Practical Insights About Regulatory Frameworks
Cybersecurity…is as critical to military strength today as tanks, aircrafts and naval fleets
In the field of cybersecurity, there is a novel expertise designated as military cybersecurity. From a defence perspective, military cybersecurity is the practice of protecting armed forces’ digital systems, information networks, and substantial data from cyber threats, thereby ensuring operational readiness, national defence, and secure communications in modern warfare. It is as critical to military strength today as tanks (army), aircrafts (air force) and naval fleets (navy). It refers to the rules, strategies, technologies, and legal frameworks used by defence organizations to safeguard sensitive information, command-and-control systems, satellites, drones, and military communication networks from cyberattacks. It encompasses both defensive measures (protecting systems from intrusion) and offensive capabilities (cyber warfare operations against adversaries).
In the context of selling military-related materials to governmental entities in Canada, the USA and the UK, altogether SMEs, suppliers or contractors must comply with strict adherence to military cybersecurity frameworks, international standards and procurement rules. For instance, it should be clearly noted that, regarding the American CMMC, Canadian SMEs, suppliers or contractors must implement the regulatory framework FAR 52.204-21 which comprises 15 Basic Safeguarding of Covered Contractor Information Systems and not NIST SP 800-171. Nevertheless, each sovereign jurisdiction operates its own regulatory ecosystem but there are common threads, namely: protecting sensitive government data, ensuring secure software development, and demonstrating compliance through audits or certifications. Consequently, what are the military cybersecurity requirements that should be fulfilled by Canadian contractors or suppliers who are aiming to sell defence-related materials to the Governments of Canada, the USA and the UK?
Our Newsletter provides pragmatic insights on regulatory frameworks and miscellaneous security clearances pertaining to this question. The credible governmental hyperlinks (1 to 20) referred to at the end of this Newsletter have been duly accessed, carefully analyzed, comprehensively shortened and adapted for the writing of several parts of this manuscript.
Government of Canada: Significant Cybersecurity Requirements
- Treasury Board of Canada Secretariat Policies: Contractors must align with directives on IT security, vulnerability management, patching, and incident reporting.
- Canadian Centre for Cyber Security Guidance: Provides baseline controls, cyber threat assessments, and certification programs (e.g.: Common Criteria, Crypto Module Validation).
- Security Clearances: Roughly 88% of IT contracts require personnel and organizational security clearances.
- National Cyber Security Strategy: Emphasizes collaboration with businesses to protect Canadians and mandates cyber resilience against evolving cyber threats.
- Government of Canada Enterprise Cyber Security Strategy: A whole-of-government approach requiring suppliers to demonstrate compliance with enterprise-wide cyber standards.
- CPCSC: The Canadian Program for Cyber Security Certification is Canada’s new mandatory cybersecurity certification program for defence suppliers. It was launched in March 2025. The CPCSC ensures that companies bidding on or working with Government of Canada defence contracts meet strict cybersecurity standards to protect sensitive governmental information.
Government of the USA: Major Cybersecurity Obligations
- Federal Acquisition Regulation (FAR) & DFARS: Defense contractors must comply with NIST SP 800-171 for protecting Controlled Unclassified Information (CUI).
- Cybersecurity Maturity Model Certification (CMMC): Mandatory for defense supply chain vendors, with tiered levels of cybersecurity compliance.
- Executive Orders & New Standards: Recent mandates require software suppliers to provide transparency, secure software development practices, and incident reporting.
- Essential Security Controls: Cloud data leak prevention, encryption, and continuous monitoring are baseline expectations.
- Incident Reporting: Contractors and subcontractors must report cyber incidents within strict timelines under federal rules.
Government of the UK: Essential Cybersecurity Prerequisites
- Government Cyber Security Standard: All digital services and infrastructure must comply with the Cyber Assessment Framework (CAF) and “Secure by Design” principles.
- GovS 007 Functional Standard: Sets expectations for protecting government assets, citizen data, and supplier systems.
- Cyber Security and Resilience Bill (2025): Updates the UK’s Network and Information Systems Regulations (NIS), expanding obligations for suppliers across sectors.
- Mandatory CAF Profiles: Suppliers must demonstrate compliance with CAF profiles tailored to their risk exposure.
- Board-Level Accountability: The new bill elevates cybersecurity to a strategic priority, requiring governance and resilience planning.
Common Cybersecurity Ecosystem Threads Across Canada, USA & UK
- Baseline Security Controls: Encryption, patch management, vulnerability scanning, and secure configurations.
