Let's cut straight to the point: if you're a defense contractor handling Controlled Unclassified Information (CUI), you need to understand SPRS affirmations: and you need to understand them right now.

This isn't some administrative checkbox. This is a legal certification with teeth. And if you get it wrong, you're not just risking a slap on the wrist. You're risking multi-million-dollar False Claims Act (FCA) liability and losing your eligibility to bid on DoD contracts.

So what exactly is an SPRS affirmation, why does it matter so much, and how do you make sure you're not the next contractor facing a seven-figure settlement?

What Is an SPRS Affirmation?

An SPRS Affirmation is an annual legal certification submitted by a senior company executive: your "affirming official": to the Supplier Performance Risk System (SPRS). When you sign it, you're attesting under penalty of law that:

  • Your organization has fully implemented all applicable CMMC security requirements
  • You will maintain those requirements throughout the contract period
  • Your attestation is accurate and based on documented evidence, not wishful thinking

This isn't a technical report. This isn't a self-assessment that stays internal. This is a legal document signed by a senior executive that goes into a government system tied to contract awards.

And here's the kicker: without a current SPRS affirmation, you cannot receive DoD contracts. Period. No affirmation = no contract award. No option exercise. No payment.

SPRS affirmation digital certification document with security shields for DoD contract compliance

Why This Is a Big Deal (And Getting Bigger)

The DoD isn't messing around anymore. Recent enforcement actions show exactly how seriously they're taking false or inaccurate SPRS affirmations:

  • April 2025: A defense contractor paid $4.6 million for submitting a false SPRS score
  • September 2025: A university paid $875,000 for similar violations

These weren't isolated incidents. These were deliberate signals from the Department of Justice that submitting inaccurate affirmations triggers False Claims Act liability.

Here's what that means in plain English: if you sign an affirmation claiming compliance when you know (or should know) you're not actually compliant, you're making a false claim to the federal government. And the False Claims Act allows for penalties of up to three times the damages plus additional fines.

This is career-ending, company-destroying stuff.

The Annual Requirement You Can't Ignore

SPRS affirmations aren't a one-and-done deal. They're required annually:

  • Upon achieving CMMC status (your first certification)
  • Every year thereafter to maintain eligibility
  • At the time of contract award (your affirmation must be current)
  • Before option exercise (if your contract has option periods)

Think of it like renewing your driver's license: except if you let it lapse, you lose your ability to compete for government contracts worth potentially millions of dollars.

And here's where it gets tricky: you can't just copy-paste last year's affirmation and call it good. Every year, you need to verify that your security controls are still implemented, still effective, and still meeting the current CMMC requirements.

Who Can Sign (And Who's Taking the Legal Risk)

The affirmation must be signed by an affirming official: typically a senior executive like your CEO, CFO, or President. This isn't something you can delegate to your IT manager or compliance coordinator.

Why? Because the DoD wants executive accountability. They want the person signing to have the authority and responsibility to ensure the organization is actually compliant.

When that executive signs, they're personally attesting to the accuracy of the certification. And if it turns out to be false? That executive is on the hook for the FCA liability.

This is why many defense contractors are suddenly very interested in having continuous, automated monitoring of their security posture. Because no executive wants to sign a legal document based on a point-in-time assessment that might already be outdated.

Executive reviewing CMMC compliance data for annual SPRS affirmation signing

The Conditional Status Trap

Here's a nuance that trips up a lot of contractors: CMMC Level 1 does not allow conditional status. You're either compliant or you're not. No POA&M. No 180-day grace period.

For CMMC Levels 2 and 3, you can have conditional status for up to 180 days while you're closing out a Plan of Action and Milestones (POA&M). But: and this is critical: you still need a current affirmation during that conditional period.

This creates a tricky situation: you're affirming compliance while simultaneously documenting gaps in your POA&M. How do you reconcile that?

The answer: your affirmation covers your current implemented controls and your documented remediation plan. But you better have rock-solid evidence that you're actively addressing those gaps and that they don't represent a material risk to CUI protection.

Because if the DoD decides your conditional status was actually non-compliance dressed up in paperwork? FCA liability is back on the table.

The "Reckless Disregard" Standard

Here's the part that keeps compliance officers up at night: you don't have to intentionally lie to trigger FCA liability. "Reckless disregard" for the truth is enough.

What does that mean?

  • Signing an affirmation without verifying your actual compliance status
  • Ignoring known security gaps or control failures
  • Relying on outdated assessments or incomplete documentation
  • Failing to investigate red flags before certification

If you sign an affirmation saying "we're compliant" when you haven't actually verified that your 110 CMMC requirements and 320 objectives are implemented and effective, that's reckless disregard. And it's enough to establish FCA liability.

This is why so many defense contractors are moving toward continuous monitoring architectures like CPE Level 2. Because annual point-in-time assessments aren't enough to give executives confidence that they can sign that affirmation without legal risk.

How Yoo-Jin AI Changes the Game

Traditional compliance approaches create a dangerous gap: you get assessed, you pass, you get your certification: and then what? How do you know you're still compliant six months later? Nine months later? The day before your affirmation is due?

Yoo-Jin AI continuously monitors over 1,500 checkpoints across your CPE Level 2 environment. That means:

  • Real-time visibility into your security posture 24/7/365
  • Automated detection of configuration drift or control failures
  • Immediate alerts when something changes that could affect compliance
  • Documented evidence of continuous compliance for your affirmation

When your affirming official sits down to sign that SPRS affirmation, they're not relying on a six-month-old assessment or crossing their fingers and hoping nothing changed. They have current, documented evidence that the security controls are implemented and effective right now.

That's the difference between reckless disregard and due diligence. That's the difference between FCA liability and peace of mind.

AI-powered continuous monitoring system tracking CMMC compliance checkpoints in real-time

The Unbreakable Approach

Here's what an unbreakable SPRS affirmation strategy looks like:

1. Start with verified compliance – Get your CPE Level 2 environment built right from day one, covering all 110 CMMC requirements and 320 objectives

2. Maintain continuous monitoring – Use Yoo-Jin AI to track 1,500+ checkpoints across your environment, ensuring nothing drifts out of compliance

3. Document everything – Every control implementation, every configuration change, every monitoring result gets documented for audit evidence

4. Review before affirmation – Before your affirming official signs, conduct a comprehensive review of your current security posture using real-time monitoring data

5. Submit with confidence – Your affirmation is backed by documented, continuous evidence: not outdated assessments or wishful thinking

This isn't just about checking a compliance box. This is about protecting your company from multi-million-dollar FCA liability while ensuring you can actually protect CUI the way the DoD requires.

The Bottom Line

SPRS affirmations are here to stay. They're required annually. They carry serious legal consequences if you get them wrong. And the enforcement environment is only getting tougher.

You cannot afford to treat this as just another piece of compliance paperwork. This is a legal certification signed by a senior executive that determines whether you can bid on DoD contracts and whether you face False Claims Act liability.

The good news? You don't have to navigate this alone. With the right architecture, continuous monitoring, and documented evidence, you can submit SPRS affirmations with confidence: knowing your security posture is not just compliant, but unbreakable.

Because in the defense industrial base, there's no substitute for absolute certainty when it comes to protecting CUI and maintaining contract eligibility.

Planet Security Inc.
Making defense contractors unbreakable since 1993
planetsecurity.net

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