1. Home
  2. |Insights
  3. |DCMA Revises Cyber Supply Chain Review: Updated Guidebook Modifies Audit Standards

DCMA Revises Cyber Supply Chain Review: Updated Guidebook Modifies Audit Standards

Client Alert | 1 min read | 07.16.19

As anticipated, the Defense Contract Management Agency (DCMA) revised its Contractor Purchasing System Review (CPSR) Guidebook as of June 14, 2019, with the most significant updates to Appendix 24, Supply Chain Management Process, to further address supply chain compliance with DFARS 252.204-7012. As we previously noted, the CPSR Guidebook was revised earlier this year to address DoD guidance related to management and oversight of the supply chain in connection with DFARS 252.204-7012.

While much of the CPSR review criteria remain the same, noteworthy revisions include:

  • Asking contractors to “show how they have determined” that their subcontractors have an adequate information system that can handle Covered Defense Information, versus the prior guidance to ask contractors to “validate” the adequacy of subcontractor systems.
  • Broadening supply chain requirements by applying the Guidebook’s language to “subcontractors,” rather than just “first tier suppliers” as in the prior version.
  • Clarifying that the CPSR review is focused only on the protection of “Covered Defense Information” and not “Controlled Unclassified Information” more broadly.

Contacts

Insights

Client Alert | 13 min read | 06.12.26

EU Cyber Resilience Act Countdown: 11 September 2026 Incident/Vulnerability Reporting Deadline Less Than 100 Days Away

The EU Cyber Resilience Act (CRA) is an EU product cybersecurity law for connected products (formally, “products with digital elements” under the CRA) commercialized in the EU; it entered into force on 10 December 2024, with direct application across the EU. Full application begins 11 December 2027, but one of its most operationally demanding provisions takes effect in just under 100 days, on 11 September 2026: the mandatory vulnerability and incident reporting under Article 14 CRA....