- Incident Reporting: Mandatory disclosure of breaches or cyber events within defined timelines.
- Supply Chain Security: Vendors must ensure subcontractors also comply with standards.
- Certification & Audits: NIST SP 800-171 (USA), CAF (UK), and Canadian Cyber Centre guidance all require demonstrable compliance.
- Secure Development: “Secure by Design” principles are now embedded in various procurement rules globally.
Figure 1: Core Cybersecurity Requirements for Defence-Related Materials Procurement
| Major Attributes | Government of Canada | Government of the USA | Government of the UK |
| Primary Focus | Protecting Canadian government and defence information on supplier systems. | Protecting Covered US Defense Information and Federal Contract Information. | Defence supply‑chain cyber assurance for UK Ministry of Defence (MOD) contracts. |
| Baseline Supplier Registration/Program | Controlled Goods Program (CGP) registration; industrial security rules; Canadian Program for Cyber Security Certification (CPCSC). | Defence Federal Acquisition Regulation Supplement (DFARS) clauses; contractor self-assessments and Cybersecurity Maturity Model (CMMC) Certification. | MOD Cyber Security Model (CSM); supplier registration for defence work. |
| Certification/Assurance Expected | CGP compliance; Canadian Program for Cyber Security Certification (CPCSC). | NIST SP 800‑171 compliance; CMMC 2.0 levels; DFARS 252.204‑7012 flow‑downs. | Cyber Essentials/ Cyber Essentials Plus; MOD CSM v4; Defence Cyber Certification. |
| Cloud Computing/ Hosting Requirements | Government guidance for handling diverse controlled data; specific cloud computing controls may be required. | FedRAMP‑authorized cloud computing services for (Controlled Unclassified Information (CUI); incident reporting to DoD. | Supplier Cyber Protection Service; cloud computing expectations tied to CSM and National Cyber Security Centre (NCSC) guidance |
| Export/Trade Controls | Defence Production Act/Controlled Goods Regulations for military items. | ITAR for defense articles; EAR for dual‑use items and re‑exports.
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UK export controls and defence procurement security rules; national security derogations. |
| Cyber Incident Reporting & Flow‑Downs | Mandatory security controls and cyber incident reporting for registered controlled goods suppliers. | Mandatory cyber incident reporting under DFARS; contractual flow‑downs to subcontractors. | MOD contractual clauses, incident reporting, and supply‑chain security obligations. |
Overview of What Government Entities Expect from Military‑Related Suppliers
Governmental entities treat defence and military procurement as high‑risk for national security and therefore classify industrial security, cybersecurity certification, export controls, and contractual flow‑downs on top of ordinary procurement rules. Suppliers should expect registration, baseline technical controls, personnel vetting, cyber incident reporting obligations, and restrictions on where and how defence data may be stored or transmitted.
Government of CanadaGovernment of Canada
Controlled Goods Program (CGP) & Canadian Program for Cyber Security Certification (CPCSC)
- Controlled Goods Program (CGP): Any organization that examines, possesses, or transfers diverse controlled goods in Canada must register in the CGP under the Defence Production Act and Controlled Goods Regulations; the program governs possession, transfer, and security plans for military‑relevant items and related technical data.
- Industrial security obligations: Registered entities must implement security plans, designate officials, and comply with security assessments and recordkeeping tied to controlled goods handling.
- Canadian Program for Cyber Security Certification (CPCSC): The Government of Canada has launched a mandatory cyber certification program for suppliers to certain defence contracts (phase rollout began in 2025) to protect unclassified government information on contractor IT systems. It is designed to align closely with models like the US CMMC and will specify certification levels and timelines for affected contracts.
Controlled Goods Program (CGP)
The Controlled Goods Program (CGP) is Canada’s domestic industrial security program that regulates access to certain military and national‑security–related goods, components, and technical data. It is administered by Public Services and Procurement Canada (PSPC) under the Defence Production Act and the Controlled Goods Regulations.
Main Features of the CGP
- Purpose: Prevents the proliferation of tactical and strategic assets by controlling who can examine, possess, or transfer controlled goods and related technology in Canada.
- Scope: Covers items such as weapons, military equipment, satellite systems, communications gear, and related intellectual property (e.g.: blueprints, technical specifications).
- Registration requirement: Any individual or organization in Canada that needs to handle controlled goods must register with the CGP.
