1. Home
  2. |Insights
  3. |“Miss Me with Rev. 3,” Says DoD: DoD Issues Class Deviation Linking DFARS 7012 to NIST SP 800-171, Rev. 2

“Miss Me with Rev. 3,” Says DoD: DoD Issues Class Deviation Linking DFARS 7012 to NIST SP 800-171, Rev. 2

Client Alert | 1 min read | 05.03.24

On May 2, 2024, the Department of Defense (DoD) issued a class deviation to DFARS 252.204-7012,  Safeguarding Covered Defense Information and Cyber Incident Reporting (DFARS 7012), specifying that contractors subject to the clause must comply with NIST SP 800-171, Revision 2.  The deviation (labeled Deviation 2024-O0013) will delay the incorporation of NIST SP 800-171, Revision 3—which is set to be finalized in the next few weeks—into DFARS 7012.

The standard version of DFARS 7012 does not identify a specific NIST SP 800-171 Revision number, and has been interpreted by DoD as requiring compliance with NIST SP 800-171’s most current Revision.  But with Revision 3’s final release looming, DoD has directed contracting officers to use Deviation 2024-O0013 in place of the standard clause moving forward, linking DFARS 7012 to Revision 2 for the time being.

In a press release announcing the deviation, DoD stated that the “intent of this class deviation is to provide industry time for a more deliberate transition upon the forthcoming release of [NIST SP 800-171, Revision 3].” 

It is unclear when DoD plans to adopt Revision 3.  However, contractors should take advantage of DoD’s reprieve to get familiar with Revision 3, as the DoD has previously indicated that it intends to incorporate NIST SP 800-171’s newest revision into both DFARS 7012 and its forthcoming Cyber Maturity Model Certification (CMMC) program.

Contacts

Insights

Client Alert | 5 min read | 06.05.26

Grants Overhauled: What the Proposed Rewrite of 2 CFR Part 200 Means for Federal Financial Assistance Award Recipients

The Office of Management and Budget issued on May 29, 2026 a Proposed Rule that would significantly revise the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) at 2 C.F.R. Part 200, potentially impacting the full lifecycle of federal grants, cooperative agreements and other forms of financial assistance, from pre-award merit review through post-award administration and termination. These proposed changes are designed to implement the President’s policy priorities, executive actions related to diversity, equity and inclusion (DEI) activities, and Executive Order No. 14332, Improving Oversight of Federal Grantmaking (EO 14332)....

View All Insights