4. 04Submit discovered malicious software to the DoD Cyber Crime Center (DC3).

03 / Records

Records to keep

  1. 01System security plan and NIST SP 800-171 assessment
  2. 02SPRS basic assessment score
  3. 03Cloud provider FedRAMP Moderate (or equivalent) documentation
  4. 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.

01 · Your teamRecord the event

A disclosure shown, a review signed, a model change approved: the event your system reports.

02 · PlanisphereSeal it

The event becomes a sealed receipt, dated and attributed to whoever is signed in.

03 · AnyoneCheck it

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

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Related: DFARS 252.204-7012: the full guide