- Security obligations: Registrants must develop and maintain a security plan, designate a company security officer, and undergo security assessments to ensure compliance.
- Subcontractors: If subcontractors will access controlled goods, they too must be registered in the program.
- Export controls link: The CGP works alongside Canada’s export control regime, ensuring that sensitive goods and technologies are safeguarded domestically before any export considerations.
Why Does the Controlled Goods Program Matter?
For companies supplying military‑related materials to the Canadian government (or foreign governments through Canadian contracts), CGP registration is often a mandatory prerequisite. It ensures that only vetted organizations and personnel can access sensitive defence items, reducing risks of espionage, diversion, or unauthorized transfer.
Canadian Program for Cyber Security Certification (CPCSC)
The CPCSC is a new federal initiative designed to strengthen cybersecurity in Canada’s defence supply chain. It introduces mandatory certification requirements for suppliers bidding on or working with certain Government of Canada defence contracts.
Purposes
- Safeguard unclassified government information stored on contractors’ networks, systems, and applications.
- Reduce risks from malicious cyber activity targeting Canada’s defence supply chain.
- Align Canada’s approach with international partners, especially the US Department of Defense’s Cybersecurity Maturity Model Certification (CMMC).
Key Features
- Certification Levels: The CPCSC has 3 levels of certification, scaled to the sensitivity of information and contract requirements.
- Third‑Party Assessments: Accredited organizations (via the Standards Council of Canada) will conduct independent assessments of suppliers’ cybersecurity controls.
- Alignment with Standards: The program is based on Canada’s ITSP.10.171 guidance (protecting controlled information in non‑government systems) and incorporates ISO/IEC 17020 accreditation for assessment bodies.
- Mutual Recognition Goal: Canada is working toward recognition with the U.S. CMMC framework to reduce duplicate compliance burdens for suppliers active in both markets.
- Implementation Timeline: Phase 1 launched in 2025, with requirements gradually applied to select defence contracts. Broader rollout is expected in subsequent phases.
Benefits
- For Canada: Stronger protection of sensitive defence information, improved resilience against cyber threats, and alignment with national cybersecurity strategies.
- For Suppliers: Clear, standardized requirements, potential recognition across borders, and enhanced credibility in defence procurement.
Synopsis: The CPCSC is Canada’s version of a defence supplier cybersecurity certification program, similar to the American CMMC, and has become a mandatory prerequisite for certain military and defence contracts starting in 2025.
Government of the USA
NIST, DFARS, CMMC, and Export Controls
- NIST SP 800‑171 and DFARS 252.204‑7012: American DoD contractors handling Controlled Unclassified Information (CUI) must implement NIST SP 800‑171 controls and comply with DFARS clause 252.204‑7012, which mandates safeguarding CUI and cyber incident reporting; this clause also requires use of approved cloud computing services and flow‑downs to subcontractors.
- CMMC: The Cybersecurity Maturity Model Certification (CMMC) provides an assessment and certification framework (levels mapped to NIST controls) that DoD is phasing into contracts; suppliers should track CMMC guidance and submit required attestations or third‑party certifications as contracts demand.
- Export Controls (ITAR/EAR): Defence materials, technical data, and military-related services may be subject to ITAR (administered by State) or EAR (Commerce) controls; export classification, licensing, and restrictions on foreign persons and transfers are critical for military‑related goods and technical data.
- Cloud Computing Services and FedRAMP: When cloud computing services are used to process CUI, DoD requires FedRAMP‑authorized cloud providers and specific reporting and incident handling procedures.
Three Certification Levels Defined by the CMMC 2.0 Framework
It should be clearly noted that, regarding the American CMMC, Canadian suppliers or contractors must implement the regulatory framework FAR 52.204-21 which comprises 15 Basic Safeguarding of Covered Contractor Information Systems and not NIST SP 800-171. The CMMC 2.0 framework defines three certification levels reflecting increasing cybersecurity maturity and data sensitivity. Level 1 – Foundational requires implementation of 17 basic practices to safeguard Federal Contract Information (FCI), as aligned with FAR 52.204‑21. Level 2 – Advanced builds on this foundation, mandating 110 controls based on NIST SP 800‑171 to protect Controlled Unclassified Information (CUI), and requires third-party assessments by accredited C3PAOs. Level 3 – Expert is aimed at organizations handling high-value CUI, incorporating all Level 2 requirements plus additional advanced practices from NIST SP 800‑172 (around 130 controls across 16 domains) to counter advanced persistent threats, with certification conducted by DIBCAC under the DoD.
