Basic Safeguarding of Covered Contractor Information Systems
Contractors handling Federal contract information must implement and maintain specific baseline cybersecurity safeguards and flow these requirements down to eligible subcontractors.
Overview
FAR 52.204-21 establishes mandatory minimum safeguarding requirements for contractor information systems that process, store, or transmit Federal contract information (FCI). The clause defines key terms and outlines 15 specific security controls that contractors must implement to protect FCI from unauthorized access, disclosure, or loss. These requirements apply to both prime contractors and applicable subcontractors, including those providing commercial products or services (excluding COTS items). The clause also clarifies that these are baseline requirements and do not supersede any additional safeguarding obligations imposed by agencies or for controlled unclassified information (CUI).
Key Rules
- Definitions and Scope
- Clearly defines covered contractor information systems, Federal contract information, and safeguarding measures.
- Mandatory Security Controls
- Contractors must implement 15 specific security controls, including access restrictions, authentication, physical security, monitoring, malware protection, and timely flaw remediation.
- Subcontractor Flowdown
- The clause must be flowed down to applicable subcontracts where FCI may be present, except for COTS items.
- Additional Requirements
- Does not relieve contractors of other agency-specific or CUI safeguarding requirements.
Responsibilities
- Contracting Officers: Ensure inclusion of this clause in applicable contracts and verify flowdown to subcontracts.
- Contractors: Implement all specified security controls, flow down the clause to eligible subcontractors, and maintain compliance with any additional safeguarding requirements.
- Agencies: May impose further safeguarding requirements for CUI or other sensitive information.
Practical Implications
- This clause sets a baseline for cybersecurity in federal contracting, aiming to reduce the risk of data breaches involving FCI.
- Contractors must assess and, if necessary, upgrade their information systems and practices to meet these requirements.
- Failure to comply can result in contractual remedies, increased scrutiny, or loss of eligibility for future awards.