Impact level and NSS terminology
| Level | System tier | Data classification | Cloud authorization path | Responsibility split note |
|---|---|---|---|---|
| IL4 | Non-NSS | Controlled Unclassified Information (CUI). No classified data. Excludes National Security Information (NSI). | FedRAMP Moderate baseline + DoD CC SRG IL4 overlay. Commercial cloud providers with DISA IL4 Provisional Authorization (PA). | CSP holds the platform PA. DoD component owns CUI configuration, access policy, and agency-side controls. Contractor systems require CMMC Level 2 for CUI processing. |
| IL5 | Non-NSS | CUI that requires higher protection than IL4: Privacy Act data, law enforcement sensitive, some export-controlled research. No classified data. | FedRAMP High baseline + DoD CC SRG IL5 overlay. Government-only cloud regions required (GovCloud or equivalent). DISA IL5 PA holders only. | Government-community cloud enforces tenant separation. CSP must operate in a US-person-only environment. DoD component retains agency-side controls identical to IL4 but with stricter access vetting. |
| IL5 | NSS | Unclassified National Security Systems. Processes NSI or directly supports NSS missions as defined in 44 USC 3552(b)(6): intelligence, cryptology, command and control of military forces, or weapons systems. | Government-only cloud region with DISA IL5 PA. CNSS Policy 22 applies. CNSSI 1253 security controls baseline applies in addition to DoD CC SRG. | DISA assumes a larger authorization role. The DoD component must document NSS boundary determination. CSP access restricted to cleared US persons; FOCI mitigation may apply. |
| IL6 | NSS | Classified information up to and including SECRET. Processed only in classified cloud environments or on-premises classified networks (SIPRNET). | Classified cloud (AWS C2S, Azure Government Secret, Oracle NSR) with DISA IL6 PA. No commercial cloud path. ATO issued by Component Authorizing Official for Classified (AOSC). | CSP operates as a cleared facility under DISA and DoD oversight. Component ISSO and AO remain accountable for classified workload configuration. Contractor access requires personnel security clearance (Secret or above) and facility clearance (FCL). |
The DoD RAI gap. The DoD Responsible AI Strategy and Implementation Pathway (2022) established five principles: Responsible, Equitable, Traceable, Reliable, and Governable (RETR-G). The strategy also created the Chief Digital and Artificial Intelligence Office (CDAO) to oversee implementation. Neither the strategy nor subsequent guidance assigns a named accountable party to each principle, specifies a measurable threshold for compliance, or defines the evidence a program office or contractor must produce. This schema fills that gap by binding each principle to a control, a persona, and an OCSF evidence pointer.
The CMMC gap. CMMC 2.0 (32 CFR Part 170, effective December 2024) governs the cybersecurity posture of defense contractors handling CUI and Federal Contract Information (FCI). Level 2 (110 practices from NIST SP 800-171) applies to contractors processing CUI. CMMC was designed around cybersecurity, not AI governance: it has no practice for model transparency, no threshold for human oversight of AI-generated decisions, and no evidence requirement for training data provenance. This schema provides the AI-specific layer that CMMC does not.
The NSS boundary problem. Many DoD AI deployments cross the NSS
boundary at runtime rather than at design time: a logistics model deployed at IL4
may later receive NSI as operational context, pushing it into NSS territory. The
nss_boundary field on every control in this schema requires the
deploying component to make and document an explicit classification determination
before deployment, not after.
The IL-split responsibility problem. The DoD Cloud Computing
Security Requirements Guide (CC SRG) defines what the CSP must do to earn a DISA
Provisional Authorization at each impact level. It does not define what the DoD
component or contractor must do on the agency side of that authorization. This schema
provides the component-side control catalog, parameterized by IL, with a
responsibility_split value on every control.
Responsibility split values
shared = documented split required; accountable party owns the split determination.
In this section
Schema design
Each control names one accountable persona and aligns to one or more of the five DoD RAI principles (Responsible, Equitable, Traceable, Reliable, Governable). DoD roles (CDAO, Program Manager, ISSO, Contracting Officer) map to SRF personas in the how-to guide, not in the JSON.
Four lifecycle stages: ACQ (acquisition), TEVV (test, evaluation, verification
and validation), OPS (operational monitoring), OVR (human oversight and remedy).
Every control also carries a responsibility_split value aligned to
the DoD CC SRG and a nss_boundary flag indicating whether the
control applies to Non-NSS, NSS, or both environments.
Machine-readable evidence uses OCSF event classes where a technical signal exists. Governance artifacts (TEVV plan, impact assessment, ATO package, CMMC evidence folder) are named explicitly so assessors and ISSOs know what documents to produce. IL6 evidence requirements note classified artifact handling.
Coverage by layer
ai-system-governance.
data-provider and application-developer.
application-developer and agentic-platform-provider.
ai-platform-provider and agentic-platform-provider.
model-provider.
GovRAMP crosswalk and CMMC practice-to-control mapping are on the roadmap. IL6 classified cloud providers (C2S, Azure Government Secret, Oracle NSR) will receive separate evidence pointer annotations once classified-environment OCSF implementation guidance is available.
Regulatory crosswalk