Official Accreditation Body for the CMMC Ecosystem
Cyber AB (Cybersecurity Assessor and Instructor Certification Organization) is the official accreditation body for the CMMC ecosystem. It oversees training, certification, and quality standards for organizations and individuals involved in CMMC assessments. C3PAOs (Certified Third-Party Assessment Organizations) are companies authorized by Cyber AB to conduct formal CMMC assessments for contractors seeking certification. Together, they ensure that assessments are consistent, credible, and aligned with Department of Defense requirements.
Tools Provided by the NIST to Implement CMMC
The NIST offers a variety of tools to help organizations implement CMMC requirements effectively. These include resources like NIST SP 800‑171A assessment procedures for evaluating compliance with Level 2 controls, as well as curated collections of assessment and auditing tools to streamline self-assessments and readiness checks. Together, these resources simplify the process of aligning with CMMC standards and maintaining strong cybersecurity practices. Since CMMC and Canada’s CPSC share the same base, these tools can also be leveraged in the Canadian context to strengthen compliance and cybersecurity posture.
NIST Special Publication 800-171
The NIST Special Publication 800‑171 is a US federal cybersecurity standard that sets out requirements for protecting Controlled Unclassified Information (CUI) when it resides in non‑federal systems and organizations. It was developed by the National Institute of Standards and Technology (NIST) in response to Executive Order 13556, which established the CUI program.
Purposes
- Ensure that sensitive but unclassified government information (like defense technical data, legal records, or financial details) is safeguarded when handled by contractors or suppliers, universities, and other non‑government entities.
- Provide a consistent baseline of cybersecurity controls across the federal government supply chain.
Structure
- The requirements are organized into 14 control categories, such as:
- Access Control
- Awareness and Training
- Audit and Accountability
- Configuration Management
- Identification and Authentication
- Incident Response
- Maintenance
- Media Protection
- Personal Security
- Physical Protection
- Risk Assessment
- Security Assessment
- Systems and Communications Protection
- System and Information Integrity
Each family contains specific cybersecurity requirements (110 in total under Revision 2; as for Revision 3, published in 2024, it updates and refines them).
NIST Special Publication 800-171 Compliance Context
- Defense contractors or suppliers: Under the DFARS 252.204‑7012 clause, US Department of Defense contractors must implement NIST SP 800‑171 when handling CUI.
- CMMC (Cybersecurity Maturity Model Certification): CMMC levels map directly to NIST SP 800‑171 requirements, making compliance a prerequisite for many DoD contracts.
- Assessment: Contractors or suppliers must perform self‑assessments or undergo third‑party audits depending on contract requirements.
Latest Revision of the NIST Special Publication 800-171
- Revision 3 (2024): Strengthens requirements, clarifies language, and aligns with evolving cyber threats. This Revision 3 (2024) supersedes Revision 2 (2021).
Synopsis: The NIST SP 800‑171 is the backbone of US government contractor cybersecurity obligations, ensuring that sensitive but unclassified federal information is consistently protected outside federal systems.
Links Between Canadian CPCSC and American CMMC
The Canadian Program for Cyber Security Certification (CPCSC) and the US Cybersecurity Maturity Model Certification (CMMC) are directly connected because Canada has deliberately designed CPCSC to align with CMMC. This alignment ensures interoperability across the North American defense supply chain, reducing duplication for contractors who work with both governments.
Five Strategic Links Between Canadian CPCSC and American CMMC
1. Shared Purposes
Both frameworks aim to protect sensitive but unclassified government information (Federal Contract Information in the US, unclassified contractual information in Canada) from cyber threats.
2. Structural Alignment
- CPCSC adopts a tiered model similar to CMMC, with three levels of certification ranging from basic cyber hygiene to advanced practices.
- Compliance is verified through self-assessments, third-party audits, and government-led evaluations, mirroring CMMC’s approach.
3. Mutual Recognition Goals
Canada has explicitly stated that CPCSC is being developed to seek mutual recognition with the US CMMC Program, so Canadian suppliers or contractors will not face redundant certification when bidding on contracts across borders.
4. Defense Supply Chain Integration
- CMMC is mandatory for U.S. Department of Defense contractors handling Federal Contract Information (FCI) or Controlled Unclassified Information (CUI).
- CPCSC has become mandatory for Canadian defense suppliers starting in 2025, with phased implementation.
