U.S. FAR 52.204-27 — Prohibition on a ByteDance Covered Application

Overview

U.S. FAR52.204-27 — Prohibition on a ByteDance Covered Application is afederal acquisition regulation clause that restricts the use ofcertain software applications, including TikTok and otherByteDance-owned products, on information technology used bygovernment contractors. The regulation aims to mitigate cybersecurityrisks and potential threats to data protection by preventing exposureto unauthorized or hostile foreign technology.

Published andenforced by the U.S. Federal Government under the Federal AcquisitionRegulation (FAR) system, FAR 52.204-27 applies to all entitiescontracting with federal agencies. Vendors, suppliers, andsubcontractors must comply with these requirements as part of thegovernment's broader risk management and supply chain securityinitiatives, complementing existing standards and regulationsrelevant to federal information systems.

To comply,organizations conduct security assessments of their IT environments,update internal controls, and implement policies prohibiting theinstallation or use of ByteDance-covered applications across devicesinvolved in federal contracts. This regulatory requirementstrengthens supply chain security, supports federal complianceprograms, and demonstrates due diligence in managing cybersecurityrisks within the government contracting ecosystem.

Why it Matters

FAR 52.204-27helps organizations mitigate national security risks by restrictingthe use of prohibited applications in federal information systems.

Key benefitsinclude:

•  Support regulatory compliance

Enableorganizations to meet federal requirements and avoid penaltiesassociated with unauthorized applications in government projects.

•  Enhance supply chain security

Reduce exposureto potential threats introduced through software supply chains andthird-party application providers.

•  Protect sensitive information

Limit the riskof unauthorized access or data exfiltration by prohibiting high-risksoftware on government networks.

•  Strengthen risk management

Improve theability to identify, assess, and address software-related securitythreats within organizational IT environments.

•  Promote operational integrity

Assurestakeholders that systems remain compliant and free from unauthorizedor untrusted applications, supporting reliable business operations.

How it Works

U.S. FAR52.204-27 establishes regulatory requirements that prohibit thepresence or use of ByteDance covered applications—includingTikTok—on any information technology used in federal contracts. Theframework sets forth compliance boundaries by clearly defining whatconstitutes a covered application, delineates scope according togovernment information systems, and outlines contractual obligationsfor federal contractors.

In practice,organizations interpret these requirements by inventorying devicesand systems to identify any use of prohibited applications, updatingsecurity policies, and deploying endpoint management tools to enforcerestrictions. Compliance teams typically conduct periodicassessments, monitor IT environments, and maintain documentation toverify removal or blocking of ByteDance software across manageddevices. Contractors integrate these activities into existinggovernance and security control programs to satisfy federalrequirements and demonstrate regulatory adherence.

UsingSmartSuite, organizations can implement FAR 52.204-27 by leveragingpolicy governance libraries tailored to regulatory mandates,configuring risk registers to track the prohibition’s impact, andmanaging compliance workflows. Evidence collection modules documentremoval actions, while compliance dashboards provide ongoingmonitoring and reporting on adherence, supporting audit readiness andcontinuous governance.

Key Elements

•  Scope of Prohibition

Specifies whichentities and contracting activities are subject to restrictionsregarding ByteDance covered applications.

•  Covered Application Definition

Defines thecriteria and characteristics that qualify an application as aByteDance covered application under this clause.

•  Contractor Responsibilities

Outlinesobligations for contractors, including ensuring compliance andmonitoring device usage within contract performance.

•  Enforcement and Monitoring Mechanisms

Describesmeasures for verifying contractor adherence and potential remediesfor non-compliance.

•  Waiver and Exception Criteria

Establishes theconditions and processes for requesting waivers or applying statutoryexceptions.

•  Applicability to Subcontractors

Clarifiesexpectations and flow-down requirements for subcontractors involvedin applicable federal contracts.

Framework Scope

U.S. FAR52.204-27 applies to federal contractors, subcontractors, and vendorswith access to government IT systems or data. The framework governsthe use of applications produced by ByteDance on informationtechnology assets managed for federal contracts, and is typicallyenforced to meet federal regulatory obligations and supportcompliance oversight for government procurement activities.

Framework Objectives

U.S. FAR52.204-27 establishes requirements to prevent unauthorized use ofByteDance covered applications on government information systems toenhance cybersecurity and regulatory compliance.

•  Safeguard federal information systems against potentialcybersecurity threats from prohibited applications

•  Strengthen governance and oversight of application usage inalignment with federal policies

•  Promote regulatory compliance with U.S. government security andrisk management mandates

•  Enhance data protection by minimizing risks introduced byunauthorized software

•  Support audit readiness through clear enforcement anddocumentation of security controls

•  Maintain operational resilience by reducing exposure to emergingprivacy and cybersecurity risks FAR 52.204-27 is a regulatoryrequirement focused on prohibiting certain applications for federalcontractors. While not a comprehensive cybersecurity framework, italigns with CMMC and NIST SP 800-171, which govern federalinformation protection. Organizations typically implement FAR52.204-27 to achieve regulatory compliance and maintain federalcontract eligibility.

Common Framework Mappings

FAR 52.204-27 isoften mapped to major cybersecurity and data protection frameworks tostreamline regulatory compliance, demonstrate adequate riskmanagement, and ensure consistent controls for federal contracteligibility.

Mappedframeworks include:

CIS CriticalSecurity Controls

FedRAMP

GDPR

ISO/IEC 27001

ISO/IEC 27002

NISTCybersecurity Framework (CSF)

NIST SP 800-53

PCI DSS

SOC 2

StateRAMP