Uncontrolled Information: DoD Audit Finds Contractor Lapses in Protecting Controlled Unclassified Information
Client Alert | 1 min read | 08.02.19
The Department of Defense Inspector General has released a much-anticipated audit report regarding the protection of Controlled Unclassified Information (CUI) on contractor networks. Begun last summer at the Defense Secretary’s request, the audits found that contractors are not consistently implementing cybersecurity standard NIST SP 800-171, despite being required to do so under DFARS 252.204-7012. The report calls particular attention to common shortcomings regarding multifactor authentication, strong passwords, vulnerability management, and removable media, among others.
The report recommends that DoD:
- Verify that contractors are identifying, responding to, and reporting cyber incidents involving CUI;
- Assess contractors’ ability to protect CUI as part of the solicitation process; and
- Validate, at least annually, that contractors are complying with their contractual cybersecurity requirements.
These recommendations are consistent with recent DoD efforts to establish a “Cybersecurity Maturity Model Certification” that would require contractors to be certified compliant with contractually-specified cybersecurity requirements to be eligible for award.
Contacts

Partner and Crowell Global Advisors Senior Director
- Washington, D.C.
- D | +1.202.624.2698
- Washington, D.C. (CGA)
- D | +1 202.624.2500
Insights
Client Alert | 2 min read | 07.24.26
GAO Finds That Challenge to Agency’s Failure to Comply With DFARS Requirement Comes Too Late
GAO’s recent dismissal of the protest in Tyonek Technical Innovations, LLC, B-424364, B-424364.2, June 30, 2026, carries an important lesson for government contractors: if you believe solicitation terms conflict with a statute or regulation, you must raise that challenge before proposals are due—not during discussions or afterwards.
Client Alert | 3 min read | 07.23.26
Client Alert | 3 min read | 07.23.26
Second Circuit Affirms Preliminary Injunction Against Nielsen in Constructive Tying Case
Client Alert | 4 min read | 07.22.26