- This means suppliers in both countries must demonstrate equivalent cybersecurity maturity to participate in defense procurement.
5. Basis for Standards
Both programs are grounded in NIST SP 800-171 controls for protecting Controlled Unclassified Information, ensuring technical consistency across jurisdictions.
Why Do the Canadian CPCSC and American CMMC Matter?
For Canadian and American defense contractors, the links between CPCSC and CMMC mean:
- Streamlined compliance: A company certified under one framework will be better positioned to meet requirements under the other.
- Market access: Certification becomes a prerequisite for bidding on lucrative defense contracts.
- Risk reduction: Both programs raise the baseline of cybersecurity across the defense industrial base, reducing systemic vulnerabilities.
In a nutshell, CPCSC is Canada’s “mirror” of American CMMC, designed to ensure Canadian suppliers remain competitive and trusted partners in the US defense supply chain.
Government of the United Kingdom
MOD Expectations and National Cyber Baseline
- MOD Cyber Security Model (CSM v4): The Ministry of Defence uses the CSM to set supplier cyber requirements and to assess supplier maturity for defence contracts; CSM v4 is the current standard for MOD suppliers and includes scoping, evidence, and assessment guidance.
- Cyber Essentials and Procurement: UK central government often requires Cyber Essentials or Cyber Essentials Plus for suppliers bidding on certain public contracts to ensure a baseline of technical controls; large suppliers may be asked to demonstrate equivalent controls if not certified.
- Supply‑Chain Security Guidance: The NCSC and UK Government Security Group publish supply‑chain security guidance and expect procurement teams to manage security risk across suppliers, including for defence and national security contracts.
MOD Cyber Security Model (CSM v4)
The Ministry of Defence (MOD) Cyber Security Model (CSM v4) is the UK MOD’s framework for embedding cybersecurity requirements into its defence supply chain. It was introduced in 2024 as the latest update to the model, replacing earlier versions, and is now a mandatory requirement for suppliers handling MOD‑identifiable information.
Purposes
- Strengthen the cybersecurity and cyber resilience of MOD suppliers and subcontractors.
- Ensure proportionate security measures are applied based on the risk profile of the contract.
- Provide a consistent framework for assessing and certifying supplier cybersecurity.
Major Components
- Four Cyber Risk Profiles:
- Level 0 (“Basic”) – minimal requirements for very low‑risk contracts.
- Level 1 (“Foundational”) – baseline controls for common risks.
- Level 2 (“Advanced”) – enhanced measures for sensitive information.
- Level 3 (“Expert”) – highest assurance for critical defence projects.
- Supplier Cyber Protection Service (SCPS): Online portal where suppliers complete assessments, submit evidence, and manage compliance.
- Flow‑down obligations: Requirements extend to subcontractors, ensuring the entire supply chain meets appropriate cyber standards.
- Alignment with DEFSTAN 05‑138: The Defence Standard sets out detailed technical requirements, updated in 2024 to match the new four‑level risk profile system.
Real-World Implications for Suppliers
- Mandatory compliance: Any supplier working with the MOD and handling MOD‑identifiable information must meet the relevant CSM v4 requirements.
- Assessment process: Suppliers are assigned a cyber risk profile based on contract sensitivity and must demonstrate compliance at that level.
- Certification: Evidence is reviewed through SCPS, and suppliers may need independent verification depending on contract risk.
- Integration with Cyber Essentials: Many contracts still require Cyber Essentials or Cyber Essentials Plus as a baseline, with CSM v4 layered on top.
Synopsis: CSM v4 is the UK MOD’s structured approach to securing its defence supply chain, introducing four risk‑based levels of cybersecurity requirements, mandatory supplier assessments, and flow‑down obligations to subcontractors.
Pragmatic Steps for Suppliers Selling Military‑Related Materials
- Classify your product and data
- Determine whether your item, component, or technical data is a controlled good (Canada), a defense article (US ITAR), or otherwise subject to national export controls.
- Register where required
- Register in Canada’s Controlled Goods Program if you will examine/possess/transfer various controlled goods.
- Ensure any US defence work flows through properly registered entities and that you understand prime contractor flow‑downs under DFARS.
- Implement cybersecurity controls
- Determine which level of security certification applies (e.g.: CMMC/CPCSC Level 1 to 3 or CSM levels 0 to 3). For CMMC/CPCSC Level 1: FAR 52.204‑21 should be applied.
