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ARTICLE · 21 AUGUST 2024

DFARS 7021 Clause 2.0: DoD Releases Proposed Rule Updating CMMC Clause

Crowell & Moring LLP
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The Clause will require every defense contractor that handles Federal Contract Information or Controlled Unclassified Information to assess and certify compliance with select CMMC security requirements.

United StatesTechnology
Michael G. Gruden, CIPP/G
Michael G. Gruden, CIPP/G
Megan L. Wolf
Megan L. Wolf
Maida Oringher Lerner
Maida Oringher Lerner
Jacob Harrison
Jacob Harrison
Alexis Ward
Alexis Ward

On August 15, 2024, the Department of Defense ("DoD") released the long-awaited proposed rule ("August 2024 Proposed Rule"), updating Defense Federal Acquisition Regulation Supplement ("DFARS") Clause 252.204-7021 (the "7021 Clause"), which, when final, will initiate the phased implementation of Cybersecurity Maturity Model Certification 2.0 ("CMMC") requirements into DoD contracts. The Clause will require every defense contractor that handles Federal Contract Information ("FCI") or Controlled Unclassified Information ("CUI") to assess and certify compliance with select CMMC security requirements. The August 2024 Proposed Rule introduces several distinct changes to the 7021 Clause published by DoD in January 2023, including:

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