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DFARS compliance checklist

About the DFARS compliance checklist

Keeping up with DFARS requirements means tracking dozens of processes, from access control to risk assessments. With this DFARS compliance checklist, you and your team can confidently manage these critical evaluations. This template gives you a standardized approach to monitoring and documenting compliance efforts, making it easier to identify gaps and address them efficiently.

A step-by-step guide to using a DFARS compliance checklist

The DFARS compliance checklist template helps you organize and document compliance tasks with ease. Follow these steps to fully leverage this tool:

Customize the checklist for your industry. Edit the template to include all necessary compliance areas specific to your operations, like access controls, encryption policies, or risk assessments. This way, the checklist aligns perfectly with your workflow.
Conduct a baseline review. Use the checklist to evaluate your current compliance status, verifying that key protocols are in place. Document findings thoroughly, including photos, notes, or signatures where required.
Assign responsibility and track progress. Assign the checklist to a designated compliance manager who will complete the sections and follow up on flagged tasks. Lumiform’s app lets you monitor progress and provides an overview of unresolved issues.
Integrate into routine audits. Incorporate the checklist into your regular compliance reviews, using it to standardize evaluations. This makes recurring audits more consistent and reliable.
Analyze and improve. Leverage the data gathered from the completed checklists to identify trends or recurring compliance gaps. Use these insights to improve processes and strengthen compliance over time.

Best practices for using a DFARS compliance checklist

With these tips, you’ll create a more efficient, reliable compliance process while staying prepared for audits or assessments.

First, leverage analytics for continuous improvement. The data you collect through the DFARS compliance checklist isn’t just for record-keeping—it’s a valuable resource for identifying trends and areas of improvement. Use Lumiform’s analytics to spot recurring compliance gaps, monitor progress over time, and develop targeted strategies to address weak spots.

Avoid rushing through sections to prevent errors. Completing the checklist requires attention to detail, especially when documenting findings or verifying compliance protocols. Take the time to thoroughly review each section, ensuring nothing is missed or misinterpreted.

Consider involving a dedicated compliance officer. Assigning a dedicated compliance officer to oversee the checklist ensures accountability and consistency in its use. This individual can focus on accurately completing sections, tracking progress, and addressing flagged issues promptly.

Download Lumiform’s DFARS compliance checklist today

With this ready-made DFARS checklist template, you’ll have a powerful tool to keep tasks organized, track your progress, and document findings with accuracy. Whether you’re conducting a one-time audit or adding compliance checks into your routine, this flexible template is designed to help you stay on track. Assign tasks, manage action points, and review outcomes—all in one place.

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Preview of the template

DFARS Compliance Self-Assessment

Access Control

Does the company have an authentication process?

Does the company require users to sign up to gain access?

Are account requests authorized before system access is granted?

Are access control lists used to restrict access to applications and data based on role and/or identity?

Do architectural solutions exist to control system data flow? (e.g., firewalls, proxies, encryption, and other security technologies).

Is there a division of responsibilities and separation of duties between individuals to avoid conflicts of interest?

Are users granted only enough privileges to do their jobs?

Do users with multiple accounts (privileged and non-privileged) typically log in with the least privileged account when not performing privileged functions?

Are non-privileged users prevented from performing privileged functions?

Is the system configured to lock the login mechanism after a certain number of invalid login attempts for a certain amount of time?

Is the system configured to terminate user sessions after a specified period of time based on the duration and/or inactivity of the session?

Are network and system monitoring applications used to monitor remote system access and log accordingly?

Is cryptography used to protect the confidentiality and integrity of remote access sessions?

Does the system route all remote access through a limited number of managed access control points?

Is remote access for privileged actions (e.g., software installation) allowed only for necessary operational functions?

Is WLAN access to the system authorized, monitored and managed

Is WLAN access encrypted according to industry best practices?

Has management established policies for the use of mobile devices?

Does the company encrypt CUI on mobile devices?

Are there policies and restrictions on the use of personal or external system access?

Are there restrictions on authorized individuals regarding the use of company-owned removable media on external systems?

Is the planned content of publicly available information reviewed prior to release?

Awareness and Training

Is basic security awareness training provided to all system users prior to authorizing access to the system, if required due to system changes, and at least annually thereafter?

Do all users, managers, and system administrators receive initial and annual training appropriate to their roles and responsibilities?

Do employees with security-related roles and responsibilities receive initial and annual training on their operational, managerial, and technical roles and responsibilities?

Do users, managers, and system administrators receive annual training on potential signs and possible harbingers of an insider threat?

Does security training include communication of employee and management concerns about potential signs of an insider threat?