- Adopt NIST SP 800‑171 controls for handling CUI (or equivalent frameworks) and prepare for third‑party assessments or self‑assessments under CMMC/DFARS or Canada’s CPCSC and the UK CSM requirements.
- Obtain required certifications
- Pursue Cyber Essentials (UK) or equivalent; plan for CMMC certification or self‑assessment (US) and for Canada, monitor and prepare for CPCSC certification requirements tied to defence contracts.
- Use approved cloud computing services and secure supply chains
- Choose FedRAMP‑authorized cloud providers for US CUI; follow UK Supplier Cyber Protection Service and MOD guidance for cloud and supplier assurance; in Canada, follow Cyber Centre guidance and CPCSC scoping for cloud computing use.
- Prepare incident response and reporting
- Establish incident detection and reporting processes that meet DFARS incident reporting timelines and MOD/Canadian reporting expectations; ensure contractual clauses are understood and flow‑downs are in place.
- Address personnel and physical security
- Implement personnel vetting and physical security measures required by controlled‑goods rules and defence contracts (designated officials, access controls, secure facilities).
- Manage export compliance
- Classify items under ITAR/EAR or UK export control lists, obtain licenses where needed, and restrict transfers of technical data to foreign persons without authorization.
SMEs, Suppliers or Contractors Specifications Questions Before Bidding on Military/Defence Contracts in Canada, USA and UK
| Questions Pertaining to Military Cybersecurity Requirements | Yes/No |
| 1. Have you classified the item/data under national controlled goods or export lists? | |
| 2. Are you registered in required national programs (CGP in Canada; supplier registers in UK or USA as applicable)? | |
| 3. Can you demonstrate baseline cybersecurity controls (NIST SP 800‑171, Cyber Essentials, CSM evidence)? | |
| 4. Do you have a cloud computing service strategy using approved providers (FedRAMP, UK or Canada equivalents)? | |
| 5. Is your incident response aligned to contractual reporting obligations? | |
| 6. Have you planned for export licensing & anticipate restrictions on technical data? | |
| 7. Can you accept flow‑downs and subcontractor cyber-assurance requirements? |
Figure 2 – Comparative Military Cybersecurity Requirements Matrix for Defence-Related Materials: Canada, USA & UK
| Categories | Canada | USA | UK | Actionable Steps for Suppliers |
| Baseline Program/Registration | Controlled Goods Program (CGP) for military items. | DFARS clauses; DoD supplier registration. | MOD supplier registration; SCPS portal. | Register in CGP (Canada), ensure DFARS compliance (USA), and onboard via SCPS (UK). |
| Cybersecurity Certifications | CPCSC (phased rollout from 2025). | CMMC 2.0 (levels mapped to NIST SP 800‑171). | MOD Cyber Security Model (CSM v4) with 4 risk levels. | Identify required certification level per contract; prepare evidence and assessments. |
| Fundamental Standards | ITSP.10.171 guidance (aligned with NIST SP 800‑171). | NIST SP 800‑171; DFARS 252.204‑7012. | DEFSTAN 05‑138; Cyber Essentials baseline. | Implement controls across 14 NIST control classifications; align with DEFSTAN and Cyber Essentials. |
| Cloud Computing Services Requirements | Canadian Centre for Cyber Security guidance; CPCSC scoping. | FedRAMP‑authorized cloud computing services for military CUI | MOD/NCSC guidance; SCPS cloud computing expectations. | Use approved cloud computing providers; document compliance for audits. |
| Cyber Incident Reporting | Mandatory cyber incident reporting under CGP and CPCSC. | DFARS requires cyber incident reporting within 72 hours. | MOD clauses mandate incident reporting. | Establish incident response plan; align reporting timelines with each jurisdiction. |
| Export Controls | Defence Production Act; Controlled Goods Regulations. | ITAR (defense articles/clauses); EAR (dual‑use items). | UK Strategic Export Control Lists. | Classify items/data; obtain export licenses; restrict foreign access to technical data. |
| Supply Chain Flow‑Downs | CGP subcontractor registration. | DFARS or CMMC flow‑down to subcontractors. | MOD CSM v4 flow‑down obligations. | Ensure subcontractors meet equivalent requirements; include clauses in contracts. |
| Staff Vetting & Physical Security | Security plans, designated officials, vetting. | Personnel screening, facility security for ITAR. | MOD vetting, facility controls. | Vet staff, secure facilities, maintain access logs. |
Plan stratégique des fournisseurs de matériel militaire : mesures concrètes
- Classify defence-related materials and data according to the requirements of national controlled lists (CGP, ITAR or EAR, UK inventories).
