Cybersecurity & Supply Chain (Parts 4 / 39 / DFARS 204)

FAR 52.204-25

Prohibition on Contracting for Certain Telecommunications and Video Surveillance Services or Equipment

Contract clause that prohibits the Government from (Part A) procuring covered telecom equipment/services as a substantial or essential component of any system, and prohibits the awardee from (Part B) using such equipment/services anywhere in its enterprise. Covers Huawei, ZTE, Hikvision, Dahua, Hytera, plus subsidiaries and affiliates and any entity owned or controlled by China.

FAR / DFARS Part
FAR Part 4 — Administrative and Information Matters
Prescribed By
FAR 4.2105(a) — Required in all solicitations and contracts.
Flow-down to Subcontracts

Yes — must be flowed down to all subcontracts at all tiers, including commercial-item subs.

What this clause requires

  • 1Awardee shall not provide to the Government any covered telecom equipment or services.
  • 2Awardee shall not use covered telecom equipment or services in any of its systems (Part B).
  • 3Report any identification of covered equipment within 1 business day of discovery; full report within 10 business days.
  • 4Flow down 52.204-25 to all subcontracts including commercial-item subs.
  • 5Maintain ongoing supply-chain risk management to detect new covered items.

When this clause applies

Every Federal contract. Applies regardless of dollar value or commercial-item designation. Includes both Federal and non-Federal use of the equipment.

Common pitfalls

!Failure to flow down to lower-tier subs — primes are responsible for sub compliance under 52.204-25(d).
!Missing the 1-day initial / 10-day full report deadlines after discovery — separate prohibited-act with its own penalties.
!Confusing 'substantial or essential component' (broad) with 'incidental use' (narrow); DoD reads the term broadly.
!Allowing facility-security cameras to remain after award — covered CCTV on the premises violates Part B.

Proposal-team checklist

  • ☐Run annual supply-chain attestation across all subs and suppliers; document the attestation.
  • ☐Include 52.204-25 flow-down language in every subcontract template — not just Federal subs.
  • ☐Train procurement, facilities, and IT teams on the covered-entity list (it grows over time).
  • ☐Establish a discovery-to-report runbook: who notifies the CO, what data goes in the report, who signs.

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FAQ

Can the prohibition be waived?

Yes, executive-branch waivers under 41 CFR 102-117, but each waiver is narrow and time-limited. Most agencies treat waivers as last resort.

Does this apply to small business?

Yes. No size carve-out. Even micro-purchase commercial buys are covered.

What if a subcontractor refuses to flow down?

Then you cannot use that subcontractor on a Federal contract subject to 52.204-25. Procurement should require a signed flow-down acknowledgment before any subcontract award.

Related clauses

FAR 52.204-24
Section 889 Part B Representation
FAR 52.204-26
Covered Telecom — Annual SAM Rep
DFARS 252.204-7012
Cyber Incident Reporting (DoD)
FAR 52.204-27
Prohibition on ByteDance Apps (TikTok)

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Reference content based on the Federal Acquisition Regulation and DFARS as of June 2026. Always verify the current clause text at acquisition.gov before relying on it for an actual submission. Educational reference; not legal advice.