Security. Compliance. Strategy. | Justin Johnson

DFARS 7012 and CMMC

DFARS 7012 and CMMC - How do these relate?

DFARS 7012 and CMMC, do you know the difference? If you’re a contractor working with the Department of Defense, understanding this distinction is crucial—not only for compliance but for securing your place in the defense supply chain.

DFARS clause 252.204-7012 has been around since 2017, introduced as a response to increasing cyber threats targeting sensitive defense information. It requires contractors to protect Controlled Unclassified Information (CUI) using cybersecurity controls dictated by NIST SP 800-171. This means implementing technical safeguards, policies, and procedures to keep sensitive information safe. However, under DFARS 7012, contractors generally self-assess and attest to their compliance, which leaves some uncertainty about the robustness of cybersecurity protections across all contractors.

The CMMC

Enter the Cybersecurity Maturity Model Certification, or CMMC. Launched by the DoD as a natural next step, CMMC builds on the same NIST 800-171 controls but adds a mandatory certification process. Contractors must now undergo rigorous third-party assessments by accredited organizations before they can qualify for DoD contracts. This is no small change—it transforms compliance from a paperwork exercise into a validated assurance that contractors meet the security bar.

CMMC also introduces maturity levels, reflecting a tailored approach based on the sensitivity of the information handled. Level 2, which closely mirrors DFARS 7012’s NIST requirements, is the foundational threshold for contractors dealing with CUI. Higher levels add controls to protect more sensitive data, responding to evolving cyber threats.

The Why?

Why does this matter? The defense industrial base is a tempting target for cyber adversaries seeking to steal valuable information. By linking DFARS 7012’s technical requirements with CMMC’s enforceable certification, the DoD is raising the cybersecurity standard industry-wide, helping to secure critical national security information from potential breaches.

For contractors, this means achieving compliance is not optional. Failing to meet these standards or to obtain the necessary certifications could mean losing contract opportunities and risking reputational damage. On the flip side, investing in cybersecurity today builds trust with the DoD, reduces risk, and positions companies for long-term success.

The What and the How…

In short, DFARS 7012 lays out the “what” of cybersecurity requirements, and CMMC provides the “how” of verified compliance. Together, they offer a comprehensive framework that strengthens the defense supply chain’s resilience against cyber threats—an investment in both security and business continuity.

Understanding and navigating this evolving landscape is essential for every defense contractor. Embracing these requirements proactively can turn regulatory burden into a competitive advantage.