- Register in compulsory national programs (CGP, DFARS, SCPS).
- Implement baseline controls (NIST SP 800‑171, CPCSC, Cyber Essentials).
- Obtain necessary certifications (CMMC, CPCSC, Cyber Essentials Plus).
- Secure cloud computing usage with approved military-related materials providers (FedRAMP, NCSC, Canadian Cyber Centre).
- Establish incident response aligned to incident reporting obligations.
- Vet personnel and secure facilities in alignment with national standards.
- Flow‑down requirements to subcontractors and monitor compliance.
- Manage export licensing for controlled goods and technical data.
Examples of Materials Specifically Related to Cyber Operations in Military Contexts
1. Doctrinal & Strategic Publications
- NATO Cyber Defence Policy – outlines collective defense approaches to cyber threats.
- US Department of Defense Cyber Strategy – defines offensive or defensive cyber operations and deterrence.
- UK MOD Cyber Primer – introduces cyber concepts for military personnel.
- Canadian Armed Forces Cyber Operations Doctrine – guidance on integrating cyber into joint operations.
2. Operational & Technical Manuals
- Rules of Engagement (ROE) for Cyber Operations – specifying when and how cyber tools can be used.
- Cybersecurity Field Manuals – for instance: US Army FM 3-12: Cyberspace and Electromagnetic Warfare Operations.
- Cyber Incident Response Playbooks – tailored for military networks (classified or unclassified environments).
- Secure Communications Protocols – encryption standards for tactical and strategic communications.
3. Training & Educational Materials
- Cyber Range Exercises – simulated environments for practicing defense or offense.
- Red Team or Blue Team Scenarios – adversarial exercises mimicking nation-state attacks.
- Military Academy Curricula – courses on cyber warfare, digital forensics, and network defense.
- Wargaming Materials – scenario-based planning for cyber-enabled conflicts.
4. Regulatory & Compliance Frameworks
- NIST SP 800-171 / 800-53 – often adapted for defense contractors.
- MOD Cyber Security Model (CSM) – UK defense supplier requirements.
- CPCSC (Canadian Program for Cyber Security Certification) – compliance for military procurement with the Canadian Armed Forces.
- International Law and Tallinn Manual – application and enforcement of international humanitarian law to cyber warfare.
5. Technical Tools & Artifacts
- Malware Analysis Reports – for instance: Stuxnet, NotPetya, or military-specific APT campaigns.
- Threat Intelligence Briefings – adversary TTPs (tactics, techniques, procedures).
- Secure Architecture Blueprints – hardened systems for command-and-control.
- Penetration Testing Guides – tailored for classified networks and mission systems.
6. Policy & Legal Materials
- Cyber Rules of Armed Conflict – interpretations of Geneva Conventions in cyberspace.
- National Security Directives – executive-level guidance on cyber defense posture.
- Procurement Clauses – contract language requiring cyber resilience in military supply chains.
- Ethical Guidelines – balancing offensive cyber capabilities with proportionality and necessity.
The above military-related materials cover a wide range of texts, among others: strategic military doctrine, training and education documentations, regulatory and compliance frameworks, policy and legal documents, hands-on technical manuals, tools and artifacts. They often overlap with the compliance worksheets and supplier contract clauses that you have been working on.
Valuable Help Provided to Canadian Innovative SMEs by NRC IRAP
The Industrial Research Assistance Program (IRAP) of the National Research Council of Canada (NRC) could help eligible Canadian innovative SMEs address their cybersecurity requirements by providing funding for compliance readiness and certification audits.
If you would like more information about NRC IRAP, please consult https://nrc.canada.ca/en/support-technology-innovation/about-nrc-industrial-research-assistance-program or reach out to your NRC IRAP Industrial Technology Advisor.
Finally, where could Canadian suppliers or contractors read the official guidance documentations and undertake appropriate registration or certification if required? Abridged below is a non exhaustive list of reliable resources and references.
Resources and References
- Government of Canada – Canada Controlled Goods Program (CGP) and Controlled Goods Regulations (CGR)
- Government of Canada – Canadian Program for Cyber Security Certification (CPCSC) and Canadian Centre for Cyber Security
- Government of the USA – US DFARS 252.204‑7012, NIST SP 800‑171, and CMMC Resources
- Government of the USA – ITAR and EAR Guidance from US State and Commerce Departments.
