Threat & Research Team Blog

Can ITAR Be CUI? Why ITAR Could Be in Scope for your CMMC Assessment
Ross Seay Ross Seay

Can ITAR Be CUI? Why ITAR Could Be in Scope for your CMMC Assessment

Any defense contractors mistakenly believe ITAR-controlled data sits outside the boundaries of CMMC Level 2 — but that assumption could cost you your certification.

In reality, the National Archives and Records Administration (NARA) confirms that certain ITAR-regulated information qualifies as Controlled Unclassified Information (CUI Specified). That means if your organization handles ITAR data, it’s likely in scope for your CMMC assessment — and must meet strict safeguarding and dissemination requirements.

In this article, we explain how ITAR and CUI overlap, what the CUI Registry actually says, and why treating ITAR as CUI is both the safest and most compliant path forward for defense contractors.

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