FCI & CUI Walk into a Bar… Only One Gets Carded

Before you embark on your CMMC journey, it’s important that you not only know what information that you’re handling, but that you also understand it. In the world of information security and government contracting, two important terms float around and throughout the ecosystem. And if you’re a federal government contractor wondering about CMMC, it’s vital that you understand the difference between them. So, FCI vs. CUI? Let’s break it down.

As organizations navigate the CMMC landscape, grasping the distinction between Controlled Unclassified Information (CUI) and Federal Contract Information (FCI) is not only essential for compliance, but for safeguarding national security and retaining federal business.

What is FCI?

Federal Contract Information (FCI) is information not intended for public release, generated by or for the government under a contract to develop or deliver a product or service to the federal government. However, FCI is generally less sensitive than CUI.

Some key characteristics of FCI:

• It does not include public information or simple transactional data
• It typically includes contract performance details, internal reports, or communication with the contracting agency
• CMMC Level 1 is designed to protect FCI and includes safeguarding requirements from FAR 52.204-21.

What is CUI?

Controlled Unclassified Information (CUI) is a category of sensitive information that, while not classified, is still subject to specific safeguarding and dissemination controls under federal law, regulation, or government-wide policy.

Examples of CUI include:

• Technical drawings
• Engineering data
• Export-controlled information
• Legal, health, or financial data protected by federal statues

CUI is subject to stricter protection requirements because it could cause harm to national security if improperly accessed. Protecting CUI is central to CMMC Level 2 and 3, which requires NIST SP 800-171 compliance and more advanced security practices.

FCI vs. CUI: Why the Distinction Matters in CMMC

CMMC is built on the foundation of protection levels that align with the sensitivity of the data being handled. Understanding the type of information you work with determines the level of certification your organization must attain to be eligible for DoD contracts.

Failure to differentiate CUI from FCI can lead to:

• Incorrect implementation of security controls
• Incomplete System Security Plans (SSPs)
• Gaps in compliance that disqualify contract eligibility
• Increased vulnerability to cyber threats

For example, a defense contractor handling only FCI may suffice with CMMC Level 1 certification. But if that same contractor also works with CUI, they must meet much more rigorous Level 2 requirements.

The Case of Compliance in FCI vs. CUI

Understanding this distinction not only helps in passing your audit, but it also allows you to make better informed business decisions. Proper classification helps with building accurate and defensible compliance documentation. It also assists you in avoiding costly rework or failed assessments.

Moreover, government agencies increasingly expect contractors to self-assess their environments accurately. This means having a wholly understanding of the information that you are working with. Misclassifying CUI as FCI (or vice versa) can raise red flags during a CMMC review and damage an organizations reputation and future opportunities.

Let Axiom Help You Understand Your Distinction

In the world of CMMC, data classification matters. Understanding FCI vs. CUI is vital in understanding CMMC compliance as a whole.

Not sure if you’re handling CUI or FCI, or how to protect it? Let Axiom guide you. We help defense contractors navigate the complexities of CMMC with tailored cybersecurity solutions, documentation support, and full-scope compliance readiness. We’re there every step of the way and well after.

Contact us today to schedule a consultation.