FAR 52.204-21

Basic Safeguards for Covered Contractor Information Systems

Requires contractors to implement NIST SP 800-171 security controls for unclassified controlled technical information.

Applicability: Required in solicitations that expect to result in a contract involving unclassified controlled technical information.

Key Requirements

1

Implement NIST SP 800-171 security controls or equivalent cybersecurity framework

2

Apply controls to information systems and associated information both internal and external to the facility

3

Comply with DoD Defense Counterintelligence and Security Agency requirements if dealing with DCTI

4

Flow down requirements to subcontractors

Common Issues & Pitfalls

Proposing without adequate security infrastructure in place

Underestimating implementation costs of NIST 800-171 compliance

Not addressing cybersecurity in the technical proposal when clause applies

Failing to include security requirements in subcontract language

Contractor Guidance for Your Bid

If your RFP includes this clause, budget significant resources for cybersecurity infrastructure. NIST 800-171 compliance is not optional and must be demonstrated before contract award. Partner with a cybersecurity firm if you lack internal expertise. This is a common area of bid failures.

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