DFARS Cybersecurity Requirements Guide

Quick Answer: DFARS cybersecurity requirements mandate that any contractor or subcontractor handling Controlled Unclassified Information (CUI) for the Department of Defense must implement the 110 security controls defined in NIST SP 800-171. Non-compliance can result in contract loss, suspension, or debarment.

DFARS Clause 252.204-7012 requires defense contractors to implement 110 security requirements across 14 control families drawn from NIST SP 800-171, report cyber incidents within 72 hours, and maintain a System Security Plan (SSP). Meeting these requirements is far more involved than most contractors initially expect. This page covers what the requirements actually include, where organizations typically struggle, and what a realistic path to compliance looks like.

Key Takeaways

• DFARS cybersecurity requirements mandate 110 security controls across 14 NIST SP 800-171 control families for any contractor that processes, stores, or transmits CUI on behalf of the DoD.
• The biggest challenge is scope creep: most contractors underestimate how many systems, users, and vendors fall within the CUI boundary.
• Realistic compliance timelines run 8 to 12 months for organizations starting from scratch, depending on current security posture.
• Building an in-house compliance function costs $84,000 to $132,000 or more per year for a single hire, before factoring in tooling and audit fees.
• A managed compliance partner can get you to DFARS alignment faster and at a lower total cost than staffing the function internally.

What Are DFARS Cybersecurity Requirements?

DFARS Clause 252.204-7012, "Safeguarding Covered Defense Information and Cyber Incident Reporting," is the contractual mechanism that makes NIST SP 800-171 compliance mandatory for DoD contractors. If your contract includes this clause and your work involves CUI, you are legally obligated to meet its requirements.

The 110 security requirements are organized across 14 control families, as defined by NIST SP 800-171 Rev. 2:

Beyond implementing these controls, DFARS also requires you to:

• Maintain a written System Security Plan (SSP) documenting how each requirement is met
• Develop a Plan of Action and Milestones (POA&M) for any requirements not yet fully implemented
• Report cyber incidents to the DoD within 72 hours of discovery
• Preserve and submit forensic images of affected systems when a breach occurs
• Flow down requirements to subcontractors who handle CUI on your behalf

It is worth noting that DFARS compliance and CMMC certification are closely related but not identical. DFARS is the contractual requirement; CMMC Level 2 is the formal third-party verification that you have actually implemented what DFARS demands. Many contractors are now pursuing both simultaneously.

Challenges Companies Face When Getting DFARS Compliant

Most contractors who struggle with DFARS compliance are not failing because they lack good intentions. They are failing because the requirements are genuinely broad and the gap between current state and required state is larger than expected.

Here are the most common pain points:

• Underestimating scope: CUI can exist across email, file shares, laptops, cloud storage, and third-party tools. Scoping your environment correctly before you start is harder than it sounds.
• No internal expertise: Fully meeting DFARS cybersecurity requirements spans IT infrastructure, security operations, HR policies, legal review, and physical security. Very few small contractors have staff across all of these areas.
• Deadline pressure: The DoD is requiring CMMC compliance by end of 2026 for most contracts, and DFARS obligations are already active in existing contracts. Many contractors are behind before they realize it.
• Documentation burden: An SSP for 110 controls is a substantial document. Writing it accurately, keeping it current, and linking it to actual evidence takes significant ongoing effort.
• Tool sprawl: Selecting, configuring, and integrating the right security tools to satisfy logging, endpoint protection, access control, and vulnerability management requirements is a project in itself.
• Subcontractor flow-down: If you use subcontractors who touch CUI, you are responsible for confirming they also meet DFARS requirements. Managing that process is frequently overlooked.

What Does It Take to Meet DFARS Cybersecurity Requirements?

Getting to DFARS compliance requires work across several distinct areas. Understanding what each one involves helps you plan realistically and avoid the gaps that derail assessments.

