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Government agencies can reduce contractor security risk by managing the relationship from acquisition through offboarding: identify what contractors and their suppliers can access, make tailored safeguards enforceable in the contract, limit access, verify performance with evidence, and monitor changes over time. The applicable requirements depend on the information, system, agency policy, and contract; no single clause covers every engagement.
1. Map what the contractor will handle
Before setting requirements, document the people, systems, services, data flows, subcontractors, and upstream suppliers involved. Identify whether the work touches Federal contract information (FCI), controlled unclassified information (CUI), personally identifiable information, classified information, or a system operated on the government’s behalf. These categories can trigger different safeguards, so do not assume one clause or baseline applies to all of them.
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Prioritize providers and assets by mission importance and the sensitivity of the information or access involved. CISA’s FY 2025 Inspector General FISMA Reporting Metrics treat identification and prioritization of external providers, awareness of upstream suppliers, and integration with acquisition as elements of agency supply-chain risk-management maturity. These are governance guidance, not a substitute for binding requirements. CISA FY 2025 Inspector General FISMA Reporting Metrics
2. Set requirements before award
Have the program office, contracting officer, security team, privacy officials, data owners, and counsel translate the identified risks into requirements that are specific enough to enforce and verify. CISA identifies contractual agreements and procurement methods for confirming contractor performance as core supply-chain practices.
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Depending on the service and applicable rules, the contract may need to specify:
- Which users, roles, devices, and functions are permitted, and how access is approved and reviewed.
- Authentication requirements and restrictions on external connections or devices.
- Incident notification, cooperation, and evidence-preservation expectations.
- How vulnerabilities and other findings are reported, prioritized, and corrected.
- What assessment evidence the contractor must provide, and when.
- Subcontractor obligations and notice of material supplier or service changes.
- Data handling, retention, return, and media sanitization or destruction at closeout.
- Resilience requirements appropriate to the service’s mission role.
These are topics to tailor to the engagement, not a claim that every item appears in a particular FAR clause. State requirements in measurable terms where possible: identify the evidence, responsible party, deadline, and process for correcting a gap.
Apply the federal baseline that fits
FAR 52.204-21, Basic Safeguarding of Covered Contractor Information Systems, applies to covered contractor information systems that process, store, or transmit FCI. The clause defines FCI as non-public information provided by or generated for the government under a contract, excluding public information and simple transactional information. FAR 4.1903 directs contracting officers to insert the clause when a contractor or subcontractor may have FCI in its system. FAR 4.1903, Contract clause
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The clause establishes minimum safeguards, including access limits, user and device identification and authentication, controls on external system connections, physical access protections, boundary protections, flaw correction, malware protection, and scanning. It expressly does not displace other agency or federal safeguarding requirements, including requirements that may apply to CUI. Confirm the specific contract and applicable agency rules rather than treating this baseline as a complete security program. FAR 52.204-21, Basic Safeguarding of Covered Contractor Information Systems
3. Limit access and exposure
Give contractor personnel only the access needed for their assigned work, and define who approves it, how it is reviewed, and how it is removed when duties or contracts change. Restrict permitted functions as well as accounts; control connections to external systems; and apply physical access and visitor safeguards where relevant. These measures align with the access and protection requirements in FAR 52.204-21 when that clause applies.
The clause states: “Limit information system access to authorized users, processes acting on behalf of authorized users, or devices (including other information systems).” — U.S. Federal Acquisition Regulation, FAR 52.204-21(b)(1)(i).
4. Make subcontractor coverage visible
Identify subcontractors and other providers that handle agency information or support the service. FAR 52.204-21 requires the substance of its clause in qualifying subcontracts when the clause’s FCI conditions apply. For other data and services, determine the right flow-down terms from the contract and applicable rules rather than assuming the FCI clause alone is sufficient.
Require the prime contractor to identify relevant suppliers and report material changes when appropriate. CISA’s maturity metrics emphasize visibility into upstream suppliers and awareness of supplier changes; those practices help agencies understand when a service’s risk profile has shifted.
5. Verify performance with relevant evidence
A questionnaire or policy statement can help establish what a contractor says it does, but it does not by itself demonstrate that safeguards are operating. CISA’s FY 2025 metrics identify audits, test results, software-producer self-attestation, and other evaluations as possible assurance evidence. Choose evidence in proportion to mission criticality, information sensitivity, access scope, and the consequences of failure.
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For each material gap, record the evidence reviewed, the finding, the remediation owner, and the expected follow-up. Use service-level or other qualitative and quantitative performance measures when they provide meaningful assurance. Revisit evidence when the service, supplier, threat, or applicable agency requirement changes.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.6. Monitor the relationship and close it out
Feed contractor and supplier risk into ongoing monitoring. Track incidents, assessment findings, exceptions, access activity, upstream supplier changes, and corrective actions. Prioritize follow-up according to mission and information risk rather than treating every provider identically.
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At transition or termination, follow the contract and applicable agency policy to remove accounts and credentials, recover agency assets, and address information return, retention, or disposal. FAR 52.204-21 specifically requires media containing FCI to be sanitized or destroyed before disposal or reuse when the clause applies; broader closeout duties must be established through the applicable contract and rules.
Keep requirements, guidance, and jurisdiction distinct
FAR 52.204-21 is a federal minimum baseline for its defined scope, not a universal checklist for all contractor work. CISA’s FY 2025 Inspector General FISMA metrics are an agency maturity framework that can help structure governance and evidence, but they are not a replacement for statutes, regulations, binding directives, contract clauses, or agency policy. The cited FAR provisions are federal; state and local requirements vary by jurisdiction. For classified information or other specialized work, contracting and security officials should determine the applicable requirements.
CISA lists its FY 2025 Inspector General FISMA Metrics Evaluation Guide and NIST SP 800-161 Rev. 1, Cybersecurity Supply Chain Risk Management Practices for Systems and Organizations, as supplemental resources for understanding the maturity framework and supply-chain risk management.
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