Training & Education

The Department of War has paused the rollout of CMMC Phase 2, but that does not mean CMMC Level 2, NIST SP 800-171, DFARS requirements, or CUI safeguarding obligations have been canceled or suspended. Contractors should use this review period to close security gaps, maintain accurate self-assessments, and continue protecting Controlled Unclassified Information—not put compliance efforts on hold.

If you work with the Department of Defense (DoD) or support the Defense Industrial Base (DIB), you’ve almost certainly heard the term CUI—but it’s also one of the most misunderstood concepts in compliance. Understanding Controlled Unclassified Information (CUI) is foundational to DFARS, NIST SP 800-171, and CMMC compliance. This guide breaks it down clearly and practically.

Does ITAR or EAR-controlled technical data count as CUI under a DoD contract? In many cases, yes. When export-controlled technical data or technology is provided by the government or generated during DoD contract performance, it may qualify as CUI and require proper marking, access controls, and physical safeguarding. This guide explains how ITAR, EAR, DFARS 252.204-7012, and CUI requirements intersect, what manufacturers need to protect, and how to reduce compliance risk in engineering, production, quality, and visitor-access areas.

Important clarifications provided by the DoD were recently released on the CMMC Phase I timeline and the impact on contracts after the effective date. The deadline is September 2025... Are you ready?