DoD maintains revision 2 CUI baseline despite new NIST standards

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The Department of Defense has issued a class deviation to keep NIST SP 800-171 Revision 2 as the applicable baseline for DFARS 252.204-7012 and CMMC Level 2. This decision remains in effect until acquisition regulations are updated to reflect the new NIST SP 800-171 Revision 3 framework. Contractors and procurement teams must verify the specific cybersecurity baseline stated in each solicitation before adjusting compliance plans. The deviation ensures that publication of Revision 3 does not automatically change requirements for existing defense contracts.

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