Is Vulnerability Data Considered CUI? Guidance for Contractors

Cybersecurity analyst examining vulnerability scan reports in a secure operations center to protect Controlled Unclassified Information (CUI) for defense contractors

Is Vulnerability Data Controlled Unclassified Information? A Practical Guide for Defense Contractors

Key Takeaways

Vulnerability data associated with systems that process, store, or transmit Controlled Unclassified Information (CUI) must be protected under CMMC requirements, and may qualify as CUI depending on context and the DoD CUI Registry. When it involves only Federal Contract Information (FCI), Level 1 safeguarding requirements still apply.
When in doubt, treat vulnerability findings as CUI to avoid risking unauthorized disclosure of sensitive DoD information.
Defense contractors must follow NIST SP 800-171 safeguards, such as encryption, access restrictions, and audit logging, on vulnerability data associated with DoD contracts.

Introduction

If you’ve ever performed vulnerability scans, analyzed penetration test results, or managed remediation efforts, you’ve likely wondered:

“Should this vulnerability data be treated as Controlled Unclassified Information (CUI)?”

This question is a common challenge throughout the Defense Industrial Base (DIB). Misclassifying vulnerability data as non-sensitive can expose critical Department of Defense (DoD) information, while treating everything as CUI unnecessarily burdens day-to-day operations.

The answer depends largely on context, but in most circumstances, vulnerability data should be protected consistent with CMMC requirements when it relates to systems that process or handle CUI or FCI. Whether the data itself is formally designated as CUI depends on DoD’s CUI Registry. This approach aligns directly with key regulations including DFARS 252.204-7012, NIST SP 800-171, and the Cybersecurity Maturity Model Certification (CMMC) requirements under 32 CFR Part 170.

In this guide, we’ll clarify when and why vulnerability data counts as CUI, outline how to handle such information properly, and provide actionable advice for defense contractors.

If you want to deepen your understanding of CMMC requirements and domains, consider reviewing our introductory guide on Understanding the Cybersecurity Maturity Model Certification.

Understanding Vulnerability Data

What exactly is “vulnerability data”? It goes far beyond just raw scanner outputs. Vulnerability data includes:

Automated scan results generated by tools like Nessus, Qualys, or OpenVAS
Findings and reports from penetration tests
Configuration assessment outcomes
Remediation plans, notes, and tickets (including Plans of Action and Milestones, or POA&Ms)
System Security Plans (SSPs) identifying potential security weaknesses

Collectively, this information falls under security assessment data, which is comprehensively covered in NIST SP 800-115 and acknowledged within 32 CFR Part 170 governing CMMC. For strategies on managing security assessments effectively, our post on Mastering CMMC Security Assessment Domain 12: Continuous Cybersecurity Protection offers expert tips.

How Does the DoD Define CUI?

Determining whether vulnerability data is CUI depends on these primary frameworks:

DFARS 252.204-7012: Requires safeguarding “covered defense information,” encompassing CUI.
NIST SP 800-171: Mandates protection measures for CUI when processed, stored, or transmitted by non-federal systems.
DoD CUI Registry: Defines categories of CUI including cybersecurity-related information such as vulnerability reports and security assessments.

If the vulnerability data reveals insights on how DoD systems might be exploited, or if it was generated as part of contracts involving CUI or FCI, it is classified as CUI.

When Should Vulnerability Data Be Treated as CUI?

You should apply CMMC protections and, when designated by the DoD CUI Registry, treat vulnerability data as CUI in these scenarios:

It pertains to systems handling CUI or FCI For example: Scan results for a contractor network that processes Controlled Technical Information (CTI).
It could expose sensitive DoD mission systems or critical programs For example: Penetration test findings for defense research and development systems.
It is part of contractual security deliverables For example: Incident reports or POA&Ms required by DFARS 7012.
It relates directly to protections mandated by NIST 800-171 or CMMC For example: Documentation addressing remediation actions following a compliance assessment.

Because this data directly influences the security of DoD assets, inadequate protection risks providing adversaries with a framework to exploit mission-critical systems.

When Might Vulnerability Data Not Be CUI?

