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ARTICLE · 16 JULY 2026

FAR Council Proposes Revised CUI Safeguarding And Incident-Reporting Framework, While DoW Pauses CMMC Implementation

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The Federal Acquisition Regulatory Council has proposed sweeping changes that would extend cybersecurity safeguarding requirements for Controlled Unclassified Information beyond defense contractors to civilian-agency contractors for the first time. As thousands of federal vendors face new compliance obligations under NIST SP 800-171 Revision 3, the Department of War simultaneously suspended its third-party CMMC certification program, creating uncertainty about the future enforcement landscape.

United StatesGovernment, Public Sector
Rajesh De
Rajesh De
Ryan Frazee
Ryan Frazee
Adam S. Hickey
Adam S. Hickey
John Prairie
John Prairie
Hadassah G. Diament
Hadassah G. Diament
Tanner Wilburn
Tanner Wilburn
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On June 23, 2026, the Federal Acquisition Regulatory Council (FAR Council) published a Proposed Rule that would establish a government-wide framework for safeguarding Controlled Unclassified Information (CUI) and reporting CUI incidents. These obligations traditionally have applied to defense contractors, but would now impact civilian-agency contractors as well. The proposal is one of a series of rules the FAR Council is issuing to implement Executive Order 14275, Restoring Common Sense to Federal Procurement, and the broader “Revolutionary FAR Overhaul.” Comments are due July 23, 2026.

Meanwhile, as discussed at the end of this Legal Update, on July 13, 2026, the Department of War (DoW) announced a suspension of the implementation of the Cybersecurity Maturity Model Certification (CMMC) program. Although defense contractors remain obligated to handle CUI and report incidents under DFARS clause 252.204-7012, the requirement to obtain a third-party assessment of their compliance

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This Mayer Brown article provides information and comments on legal issues and developments of interest. The foregoing is not a comprehensive treatment of the subject matter covered and is not intended to provide legal advice. Readers should seek specific legal advice before taking any action with respect to the matters discussed herein.

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