Audit and Accountability

Does the company create, protect, and retain records of information system audits for a period of 30 days to one year (depending on the data source and applicable regulations) to enable monitoring, analysis, investigation, and reporting of unlawful, unauthorized, or inappropriate system activities?

Can the organization clearly track and hold accountable users who perform unauthorized actions?

Does the organization review and update audited events annually or when significant system changes occur or as needed?

Is there a real-time alarm when a defined event occurs?

Does the system alert employees with safety responsibility in the event of an audit processing error?

Does the company use mechanisms for integrating review, analysis, correlation, and reporting processes across multiple repository locations?

Does the system provide audit reduction and reporting capabilities?

Does the system protect audit information and audit tools from unauthorized access, modification, and deletion?

Does the system use internal system clocks to generate timestamps for audit records?

Is access to audit functionality management allowed only to a limited group of privileged users?

Configuration Management

Are baseline configurations developed, documented, and maintained for each information system type?

Are changes tracked and documented in an approved IT service management (ITSM) system or equivalent tracking service?

Are configuration changes tested, validated, and documented before they are installed on the operational system?

Are authorized personnel approved and documented by the service owner and IT security?

Does the system employ processing components with minimal functionality and data storage)?

Are only applications and services configured and enabled that are needed for the system to function?

Is the information system configured to run only authorized software?

Are there user controls in place to prevent the installation of unauthorized software?

Identification and Authentication

Are company and service accounts centrally managed and automatically deleted when an employee leaves the company?

Do all passwords follow the best practice of at least 12 characters and require a mix of upper and lower case letters, numbers and special characters?

Is multifactor authentication used for local access to authorized accounts?

Are defined repeatable authentication mechanisms used for network access to privileged accounts?

Are account identifiers uniquely assigned to employees, contractors, and subcontractors?

Are user or device identifiers deactivated after a period of inactivity (e.g., 30 days)?

Does the organization specify a level of complexity, such as whether account passwords must be at least 12 characters long and contain a mix of upper and lower case letters, numbers, and special characters, including minimum requirements for each type?

Is password reuse limited to a certain number of generations?

Are temporary password activation links sent to authorized employees in case they need to reset or change a password?

Does the company follow the best practice of "salting" hashed passwords?

Do the authentication mechanisms hide the feedback of authentication information during the authentication process?

Incident Response

Is there a company incident response policy that specifically outlines requirements for handling incidents involving CUI?

Is there a company incident response policy that specifically outlines requirements for tracking and reporting incidents involving CUI to appropriate officials?

Does the company test its incident response capabilities?

Maintentance

Does the company perform maintenance on the information system?

Are controls in place that limit the tools, techniques, mechanisms, and employees used to maintain information systems, devices, and supporting systems?

Are media that are removed from the premises for maintenance, repair, or disposal sanitized per the company’s media sanitization policies?

Are media that are provided by authorized maintenance personnel (and not normal systems administrators/owners) for troubleshooting, diagnostics, or other maintenance run through an anti-virus/anti-malware/anti-spyware program prior to using in the company’s information system?

Does the system require multifactor authentication for remote access?

Are all activities of maintenance personnel (who do not normally have access to a system) monitored?

Media Protection

Have responsible parties for data in these systems documented and ensured proper authorization controls for data in media and print?

Does the company limit CUI media access to authorized users?

Is system digital and non-digital media sanitized before disposal or release for reuse?

Are all CUI systems identified with an asset control identifier, for example, does each company laptop have an asset id tag with a unique number?

Are all CUI data on media encrypted or physically locked prior to transport outside of the company’s secure locations?

Are cryptographic mechanisms used to protect digital media during transport outside of controlled areas?

Is the use of writable, removable media restricted on the system?

Do all portable storage devices have identifiable owners?

Are data backups encrypted on media before removal from the company’s secured facility?

Personnel Security

Are individuals requiring access screened before access is granted?

Does the company disable information system access prior to employee termination or transfer?

Physical Protection

Has the facility/building manager designated building areas as “sensitive” and designed physical security protections (including guards, locks, cameras, card readers, etc.) to limit physical access to the area to only authorized employees?

Is physical access monitored to detect and respond to physical security incidents?

Are visitors escorted and monitored as required in security policies and procedures?

Are logs of physical access to sensitive areas maintained per retention policies? (This includes authorized access as well as visitor access.)

Are physical access devices (such as card readers, proximity readers, and locks) maintained and operated per the manufacturer's recommendations?

Do all alternate sites where CUI data is stored meet the same physical security requirements as the main site?

Risk Assessment

Does the company have a risk management policy?

Have initial and periodic risk assessments been conducted?

Are changes in use or infrastructure documented and assessed?

Are systems periodically scanned for common and new vulnerabilities?

