Clauses · DFARS · Cybersecurity
DFARS 252.204-7021 Contractor Compliance With the Cybersecurity Maturity Model Certification Level Requirements
Does the regulation require it to flow down?
Yes
Whenever the sub processes/stores/transmits FCI or CUI; sub's level per 32 CFR 170.23 (FCI only → L1 self; CUI → minimum L2)
- Form
- substance (excluding (e)(1))
- Reaches
- all tiers
Checked against acquisition.gov on 2026-08-09 · edition NOV 2025 · base v0.9.3 Read the text ↗
What it makes you produce
6 items for your checklist, slowest first.
Something somebody else has to issue you2
The same day if the issuer is one of your own suppliers, months if it is an assessor or an underwriter.
- 252.204-7021(d)(1)(i)
An assessment by an accredited third-party assessment organization
Owed when the value written at (d)(1)(i) is CMMC Level 2 (C3PAO). At CMMC Level 1 (Self) or Level 2 (Self) no outside assessor is owed, and Level 3 (DIBCAC) is assessed by the Government
- 252.204-7021(d)(4) and (f)(2)
An affirmation of continuous compliance from each of your own suppliers, and a current certificate or status at the level their work calls for
Owed when you award a subcontract of your own that will process, store or transmit the information — both are due before that award rather than after it
A state you have to be in, in a government system3
The record has to be posted before the prime can see it, and posting is not the same day as being ready.
- 252.204-7021(d)(1)(i)
A current CMMC status at the level written into the order, or higher, held for the life of the work
Owed when for every information system used on the work that processes, stores or transmits the information — the level is the value the contracting officer wrote into the blank at (d)(1)(i)
- 252.204-7021(d)(3)
An affirmation of continuous compliance, completed each year in the Supplier Performance Risk System by a named affirming official
Owed when for each CMMC identifier covering a system used on the work, and it has to be current rather than merely on file
- 252.204-7021(e)(2)
The results of a current self-assessment entered in that same system
Owed when each CMMC identifier not covered by a C3PAO assessment or a DIBCAC assessment
Something you write
Days to weeks, and nobody outside your company has to agree to it.
- 252.204-7021(d)(5)
A plan of action and milestones carried through to a close
Owed when the status on record is Conditional rather than Final
When it is used
Contracts (including commercial, except pure COTS) where contractor systems process FCI or CUI, when the CO inserts the required level. Phase 1 (L1/L2 self-assessments) in effect since 2025-11-10.
Read closely
32 CFR 170.23 sets the level a subcontract carries, and it is not always the level of the contract above it. Paragraph (e)(1), the identifiers submitted to the contracting officer, is expressly excluded from what (f)(1) flows down, so that one binds the tier holding the prime contract rather than a supplier under it.
The 11 templates that name it, with the line
Source: acquisition.gov, DFARS 252.204-7021; DoD CIO memo 2026-07-13. Codified text read at DFARS Change 5/7/2026, prescribed at 204.7504(a) with designation (NOV 2025). RFO class deviation 2026-O0025 (DFARS part 240, effective 2026-02-01) prints the same designation and prescribes it at 240.371-5(a). The memo itself, Removing Barriers to Defense Industrial Base Expansion, and its Attachment 1 were read at dowcio.war.gov: the memo is signed by Kirsten A. Davies over a signature block that carries no date, and the date it does carry, 2026-07-13, is the open-publication clearance stamp on its face, which is also the announcement date the DoW CIO CMMC page states. Codified text, deviation and memo all read against their primary sources (verified 2026-08-09)
This is research, not legal advice. It states what the regulation says about this clause and cites the paragraph behind it. It does not rule on your order, and it does not rule on whether a prime's markings are correct.