Documentation and Policy Development

Your SSP is the foundation of your DFARS compliance posture. It must document every one of the 110 requirements and describe exactly how your organization meets each one. You will also need supporting policies covering access control, incident response, media handling, and configuration management. BEMO creates 18 or more IT policies during implementation to support this documentation layer.

Technical Controls and Tooling

DFARS requires multi-factor authentication, audit logging, encrypted communications, endpoint protection, vulnerability scanning, and more. Each of these requires the right tools configured correctly. A Microsoft-native environment using M365, Entra ID, Intune, Defender, and Sentinel covers a significant portion of the technical requirements, but configuration matters as much as the tools themselves.

Ongoing Monitoring and Maintenance

Compliance is not a one-time project. You need continuous log monitoring, vulnerability patching, periodic access reviews, and policy updates as your environment changes. The 72-hour cyber incident reporting requirement means your monitoring function must be active at all times, not just during audit prep.

Staff Training and Awareness

DFARS requires documented security awareness training for all users who handle CUI. This includes initial training and periodic refreshers. Platforms like KnowBe4 automate delivery and tracking, but someone still needs to manage the program, review completion rates, and address gaps.

Auditor Coordination and Evidence Collection

If you are pursuing CMMC Level 2 alongside DFARS compliance, you will work with a C3PAO (Certified Third-Party Assessment Organization) to validate your controls. Even for DFARS alone, the DoD can request your SSP and POA&M at any time. Having clean, organized evidence ready before that request arrives is the difference between a smooth review and a painful scramble.

In-House vs Managed: Approaches to DFARS Compliance

There is no single right way to achieve DFARS compliance. The best approach depends on your internal resources, timeline, and budget. Here is an honest look at all three paths.

The DIY path gives you full control but requires significant internal capacity. A GRC platform accelerates documentation and evidence collection, but you still own all the implementation work and auditor coordination. A managed partner takes on the build, the tooling, and the ongoing operations, which is why many contractors with limited internal IT staff choose this route.

One important consideration: a GRC platform subscription does not make you compliant. It helps you organize and track compliance. The actual security controls still need to be implemented and maintained by someone with the right expertise.

Getting Started With DFARS Compliance

If you are starting from scratch or trying to close gaps in an existing program, here is a practical four-step path forward.

1. Book a GAP Assessment

A GAP assessment evaluates your current security posture against all 110 DFARS cybersecurity requirements and identifies exactly where you stand. This gives you a clear picture of what needs to be built, fixed, or documented before you can claim compliance.

2. Get Your Implementation Roadmap

Based on the GAP assessment, you receive a prioritized plan covering which controls to address first, what tools you need, what policies must be created, and what a realistic timeline looks like for your specific environment.

3. Deploy Controls

This is the hands-on phase: configuring your security stack, building your SSP and supporting policies, setting up logging and monitoring, and deploying security awareness training. For most organizations, this is the most resource-intensive part of the process.

4. Achieve and Maintain Compliance

Once controls are in place, ongoing compliance requires continuous monitoring, periodic reviews, staff training updates, and readiness for DoD requests or formal CMMC assessments. This phase never ends, which is why many contractors move to a managed compliance service after initial implementation.

Why Choose BEMO for DFARS Cybersecurity Compliance

The challenges covered in this article are real, and they compound quickly for small and mid-sized contractors who do not have a dedicated security team. BEMO was built specifically for this situation.

