Cybersecurity Compliance for Supplier Systems (NIST SP 800-171)

The contract requires the implementation and ongoing maintenance of cybersecurity controls aligned with NIST Special Publication 800-171 to safeguard controlled unclassified information processed, stored, or transmitted on contractor systems. This obligation stems from the Defense Federal Acquisition Regulation Supplement clause 252.204-7020, which mandates strict compliance for all subcontractors handling CUI on behalf of the Department of Defense. The subcontractor must establish, document, and enforce a comprehensive cybersecurity program that addresses all 14 families of security requirements outlined in NIST SP 800-171, including access control, audit, configuration management, identification and authentication, and incident response. The work is performed under a subcontract issued by the Defense Logistics Agency, categorized under NAICS code 541512 for computer systems design services. The contract is positioned within the broader DoD supply chain, and compliance is not optional—failure to meet these requirements may result in contract termination or debarment. While no specific location for performance is identified, adherence must be maintained across all systems where CUI is present, and continuous monitoring, reporting, and documentation of compliance posture are required. The subcontractor is expected to self-assess and validate control implementation, with readiness for potential government audits or assessments at any time.