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FAR & DFARS: Procurement Power · September 28 · 7 min

Federal Cyber Rules Are Splitting in Two

This episode breaks down the latest federal cybersecurity rule changes for contractors, from the shift to NIST SP 800-171 Revision 3 in civilian contracts to CMMC Level 2’s continued use of Revision 2 in defense work. It also covers the end of basic assessments, new breach reporting rules, key subcontractor flowdown issues, and the new form agencies must use to define CUI scope before demanding costly controls. Show Notes [PDF] Class Deviation 2026-O0025, “Revolutionary Federal Acquisition ...: https://www.acq.osd.mil/dpap/dars/classdev/DFARS_RFO/Part-240/2026-O0025_TAB_A_Deviation_Memo_DFARS_240.pdf

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This episode breaks down the latest federal cybersecurity rule changes for contractors, from the shift to NIST SP 800-171 Revision 3 in civilian contracts to CMMC Level 2’s continued use of Revision 2 in defense work. It also covers the end of basic assessments, new breach reporting rules, key subcontractor flowdown issues, and the new form agencies must use to define CUI scope before demanding costly controls.

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