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Controlled Unclassified Information (CUI) Under CMMC: What You Need to Know

April 14, 2025 · Advantage Technology · CMMC Compliance

Learn what Controlled Unclassified Information (CUI) is, why it matters under CMMC, and how defense contractors can properly secure it for full DoD compliance.

Controlled Unclassified Information (CUI) refers to sensitive information generated or owned by the Unites States government that doesn’t meet the criteria for classification but still requires protection against unauthorized access. Under the Department of Defense’s Cybersecurity Maturity Model Certification (CMMC), defense contractors must secure CUI to prevent exploitation by adversaries seeking vulnerabilities.

Having a clear understanding of CUI is necessary for defense contractors aiming to maintain compliance, protect valuable government information, and remain competitive in the evolving defense industry landscape.

Understanding Controlled Unclassified Information (CUI)

Business man, thinking and computer at desk in office for online research, reading email or report. Male entrepreneur person with internet connection for feedback, review and focus on project.Controlled Unclassified Information is government-generated or government-owned information that requires safeguarding measures but does not meet the criteria for classification as confidential, secret, or top-secret. Even though CUI lacks formal classification, it remains highly valuable to adversaries who target it as a potentially easier path to sensitive Department of Defense (DoD) operations and strategic information.

Classified information is tightly restricted and limited to specific personnel, but CUI is widely disseminated, managed, and used across all ranks and roles within the DoD. This extensive accessibility makes CUI particularly vulnerable, heightening the importance of its secure management.

Defense contractors need to recognize the diverse forms CUI takes, from procurement details and product research to trade secrets and technical data, since these are precisely the types of sensitive information frequently targeted. Protecting CUI effectively defends national security and preserves contractors’ ability to do business with the federal government.

CMMC’s Role in Protecting CUI

The Cybersecurity Maturity Model Certification is a structured, three-level cybersecurity framework developed by the DoD to protect both Federal Contract Information (FCI) and CUI.

Its primary purpose is to standardize cybersecurity practices among defense contractors and subcontractors, reducing the risk of breaches and unauthorized disclosures. Assessments conducted under the CMMC program verify compliance and help maintain consistent cybersecurity standards throughout defense supply chains. CMMC 2.0 consists of three distinct levels:

  • Level 1 (Foundational) requires contractors to perform an annual self-assessment covering 15 security requirements outlined by FAR clause 52.204-21, addressing the basic safeguarding of FCI.
  • Level 2 (Advanced) focuses on the thorough protection of CUI, involving the 110 NIST SP 800-171 requirements, evaluated through either self-assessment or third-party assessment by a certified assessor (C3PAO).
  • Level 3 (Expert) demands rigorous protection against advanced persistent threats, including additional NIST SP 800-172 requirements, assessed every three years by the Defense Contract Management Agency’s specialized cybersecurity assessment team (DIBCAC).

The Two Main Types of CUI

Software developer working with programming code on dark screen. Professional programmer analyzing data in night office. Technology and coding concept with copy spaceControlled Unclassified Information is categorized into two main types of data: Basic and Specified.

  • Basic CUI represents sensitive government information that requires protection but does not have distinct or explicitly defined handling protocols beyond standard safeguarding measures. The majority of CUI typically falls into this category.
  • Specified CUI includes sensitive information that, due to its nature or governing regulations, mandates specific protective measures or handling instructions.

Clearly understanding these two subsets is essential for businesses working with the DoD. The accurate identification and correct handling of both Basic and Specified CUI help organizations maintain compliance and effectively mitigate potential cybersecurity risks.

Essential Questions to Identify and Secure CUI

Effectively managing Controlled Unclassified Information involves accurately identifying and categorizing this sensitive information within your organization. Having a firm understanding of exactly what qualifies as CUI within your company’s operations is a foundational step, as any misclassification or oversight can create compliance gaps.

Equally important is pinpointing precisely where your CUI resides, including locations where it’s stored, systems in which it’s processed, and channels through which it’s disseminated. Maintaining a highly detailed inventory cuts down on vulnerabilities because it highlights specific areas requiring stronger protections. Organizations must also assess if current protective measures are sufficient, clearly documented, and regularly reviewed.

Continuous documentation and assessments offer evidence that the company meets the cybersecurity standards outlined by the DoD, particularly within CMMC requirements and compliance efforts. Asking these questions routinely allows organizations to strengthen their security posture, reducing exposure to cyber threats and staying aligned with regulatory obligations.

Best Practices for Ensuring CUI Protection

Portrait of a smiling young Asian businessman sitting at his desk in an office going over paperwork and using a laptopEffectively protecting CUI involves adopting structured practices to operations and having clear processes in place. Implement the following best practices to help your organization remain compliant, reduce vulnerabilities, and improve overall cybersecurity:

  • Conduct Regular Assessments: Perform regular inventories and clearly identify all CUI in your organization. Document each type clearly, specifying locations where CUI is stored, processed, and shared.
  • Implement Proper Controls: Leverage specialized solutions designed explicitly for safeguarding CUI. For defense contractors, Microsoft 365 Government GCC High is recommended, as standard Microsoft 365 Commercial and GCC do not meet the requirements for protecting sensitive DoD information.
  • Document Everything: Make sure to maintain thorough records of security policies, procedures, assessments, and corrective actions. Having detailed documentation in place helps verify compliance during CMMC audits or third-party evaluations.
  • Educate Your Staff: Provide ongoing training to all of your employees to make sure that they recognize, handle, and report incidents involving CUI promptly and appropriately. A high degree of staff awareness significantly enhances organizational security.
  • Integrate Compliance into Daily Operations: Incorporate cybersecurity measures directly into everyday operational processes. A systematic approach helps maintain consistent compliance and promptly identifies potential issues before they escalate.
  • Work With Experts: Engage qualified CMMC Registered Practitioners who understand complex compliance requirements. This should include consultation and support for regulatory frameworks such as GDPR, HIPAA, SOC2, CMMC, and PCI DSS.

Strengthen Your CUI Protection with Advantage Technology

Securing Controlled Unclassified Information is a priority for defense contractors to maintain compliance, avoid cybersecurity breaches, and protect their competitive standing. Proactive measures, including thorough data identification, meticulous documentation, specialized technology solutions, and regular training, are essential to managing CUI effectively.

Advantage Technology stands as a trusted advisor uniquely positioned with specialized cybersecurity expertise, deep regional understanding, and in-depth managed services. Our team offers personalized consultations and customized solutions that precisely address your organization’s requirements and current compliance obligations.

Advantage Technology will help you secure your organization’s CUI effectively and comply confidently with CMMC. Our experienced cybersecurity professionals are standing by and are available to support your needs. Connect today for personalized guidance that addresses your firm’s distinct needs and requirements. Call toll-free at 1-(866)-497-8060 or schedule your consultation online.

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