Do system owners and company managers upon recognition of any vulnerability provide an action plan for remediation, acceptance, avoidance, or transference of the vulnerability risk?

Security Assessment

Has a periodic (e.g., annual) security assessment been conducted to ensure that security controls are implemented correctly and meet the security requirements?

Does the assessment scope include all information systems and networks, including all security requirements and procedures necessary to meet the compliance requirements of the environment?

Does the assessment include, but is not limited to, vulnerability scanning, penetration testing, security control testing and reviews, configuration testing and reviews, log reviews, and talking with company employees?

Is the assessment conducted by an independent security auditor/consultant?

Is a final written assessment report and findings provided to company management after the assessment?

Is there an action plan to remediate identified weaknesses or deficiencies?

Are continuous monitoring reports and alerts reviewed frequently (e.g., daily)?

Is the system security plan reviewed and approved by company management prior to plan implementation?

Does the company update the system security plan to address changes to the system, environment of operation or problems identified during plan implementation or security assessments?

Systems and Communications Protection

Does the system monitor and manage communications at the system boundary and at key internal boundaries within the system?

Are the company’s information security policies (including architectural design, software development, and system engineering principles) designed to promote information security?

Are physical or logical controls used to separate user functionality from system management-related functionality (e.g., to ensure that administration [e.g., privilege] options are not available to general users)?

Does the system prevent unauthorized or unintended information transfer via shared system resources, e.g., register, main memory, secondary storage?

Does the company implement DMZs (Demilitarized Zones)?

Does the system deny network traffic by default and allow network traffic by exception?

Are controls in place to prevent split tunneling in remote devices, and to mandate VPN use when necessary for business functions?

Are cryptographic mechanisms used to prevent unauthorized disclosure of information during transmission unless otherwise protected by alternative physical measures?

Are processes and automated mechanisms used to provide key management within the information system?

Do communication cryptographic mechanisms comply with applicable policies, standards, and guidance?

Have collaborative computing devices (e.g., cameras, microphones, etc.) been configured so they cannot be remotely activated?

Are there defined limits of mobile code usage, established usage restrictions, that specifically authorize the use of mobile code (e.g., Java, JavaScript, ActiveX, PDF, Flash, Shockwave, Postscript, VBScript, etc.) within the information system?

Is the use of VoIP authorized, and monitored?

Does the system provide mechanisms to protect the authenticity of device-to-device communications sessions?

Are there controls used to protect CUI while stored in company information systems?

System and Information Integrity

Are system errors detected, reported, and corrected within the timeframes defined by the organization?

Does the organization employ malicious code protection mechanisms at system entry and exit points to minimize the occurrence of malicious code? (System Entry and exit points can include firewalls, Email servers, web servers, proxy servers, remote access servers, workstations, notebooks, and Computers and mobile devices).

Does the company receive security alerts, recommendations and instructions from reputable external companies?

Does the company update information system protection mechanisms (e.g., antivirus signatures) within 5 days of new versions?

Does the company perform regular scans of the information system for malware?

Are scans performed within the timeframe that is in policy or within the system security plan?

Does the company monitor the information system to detect attacks and signs of potential attacks, as well as unauthorized local, network and remote connections?

Is unauthorized use of the system detected (e.g. log monitoring)?

Confirmation

IT Specialist - Name & Signature

Client - Name & Signature

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Frequently asked questions

What is the most overlooked aspect of DFARS compliance?

Data flow documentation is often one of the most overlooked areas in DFARS compliance. Many organizations focus on securing systems but neglect to map how Controlled Unclassified Information (CUI) moves across networks, devices, and third-party systems. Clearly documenting these pathways helps identify vulnerabilities and ensures every access point is secured.

What should I include in a DFARS compliance audit report?

A comprehensive DFARS compliance audit report should include an overview of your compliance status, evidence supporting each control (like logs or encryption protocols), flagged vulnerabilities, and recommended corrective actions. Adding timelines for remediation and assigning responsibilities for follow-up actions creates a clear roadmap for resolving compliance gaps.

How do I handle third-party vendors under DFARS guidelines?

When working with third-party vendors, verify they meet DFARS requirements by requesting compliance documentation or certifications. Clearly define their responsibilities in contracts, specifying how they must handle CUI. Regularly audit vendors to confirm adherence and provide guidance if their processes affect your compliance standing.

This template, developed by Lumiform employees, serves as a starting point for businesses using the Lumiform platform and is intended as a hypothetical example only. It does not replace professional advice. Companies should consult qualified professionals to assess the suitability and legality of using this template in their specific workplace or jurisdiction. Lumiform is not liable for any errors or omissions in this template or for any actions taken based on its content.