DFARS Compliance Checklist for Electronics Design Teams
The Defense Federal Acquisition Regulation Supplement (DFARS) is a set of regulations developed and used by the U.S. Department of Defense (DoD) to govern the acquisition of goods and services; the regulations are designed to make sure that the DoD procures items and services in a way that promotes national security and supports defense objectives. And so, if your company, regardless of industry, has any involvement in supplying the department, you must abide by DFARS.
Why Is DFARS Important for Electronics Design Teams?
It should come as no surprise that, in a world where dependence on technology is proliferating, electronic design teams that work on DoD contracts must especially stick to the rules. Non-compliance can lead to severe consequences, such as contract termination, fines, and reputational damage; with that in mind, it's of the utmost importance that your teams understand and implement DFARS requirements when designing and developing new boards to protect sensitive information, mitigate risk, and maintain a strong relationship with the DoD.
Across the following two sections, you will find two tables that serve as a checklist for considerations that your teams should be ticking when preparing electronics for the DoD.
Key DFARS Compliance Requirements for Electronics Design Teams
There are several key elements for teams to consider when it comes to DFARS; broadly, these are outlined by secure design practices, cybersecurity, supply chain security, data rights, and export controls—the details for which you will find in the following table:
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Consideration |
Example |
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Secure design practices |
Adhere to secure coding standards like OWASP Top 10 to reduce vulnerabilities in firmware and software. |
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Implement hardware security measures such as secure boot, hardware-based encryption, and tamper detection. |
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Conduct thorough threat modeling to identify potential vulnerabilities and risks in the design. |
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Always prioritize components with strong security features and avoid those with known vulnerabilities. |
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Prepare a plan with each component's end-of-life in mind to address the security implications of component obsolescence. |
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Cybersecurity |
Identify and protect Controlled Unclassified Information (CUI) in accordance with DFARS clause 252.204-7012, which may include technical data, source code, and design documents; implementation of access controls, encryption, and regular security assessments can all assist in this endeavor. |
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Adhere to the security standards outlined in NIST SP 800-171, including those related to access controls, incident response, and risk assessments. |
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Establish reliable incident response plans so that teams across the organization can promptly detect, respond to, and report cybersecurity incidents in accordance with DFARS clause 252.204-7012. |
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Comply with DFARS' "Cloud Computing Services" clause 252.239-7010 and clause 252.204-7008, known as "Compliance with Safeguarding Covered Defense Information Controls", and any others that are relevant to the protection of sensitive data. |
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Supply chain security |
Conduct sufficient due diligence to assess and verify the authenticity and cybersecurity practices of suppliers, as well as ensure they comply with necessary standards and regulations. If existing suppliers fail to meet the standard, you should either replace them or bring them up to standard. |
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Implement measures to prevent the introduction of counterfeit components into the supply chain; you can achieve this through supplier audits, component traceability, and counterfeit part detection tools. |
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Assess and mitigate risks associated with the supply chain; this could include geopolitical factors and disruptions, such as warfare, natural disasters, and cyber threats. |
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Data rights |
Familiarize yourself and your teams with the different types of data rights (limited rights, unlimited rights, etc.) and their implications. Make sure that everybody understands how data rights affect the ownership, usage, and distribution of data. |
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Properly mark and handle government-furnished information (GFI) to ensure its security and proper usage. Implement procedures for controlling access, storage, and transmission. |
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Export controls |
Determine whether your designs or technology are subject to export controls under the International Traffic in Arms Regulations (ITAR) or the Export Administration Regulations (EAR). |
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Obtain the necessary licenses and permits for exporting or transferring controlled technology and implement export control procedures, including screening orders, classifying items, and obtaining required authorizations. |
Cloud Computing and DFARS Compliance
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Consideration |
Example |
