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CUI Readiness Checklist

Retire Every Legacy CUI Marking Before Your Assessment

FOUO and SBU are no longer authorized. Cross-check every category against the current NARA CUI Registry and get your banner, portion, and dissemination markings assessment-ready.

The problem

You have carried category names for years, and you don’t know which NARA has renamed or retired

Organizations that have run a CUI program for several years frequently carry legacy category names that no longer match current registry entries, and legacy labels like FOUO and SBU that 32 CFR Part 2002 no longer authorizes. An outdated category name creates marking inconsistencies and raises questions about every safeguarding decision tied to that designation. Assessors trace each CUI designation back to its authority source, and weak or missing authority citations are among the most consistent categorization findings in DIB assessments. Gaps an assessor finds, rather than ones you have already documented, undermine confidence in your entire SSP.

Free download

Get instant access to the checklist

Instant download, straight to your inbox. The full 41-point, 10-section CUI Readiness Checklist, built for program managers and compliance leads preparing for a CMMC or DFARS assessment.

What’s inside

What the marking and categorization checks cover

Cross-referencing your category list against the current NARA CUI Registry
Banner, category, portion, and designation-indicator marking checks
Authority citations assessors can trace back to a registry entry
CUI Basic vs. CUI Specified determinations for every category in scope
Limited dissemination controls: NOFORN, FEDCON, and REL TO usage

The payoff

What you can do once you have worked through it

Walk in knowing where your program would fail

You find and close your own CUI gaps before an assessor does, instead of discovering them during the assessment.

Defend every category you apply

You can produce a registry-confirmed, documented basis for each category in use and retire the deprecated and renamed ones.

Stop relying on markings that are no longer valid

You replace legacy FOUO and SBU labels with approved banners, portion markings, and dissemination controls drawn straight from the registry.

See the program the way the auditor will

Each section names what assessors check first and where DIB programs most commonly fail, so you prioritize the right fixes.

Full coverage

The checklist covers the full program, not just marking

01
Program foundation
SAO designation, governing policy, CUI vs. FCI, DFARS 7012 flowdown.
02
NARA registry and categorization
Registry cross-reference, authority citations, and categorization checks.
03
CUI inventory verification
Inventory, data flow mapping, and review cadence.
04
Marking compliance
Banner, portion, email, and dissemination marking compliance.
05
NIST 800-171 safeguarding
All 110 requirements across 14 families and SPRS accuracy.
06
Enhanced & secure sharing
NIST 800-172 requirements, secure sharing, and enclave checks.
07
Handling through sign-off
Handling, destruction, training, and assessment readiness sign-off.

Grounded in the authorities

Grounded in the actual authorities

The regulatory stack

Cites 32 CFR Part 2002, 32 CFR Part 170 (CMMC), NIST SP 800-171 Rev 2, NIST SP 800-172, and NIST SP 800-88 Rev 1.

The contract clauses

Cites DFARS 252.204-7012, 7019, 7020, 7021 and FAR 52.204-21.

All 110 requirements

Breaks down all 110 NIST 800-171 requirements across the 14 control families.

Scoring & assessment paths

References the DoD Assessment Methodology v1.2.1, SPRS, FedRAMP Moderate, DoD Impact Levels, and the DIBCAC and C3PAO assessment paths.

Concrete standards

Names FIPS 140-2/140-3, TLS 1.2+, DIN 66399 Level P-4 shredding, the 88/110 minimum, and the 180-day POA&M limit.

FAQ

Before you download

CUI Basic follows the baseline handling requirements in 32 CFR 2002 and NIST SP 800-171. CUI Specified carries additional or alternative handling requirements set by the authorizing law, regulation, or government-wide policy for that category. The checklist walks you through producing a written determination for each category in scope so you do not default everything to Basic.

CUI Readiness Checklist

Find your own gaps before an assessor does

Instant download, straight to your inbox. 41 items across 10 sections.