Partial CUI Compliance
1 NIST 800-171 gaps detected. Commercial DocuSign is NOT FedRAMP authorized. Most contractors use the commercial version. If contracts contain CUI, the government version is required.
DocuSign (Commercial)
by DocuSign
FedRAMP Status
Not FedRAMP Authorized
Impact Level
N/A
Category
E-Signature & Document Management
Overview
Commercial DocuSign is the standard e-signature platform used by most businesses. It is NOT FedRAMP authorized. If contracts, proposals, or documents being signed contain CUI, contractors must use DocuSign Government or Adobe Sign Government instead.
CUI Risk Assessment
Commercial DocuSign is NOT FedRAMP authorized. Most contractors use the commercial version. If contracts contain CUI, the government version is required.
Deployment & Architecture
Deployment Model: Cloud SaaS (vendor-hosted)
DocuSign (Commercial) has no FedRAMP authorization on record. DFARS 252.204-7012(b)(2)(ii)(D) requires an external cloud service provider to meet security requirements equivalent to the FedRAMP Moderate baseline — an authorization is the straightforward way to show that, but it is not the only one. Without one, the burden is on you to establish, document, and defend equivalency, and to meet the clause's incident-reporting and media-preservation obligations. Most contractors find an authorized alternative cheaper than carrying that burden.
Migration Checklist
- 1ISSO must immediately update the authorization boundary diagram to exclude DocuSign Commercial from CUI processing workflows and document this boundary violation in the current POA&M.
- 2Contracts officer must conduct a comprehensive review of all active contracts and amendments to identify which documents contain CUI that were processed through DocuSign Commercial within the past 12 months.
- 3ISSO must procure DocuSign Government Cloud or Adobe Sign Government licenses through a FedRAMP authorized vendor, ensuring the selected service operates within FedRAMP boundaries.
- 4System administrator must configure API access to export all historical signature data from DocuSign Commercial while ensuring CUI data remains encrypted during the export process.
- 5Legal counsel must review all signature workflows to ensure compliance with DFARS 252.204-7012 requirements for CUI protection during the migration period.
- 6ISSO must update the System Security Plan to document the replacement e-signature solution and its inherited FedRAMP controls, removing references to the commercial DocuSign service.
- 7Training coordinator must develop user training materials highlighting differences between commercial and government cloud interfaces, particularly CUI handling requirements.
- 8System administrator must configure the new government cloud platform with appropriate user roles, access controls, and audit logging to meet NIST 800-171 requirements.
- 9ISSO must establish procedures for validating that all future documents processed through the signature platform undergo CUI classification review before processing.
- 10Compliance officer must close existing POA&M entries related to DocuSign Commercial usage and provide evidence of successful migration to DCMA for the next CMMC assessment.
NIST 800-171 Violations
Using DocuSign (Commercial) for CUI without FedRAMP authorization may violate these NIST 800-171 controls:
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FedRAMP Compliant Alternatives
Related Compliance Assessments
Frequently Asked Questions
Is commercial DocuSign compliant for defense contracts?
If the documents being signed contain CUI, no. Commercial DocuSign is not FedRAMP authorized. Use DocuSign Government (FedRAMP Moderate) for CUI-containing documents.
How do I know if my documents contain CUI?
Review your contract for CUI markings, DFARS 7012 clauses, and controlled information categories. Technical data, source selection information, and contractor proprietary data marked as CUI require FedRAMP authorized handling.
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This DocuSign (Commercial) CUI review flags the gaps. The next step is a compliance architecture review where we map your data flows to FedRAMP-authorized alternatives and CMMC-aligned controls.
Schedule architecture reviewRelated: how much CMMC certification costs — DoD’s own priced figures