Not all vulnerability-related information meets the threshold to qualify as CUI. Examples of non-CUI vulnerability data include:

Internal IT scans unrelated to DoD contracts For instance, a vulnerability scan on a corporate human resources system that contains no CUI or FCI.
Generic security testing reports not linked to government systems For example, internal vendor benchmark reports on password strength.
Information about commercial systems outside federal contracting scope For example, scan results from a marketing website with no DoD contract involvement.

In general, if the data does not touch systems processing, storing, or transmitting CUI or FCI, it usually does not fall under DoD’s CUI safeguarding requirements.

Required Protections for Vulnerability Data as CUI

If vulnerability data qualifies as CUI, contractors must implement the following safeguards consistent with NIST SP 800-171 and CMMC Level 2 requirements:

Access Control: Restrict data visibility to authorized personnel only.
Encryption: Secure vulnerability data both at rest and during transmission.
Audit Logging: Maintain detailed logs tracking all access to the data.
Configuration Management: Store reports and remediation notes within systems that comply with CUI handling standards.
Evidence Retention: Safely retain documentation for CMMC audits and assessments.

When uncertainty arises about classification, it is safest to treat vulnerability data as CUI to prevent inadvertent disclosure.

For detailed guidance on how to implement configuration management securely, see our article on Mastering Configuration Management in CMMC.

Frequently Asked Questions

Is vulnerability data always considered CUI?

No, but it is if it concerns systems processing DoD CUI or FCI. Otherwise, it remains internal company information.

What about data created internally but related to a DoD agency?

Data not provided by the DoD and unrelated to contract systems is typically not CUI, but exercise caution if it could reveal DoD operations.

Is a database schema CUI?

If the schema exposes structure of systems handling CUI or FCI, it may be CUI. Generic commercial schemas usually are not.

Does remediation documentation count as CUI?

Often yes, especially when it references vulnerabilities in systems linked to CUI. This includes POA&Ms and corrective action reports required by NIST 800-171. Under 32 CFR Part 170 170.21, POA&Ms tied to CMMC assessments must be closed within 180 days to maintain certification status. If the remediation only involves FCI, Level 1 safeguards apply but the data itself may not be designated as CUI.

How should scan results be stored?

Within controlled environments that meet CMMC Level 2 standards, using encryption, access controls, and logging consistent with your System Security Plan.

Wrapping Up

Understanding the classification of vulnerability data is essential for defense contractors to stay compliant with DoD cybersecurity requirements. Most vulnerability data tied to systems handling DoD CUI requires CUI-level safeguarding. Vulnerability data tied only to FCI is still subject to CMMC Level 1 requirements but is not always considered CUI.

By applying NIST SP 800-171 and CMMC 2.0 protections, limiting access, encrypting sensitive information, and maintaining audit trails, you can ensure your vulnerability data remains secure and compliant.

If your organization faces challenges distinguishing CUI from internal data or in maintaining compliance documentation, adopting structured classification and management tools is crucial.

Next Steps

Classifying vulnerability data correctly is a cornerstone of achieving CMMC compliance and protecting DoD assets. Consider tools designed specifically for defense contractors to streamline categorizing CUI/FCI, track compliance evidence, and prepare efficiently for C3PAO assessments.

Explore how our [SaaS product name] can simplify your vulnerability data management and compliance workflows — ensuring you protect sensitive information without operational overload.

Ready to take the next step toward compliance? Sign up today for the CMMC Dashboard to manage your compliance efforts with confidence, streamline audit readiness, and safeguard controlled information with ease.

References:

DFARS 252.204-7012, Safeguarding Covered Defense Information and Cyber Incident Reporting
NIST Special Publication 800-171 Rev 2, Protecting Controlled Unclassified Information in Nonfederal Systems and Organizations
NIST Special Publication 800-115, Technical Guide to Information Security Testing and Assessment
Code of Federal Regulations Title 32 Part 170, Cybersecurity Maturity Model Certification (CMMC)
DoD Controlled Unclassified Information Registry, https://www.dodcui.mil/

Protect vulnerability data thoughtfully: Error on the side of caution and ensure robust safeguards are in place to protect the very systems your organization relies on.