Compare

DoW IL2 / IL4 vs DFARS 252.204-7012: how they differ, side by side

How DoW IL2 / IL4 and DFARS 252.204-7012 differ: what each is, who owes it, when it applies and who enforces it.

DoW IL2 / IL4Binding on DoD components; applies to cloud providers through DISA authorization and contracts

DFARS 252.204-7012Binding on DoD contractors through contract

Checked21 Oct 2026

01 / Side by side

DoW IL2 / IL4 and DFARS 252.204-7012, side by side

	DoW IL2 / IL4	DFARS 252.204-7012
What it is	federal standard	contract clause
Jurisdiction	United States (federal)	United States (federal)
Legal force	Binding on DoD components; applies to cloud providers through DISA authorization and contracts	Binding on DoD contractors through contract
Status	In force	In force
Who owes it	Commercial cloud service providers seeking a DoD Provisional Authorization, and DoD mission owners hosting DoD data in commercial cloud.	DoD contractors and subcontractors whose information systems process, store or transmit covered defense information, or that provide operationally critical support.
Enforcement	DISA Authorizing Official (PA issuance, conditions, revocation) and DoD component authorizing officials; contract remedies. No fines.	DoD contracting officers through contract remedies (termination, withholding, exclusion); misrepresented compliance can bring False Claims Act liability. No fixed fines in the clause.

02 / DoW IL2 / IL4

What DoW IL2 / IL4 requires

Applies to AI systems as to any system: commercial AI services handling DoD CUI need at least an IL4 Provisional Authorization, and IL2 only suits public or non-critical data.

01IL2: hold a FedRAMP Moderate or High authorization for the cloud service offering.
02IL4: implement FedRAMP Moderate controls plus DISA parameters and the SRG's FedRAMP+ controls (Table D-1).
03IL4: connect through a DoD-approved Boundary Cloud Access Point and use DoD PKI authentication.
04Obtain a DoD Provisional Authorization from the DISA Authorizing Official, then the mission owner's ATO.
05Maintain continuous monitoring, including 30/90/180-day vulnerability remediation and annual assessments.

03 / DFARS 252.204-7012

What DFARS 252.204-7012 requires

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.

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.

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