What is CUI
For organizations operating within or entering the Defense Industrial Base (DIB), understanding the mandate to protect Controlled Unclassified Information (CUI) is not just a compliance issue—it is a prerequisite for doing business with the federal government under the Cybersecurity Maturity Model Certification (CMMC) framework.
CUI represents sensitive federal data that, while not classified, still requires safeguarding. Mishandling CUI can lead to regulatory action, contract loss, security breaches, and can put reputations and security clearances at risk.
CUI is sensitive federal data that requires safeguarding because its compromise could pose a direct threat to national security, intellectual property, or operational integrity. It has replaced older, often inconsistent, labels like FOUO (For Official Use Only) or SBU (Sensitive But Unclassified).
You may be handling CUI without realizing it if your business:
• Works on DoD or other federal contracts.
• Manages PII (Personally Identifiable Information) or health records under HIPAA.
• Develops or shares proprietary data with the government, such as schematics, R&D, or technical drawings.
• Engages with subcontractors on federal work.
It is important to differentiate CUI from Federal Contract Information (FCI):
• FCI is any information created for or by the government that is not intended for public release.
• CUI is a subset of FCI that requires additional safeguarding.
• The bottom line is: All CUI is FCI, but not all FCI is CUI.
CUI is categorized into two main types, which dictate the level of protection required:
1. CUI Basic: This classification requires organizations to implement the foundational cybersecurity framework, NIST SP 800-171, which consists of 110 controls. This is the baseline for all federal contractors handling CUI.
2. CUI Specified: This type of CUI requires additional protections defined by specific laws or policies, often including compliance with DFARS 7012, in addition to NIST 800-171. CUI Specified demands elevated controls and close legal alignment.
The CMMC framework ensures contractors protect FCI and CUI. If your organization processes, stores, or transmits CUI, you will typically need at least CMMC Level 2 compliance.
CMMC Level 2 demands the full implementation of all 110 security controls from NIST SP 800-171 Rev 2. To meet this requirement, organizations must prepare for a third-party assessment conducted by an accredited Certified Third-Party Assessment Organization (C3PAO).
Protecting CUI involves mandatory organizational responsibilities:
• Implement NIST SP 800-171.
• CUI Training: Mandatory CUI training is required annually for DoD contractors.
• Asset Inventory: Organizations must maintain a CUI Asset Inventory to track all systems that process or store CUI.
• Marking and Handling: Organizations must stay current on how CUI is marked, disseminated, decontrolled, and destroyed. For example, any media storing CUI (like USBs or drives) must be labeled appropriately.
• Subcontractor Compliance: Prime contractors are responsible for ensuring that their subcontractors and suppliers also comply with CUI requirements.
Executive Takeaway: Handling CUI is complex, but non-compliance may result in legal penalties or the loss of federal contracts. Proactive planning, focused on implementing NIST SP 800-171 and preparing for the Level 2 audit, is essential to remain competitive and trustworthy within the DIB.
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Think of CUI as valuable blueprints for a sensitive project. It’s not classified (a state secret), but if those blueprints fall into the wrong hands, national security or intellectual property is severely damaged. CMMC Level 2 is the robust security system—the multi-layered vault, alarm, and security guards—required to protect those blueprints.