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DoD's New Year's Gift: More Time to Meet Cyber Safeguarding Requirements

Client Alert | less than 1 min read | 12.30.15

On December 30, DoD issued an interim rule amending the DFARS Safeguarding Rule in several respects, including to provide contractors up to December 31, 2017, to comply with the security control requirements identified in DFARS 252.204-7012, Safeguarding Covered Defense Information and Cyber Incident Reporting, and detailed in NIST Special Publication 800-171, Protecting Controlled Unclassified Information in Nonfederal Information Systems and Organizations. Despite the additional time to comply, within 30 days of contract award, contractors must still notify the DoD Chief Information Officer of any NIST SP 800-171 security requirements not yet implemented.

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Client Alert | 2 min read | 07.15.26

CMMC Phase II Suspension Requires Reconsideration of Such Requirements in Solicitations

As discussed in more detail here, the U.S. Department of War (DoW) recently issued a memorandum (Memo 26-P-1023, dated July 13, 2026) directing the immediate suspension of Cybersecurity Maturity Model Certification (CMMC) Phase II requirements (Level I and II self assessments are still permitted). Significantly, the memo directs that “all pending and future CMMC implementation milestones across DoW solicitations and contracts are held in abeyance until further notice.” Moreover, the DoW issued a memorandum on implementing these requirements (available here), directing agencies to issue amendments removing CMMC Level 2 and 3 requirements from active solicitations “as soon as practicable.” Contractors should monitor the government’s compliance with this requirement and should be prepared, if needed, to file a bid protest to protect their rights....

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