In the world of government contracting, particularly with the Department of Defense (DoD), the term CUI — or Controlled Unclassified Information — is one you’ll encounter frequently.
But what exactly is CUI, and why is it so important?
Whether you're prepping for CMMC certification, managing contracts in the Defense Industrial Base (DIB), or just trying to make sense of acronyms like DIBCAC, C3PAO, DCMA, this video with Tony Bai of RISCPoint is your go-to guide for understanding CUI at a foundational level:
CUI stands for Controlled Unclassified Information. It refers to any information the DoD provides to a contractor that is not classified but still requires protection under specific laws or regulations.
Unlike classified information, CUI is not meant for public release. If you’re familiar with older DoD terms like FOUO (For Official Use Only), much of that information now falls under the CUI umbrella as part of the DoD’s updated CUI program.
This is the general category of CUI that requires standard protection. It includes information that must be safeguarded but doesn’t have additional handling restrictions.
These are specific categories of CUI that come with special handling instructions, imposing extra restrictions.
For example, information marked “No Foreign” (meaning U.S. eyes only) is a type of CUI with special handling requirements.
To make sense of CUI, let’s look at some real-world examples:
1- Personally Identifiable Information (PII):
This includes data like names, Social Security numbers, or other identifiers protected under the Privacy Act of 1974.
PII is a type of CUI because it requires safeguarding to prevent unauthorized disclosure.
2- Protected Health Information (PHI):
PHI, governed by HIPAA, includes medical records or other health-related data.
Like PII, it’s considered CUI due to legal protections.
3- Sensitive Technical Information:
Information about certain materials or processes (example: instructions for handling hazardous substances like ammonium nitrate) may also be designated as CUI if it’s subject to regulatory restrictions.
The DoD maintains a comprehensive list of CUI categories on its website, dodcui.mil, which outlines each type and its specific requirements. Contractors working with the DoD should refer to this resource to understand what qualifies as CUI.
When a company wins a DoD contract, the DoD is required to notify the contractor about any CUI involved. This happens during contract award or negotiations, where the DoD specifies what information must be treated as CUI.
From there, the contractor is responsible for protecting that information in accordance with the contract’s terms.
If the contractor works with subcontractors, they may need to “flow down” CUI requirements, meaning they share relevant CUI with subcontractors and make sure they also comply with protection protocols.
This traceability ensures that everyone handling CUI is accountable for its security.
Enforcement of CUI requirements falls to the Contracting Officer’s Representative (COR) assigned to each contract. The COR ensures that contractors adhere to all contract requirements, including those related to CUI protection.
The Defense Industrial Base Cybersecurity Assessment Center (DIBCAC), part of the Defense Contract Management Agency (DCMA), also plays a role in verifying compliance.
Before the introduction of the Cybersecurity Maturity Model Certification (CMMC), DIBCAC conducted assessments (low, medium, or high confidence) to validate that contractors were meeting security standards, like those outlined in NIST SP 800-171.
With CMMC, third-party assessors (C3PAOs) now perform similar high-confidence assessments, certifying compliance through an ISO-aligned framework.
→ Learn how to simplify & automate your CMMC certification
Understanding and properly handling CUI is critical for DoD contractors. Failure to protect CUI can lead to legal, financial, and reputational consequences.
Worse, CUI is often sensitive information that, if mishandled, could harm individuals (e.g., through identity theft) or national security (e.g., by exposing sensitive processes).
The key is for contractors to stay informed.
Visit dodcui.mil to review CUI categories, work closely with your COR during contract execution, and ensure your cybersecurity practices align with DoD requirements, such as those in CMMC.
CUI may seem complicated with so many categories and regulations. But at its core, it’s about protecting sensitive information that the DoD entrusts to its contractors.
For more details on CUI, check out dodcui.mil or consult with your DoD contracting officer. Staying compliant isn’t just a requirement — it’s a critical part of doing business with the DoD.
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