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Cloud service provider (CSP) selection |
Choose CSPs that have strong security practices and can meet DFARS requirements; consider factors such as the Federal Risk and Authorization Management Program (FedRAMP certification), data center locations, and security certifications. |
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Really consider using FedRAMP-authorized CSPs, which have undergone arguably the most rigorous security assessments and are deemed compliant with federal security standards. |
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Data security in the cloud |
Encrypt sensitive data both at rest and in transit, and try to implement strong encryption algorithms and key management practices across teams. |
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Restrict access to sensitive data only to authorized personnel, with role-based access controls and multi-factor authentication processes. |
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Conduct regular security assessments to identify and address vulnerabilities; to do this, you can run vulnerability scans, penetration tests, and security audits. |
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Data residency and sovereignty |
Be aware of data residency requirements and ensure that sensitive data is stored in approved locations. Don't forget to consider data sovereignty laws and regulations that may impact data storage and transfer. |
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Adhere to data transfer restrictions and obtain necessary approvals for cross-border data flows, implement data transfer controls, and monitor data flows to ensure compliance with regulations. |
Practical Tips for DFARS Compliance
DFARS is a multifaceted and regularly changing standard, but it is an essential aspect of working with the DoD, so it's something that all companies in such a situation must wrestle with. With that in mind, we have come up with some practical tips for compliance that you can implement within your own company to make it a slightly easier ride.
1. Establish a DFARS Compliance Program
Find a responsible team member who can play the role of DFARS compliance officer; their job will be to oversee compliance efforts. At the same time, develop a comprehensive plan that outlines procedures for the identification, assessment, and mitigation of DFARS risks. Once these two steps have been established, make sure that your team performs periodic audits to verify adherence to the requirements and identify areas where you could improve.
2. Implement Strong Cybersecurity Measures
You will also need to secure your system and infrastructure. Make sure that you have company-wide adherence to secure coding practices, such as input validation, output encoding, and error handling; implement network segmentation, firewalls, intrusion detection systems, and other security measures to protect sensitive design and development data; and develop and regularly test an incident response plan to address incidents promptly.
3. Train Your Team
Software alone cannot protect your company or teams. Given that cybersecurity is a relatively infantile concept, it's important that the company educates its employees sufficiently about cyber threats, best practices, and how to protect sensitive information. Such education can be reinforced by training employees on proper data handling procedures, including classification, labeling, and access controls. It is equally important, as mentioned above, that teams know everything about export control regulations, as well as licensing requirements and the potential consequences of non-compliance.
4. Embrace Automation
Tools provided by innovative tech companies can make this entire process easier. For example, you could implement data loss prevention (DLP) tools to monitor and control data movement, which removes the human element and prevents unauthorized transfers and leaks; use security information and event management (SIEM) tools to collect, analyze, and correlate security event logs, which enables the timely detection and response to incidents; or employ configuration management tools to automate the configuration and deployment of systems, which ensures consistent security settings and a reduces the risk of misconfigurations.
Remember that adherence to DFARS regulations isn't purely about compliance; it's also a strategic move that makes your company eligible for bigger, arguably better contracts through the DoD. Compliance with these regulations gives your company a fantastic opportunity to enhance its reputation as a trusted—and, for future collaborations, trustworthy—partner that mitigates risks and protects sensitive information.
It's not the simplest process, but it's a worthwhile one, and Altium 365 can help with the process through centralized design data; enhanced collaboration between internal teams, suppliers, and partners; robust security measures, including data encryption and access controls; and compliance checking automation integrations. Explore Altium 365 GovCloud today—a dedicated region of Altium 365 built on AWS GovCloud infrastructure—to take the next step towards DFARS compliance and strengthen the security of your electronics design process.
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Table of Contents
- Why Is DFARS Important for Electronics Design Teams?
- Key DFARS Compliance Requirements for Electronics Design Teams
- Cloud Computing and DFARS Compliance
- Practical Tips for DFARS Compliance
- 1. Establish a DFARS Compliance Program
- 2. Implement Strong Cybersecurity Measures
- 3. Train Your Team
- 4. Embrace Automation
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