Here is what you get when you work with BEMO:

• A dedicated team assigned to your account: Customer Success Manager, Project Manager, Delivery Engineer, Security Engineer, SOC Analyst, IT Manager, Support Engineer, and virtual CISO. You are not buying software; you are getting people who own your outcome.
• Microsoft-native security stack: BEMO deploys and configures M365, Entra ID, Purview, Sentinel, Intune, and Defender to satisfy the technical requirements of DFARS and NIST SP 800-171.
• GRC automation with hands-on management: BEMO uses Drata as the GRC platform and provides compliance engineers who actively manage it. You are not left to figure out the platform on your own.
• Full auditor coordination: BEMO works directly with auditor partners including Sensiba, A-LIGN, and Johanson Group on your behalf, managing evidence collection and remediation cycles.
• 8-month implementation timeline with bi-weekly status meetings and a 72-hour SLA for remediation items.
• Cost advantage: Starting at approximately $4,800 per month versus $84,000 to $132,000 or more per year for a single in-house compliance hire, before factoring in three months of hiring time and three months of onboarding.
• Certified themselves: BEMO holds SOC 2 Type 2 and ISO 27001 certifications and is a Cyber AB Registered Practitioner Organization (RPO), meaning they meet the same standards they help clients achieve.
• 24/7 SOC: AI reviews 100,000 or more monthly logs with approximately 100 per month human-verified by BEMO's SOC team.

Ready to Meet DFARS Cybersecurity Requirements?

BEMO assigns a dedicated multi-role team to every client and owns the outcome of getting your organization compliant. Starting at approximately $4,800 per month, it is a more practical path than building the function in-house.

Book a meeting with BEMO to get started with a GAP assessment.

Frequently Asked Questions About DFARS Cybersecurity Requirements

What are the DFARS cybersecurity requirements?

DFARS cybersecurity requirements refer to the 110 security controls in NIST SP 800-171, made mandatory for DoD contractors through DFARS Clause 252.204-7012. Any contractor that processes, stores, or transmits CUI must implement these controls, maintain an SSP, and report cyber incidents to the DoD within 72 hours. The requirements span 14 control families covering everything from access control to incident response.

What is the difference between DFARS and CMMC?

DFARS is the contractual clause that requires you to meet NIST SP 800-171. CMMC is the formal assessment program the DoD uses to verify that contractors have actually implemented those requirements. For most contractors handling CUI, CMMC Level 2 covers the same 110 controls as DFARS but adds the requirement for a third-party assessment every three years. Many contractors are working toward both at the same time.

How long does it take to become DFARS compliant?

Realistic timelines vary based on your starting point. Organizations with little existing security infrastructure typically take 12 to 18 months on a DIY path. With a managed compliance partner, the initial implementation typically takes around 8 months, including documentation, technical controls, and staff training. The ongoing compliance program continues indefinitely after that.

What does a DFARS GAP assessment include?

A GAP assessment maps your current security environment against all 110 NIST SP 800-171 requirements and identifies which controls are fully met, partially met, or missing. It also reviews your existing documentation, such as any SSP or POA&M you may already have. The output is a prioritized list of gaps and a recommended remediation plan. This is the logical starting point before any implementation work begins.

How much does DFARS compliance cost?

Costs vary significantly depending on your approach. Building the function in-house requires at least one dedicated hire at $84,000 to $132,000 or more per year, plus tooling and audit fees. A GRC platform alone runs $10,000 to $30,000 per year but does not cover implementation or auditor coordination. A managed compliance partner like BEMO starts at approximately $4,800 per month and includes the full team, tooling, and ongoing management.

Why should I use a managed compliance partner for DFARS?

DFARS cybersecurity requirements span IT, security operations, HR, legal, and physical security. Most contractors do not have staff with expertise across all of these areas, and building that capacity internally takes time and money that many organizations do not have. A managed partner brings a pre-built team and proven process, which reduces timeline risk and lowers total cost compared to hiring internally. This is especially relevant given the DoD's push to require CMMC compliance by end of 2026.

What team does BEMO assign for DFARS compliance?

BEMO assigns a dedicated team to every client account. That team includes a Customer Success Manager, Project Manager, Delivery Engineer, Security Engineer, SOC Analyst, IT Manager, Support Engineer, and virtual CISO. Each role has a defined function in your compliance program, and the team operates under a 72-hour SLA for remediation items throughout the engagement.