What Federal Contract Information (FCI) Is and Is Not

Federal Contract Information (FCI) is one of the most frequently misunderstood concepts in the world of government contracting. Many organizations overclassify their federal contract data, treating all information as if it were Controlled Unclassified Information (CUI) and applying stricter security controls unnecessarily. Other organizations fail to recognize when FCI is present, leaving themselves at risk of non-compliance.

Misunderstanding Federal Contract Information often leads to gaps in government contract security, especially when organizations fail to align their safeguards with actual FCI requirements.

Understanding what FCI is, and what it is not, is essential for accurately defining system boundaries, maintaining compliance, and ensuring that defense contractor cybersecurity resources are applied efficiently.

At ProActive Solutions, we help defense contractors and suppliers in the Defense Industrial Base (DIB) navigate the complexities of the Cybersecurity Maturity Model Certification (CMMC) and meet related defense contractor security requirements.

Let’s take a closer look at how FCI is defined, where it appears in practice, and what safeguards are required under federal regulations.

What Federal Contract Information (FCI) Is and Why It Matters  

The Federal Acquisition Regulation (FAR) defines FCI in clause 52.204-21 as information, not intended for public release, that is provided by or generated for the government under a contract to develop or deliver a product or service to the government. In simpler terms, FCI is any information that supports a federal contract but is not meant for public distribution.

FCI is tied directly to the performance of a government contract. If the information is created, shared, or used as part of that contract and is not publicly available, the data should be treated as FCI. Accurately classifying and protecting FCI is crucial, not only for meeting compliance, but also to ensure that your organization remains eligible to receive government contracts.

Common Examples of FCI in Contractor Environments

A clear understanding of which federal contract data qualifies as FCI helps contractors identify and protect contract data appropriately.

Common examples of FCI include:

What Federal Contract Information (FCI) Is and Why It Matters

• Purchase orders, statements of work, or task orders received from a federal customer
• Project plans, schedules, or deliverable drafts generated for a contract
• Emails containing instructions, performance details, or clarifications from a contracting officer
• Configuration data, design documents, or progress reports tied to a specific contract

These types of information often flow through multiple systems in contractor environments, such as file shares, project management tools, and email servers, that are used to manage federal contracts and deliverables. Properly identifying where FCI resides and is handled helps ensure that security controls are applied consistently across systems, and these systems can be documented for assessments, including CMMC audits.

What Is Not Considered Federal Contract Information 

While the definition of FCI is broad, not everything related to a contract qualifies. The following examples illustrate what does not fall under the FCI definition:

• Publicly available information, such as press releases, marketing materials, or bid solicitations
• Internal corporate data unrelated to government contracts
• Classified information or Controlled Unclassified Information (CUI), which require higher levels of protection

If the information is already public, not linked to a specific federal contract, or falls under another classification, it is not considered FCI.

How FAR 52.204-21 Safeguards Apply to FCI 

Contractors that handle FCI are required to implement the basic safeguarding requirements described in FAR 52.204-21. These federal contract security requirements are derived from the National Institute of Standards and Technology (NIST) SP 800-171 and include practices such as:

• Limiting access to authorized users
• Protecting information at rest and in transit
• Monitoring systems for unauthorized activity

These safeguards play a critical role in broader CMMC compliance efforts, particularly for organizations supporting federal and defense programs. Implementing FAR 52.204-21 safeguards establishes the foundation for CMMC Level 1 compliance. Contractors who manage both FCI and CUI will need to extend these protections by adopting additional controls under CMMC Level 2.

Why Proper FCI Classification Is Critical for CMMC Readiness

Properly identifying and classifying FCI is a critical step in CMMC compliance readiness. Overclassification can lead to unnecessary government contract security costs and complexity, while underclassification can create significant security and regulatory risk.

Accurate classification of FCI allows organizations to scope, secure, and document their environments correctly, ensuring that System Security Plans (SSP) and boundary diagrams reflect the actual flow of government contract-related data.

Achieving clarity in FCI classification not only supports CMMC compliance but also improves organizations’ overall cybersecurity posture by helping them focus security resources on areas that matter most.

Get Help from ProActive Solutions Identifying and Protecting FCI 

ProActive Solutions helps defense contractors prepare, protect, and perform with confidence across every phase of their cybersecurity journey to meet evolving FCI compliance and CMMC Level 1 requirements. Our CMMC Readiness Workshop provides practical guidance on how to identify and protect FCI and CUI within your organization.

During the Workshop, participants learn how to map data flows, apply the 0–3 readiness scoring model, and understand what assessors look for during a CMMC review.

Gain clarity on Federal Contract Information and confidence in your CMMC readiness journey with expert guidance from ProActive Solutions. Register to join ProActive for the next session of our CMMC Readiness Workshop.