- Government of the UK – Ministry of Defence (MOD) Cyber Security Model and National Cyber Security Centre (NCSC) Supply‑Chain Guidance; Cyber Essentials Scheme.
- Government of Canada – Canadian Centre for Cybersecurity (CCC).IT Security Risk Management: A Lifecycle Approach (ITSG-33).IT security risk management: A lifecycle approach (ITSG-33) – Canadian Centre for Cyber Security
- Government of Canada – National Security and Defence. Security Requirements for Contracting with the Government of Canada.Cyber Security Certification for Defence Suppliers in Canada.Cyber security certification for defence suppliers in Canada – Canada.ca
- Government of the USA – US Department of War – Chief Information Officer.Cybersecurity Maturity Model Certification (CMMC) Resources and Documentation: Internal, External and Additional Resources.CIO – CMMC Resources & Documentation
- Government of the USA – Defence Federal Acquisition Regulation Supplement (DFARS).252.204-7012 Safeguarding Covered Defense Information and Cyber Incident Reporting.252.204-7012 Safeguarding Covered Defense Information and Cyber Incident Reporting. | Acquisition.GOV
- Government of the USA – Federal Acquisition Regulation (FAR).52.204-21 Basic Safeguarding of Covered Contractor Information Systems.52.204-21 Basic Safeguarding of Covered Contractor Information Systems. | Acquisition.GOV
- Government of the UK – Ministry of Defence (MOD).Information on the Ministry of Defence Cybersecurity Model (CSM) Including the Standards and Guidance for Suppliers to Meet CSM Version 4.Cyber Security Model – GOV.UK
- IASME – The UK Ministry of Defence’s Official DCC Delivery Partner.Defence Cyber Certification (DCC) – A Comprehensive, Cyber Security Certification Framework for UK Defence Suppliers.Defence Cyber Certification – Defence Cyber Certification
- North Atlantic Treaty Organization (NATO).NATO Cyber Defence Policy. Hyperlink 1:Cyber defence | NATO Topic Hyperlink 2: NATO-110608-CyberdefencePolicyExecSummary.pdf
- US Defense Information Systems Agency (DISA).DISA Next Strategy: Fiscal Year 2025-2029.DISA Next: Strategy, Fiscal Year 2025 to 2029
- US Department of the Army – Central Army Registry.FM-312: Cyberspace and Electromagnetic Warfare Operations – September 2025. 238 pages document officially published by the US Department of the Army headquartered at 101 Army Pentagon, Washington, D.C. 20310-0101. This publication supersedes FM-312 dated 24thof August 2021. Document approved for public release with unlimited distribution. FM 3-12 (Signature Draft)
- Canadian Armed Forces Cyber Command (CAFCYBERCOM).Canadian Armed Forces CyberOperations Doctrine. Canadian Armed Forces Cyber Command (CAFCYBERCOM) – Canada.ca
- The Digital Manufacturing and Cybersecurity Institute (MxD).Playbook for CMMC 2.0 Level 1.Headquartered in Chicago, Illinois (USA), The Digital Manufacturing and Cybersecurity Institute (MxD) is a public-private partnership established under the authority of the US Department of War. MxD-CMMC-2.0-Playbook.pdf
- The Cyber AB – CMMC Accreditation.CMMC Assessment Process Version 2.0.Headquartered in Maryland (USA), The Cyber AB is an independent accreditation body responsible for overseeing the Cybersecurity Maturity Model Certification (CMMC). It serves as the sole authorized non-governmental partner of the US Department of War in implementing and managing CMMC assessments and certifications. CMMC Assessment Process v2.0.pdf
- National Research Council of Canada (NRC) Industrial Research Assistance Program (IRAP).About the NRC Industrial Research Assistance Program: Helping Your Business Grow Through Innovation.About the NRC Industrial Research Assistance Program – National Research Council Canada
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Newsletter Executive Editor:
Alan Bernardi, SSCP, PMP, Lead Auditor for ISO 27001, ISO 27701 and ISO 42001
B.Sc. Computer Science & Mathematics, McGill University, Canada
Graduate Diploma in Management, McGill University, Canada
Author-Amazon USA, Computer Scientist, Certified Professional Writer & Translator:
Ravi Jay Gunnoo, C.P.W. ISO 24495-1:2023 & C.P.T. ISO 17100:2015
B.Sc. Computer Science & Cybersecurity, McGill University, Canada
B.Sc. & M.A. Professional Translation, University of Montreal, Canada
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