The responsibility for applying Controlled Unclassified Information (CUI) markings and dissemination instructions primarily lies with the Authorized Holder of the information at the time of its creation. This includes federal agency personnel, contractors, and other third parties who create, handle, or disseminate CUI. The Authorized Holder must determine whether the information qualifies as CUI, categorize it appropriately, and apply the required markings and dissemination controls according to the CUI guidelines and the National CUI Registry
. Key roles involved in the process include:
- CUI Designating Officials : Individuals within federal agencies authorized to determine if information qualifies as CUI based on applicable laws and policies
- Information Owners/Data Stewards : Responsible for ensuring that CUI under their control is correctly marked and safeguarded
- Program Managers and Supervisors : Oversee compliance within their teams and provide guidance on CUI marking requirements
- Employees and Contractors : Must be trained to recognize, mark, and protect CUI properly
- CUI Program Managers/Coordinators : Develop policies, training, and oversee implementation of CUI marking and handling within organizations
The marking process involves identifying CUI, categorizing it according to the CUI Registry, and applying standardized markings on documents and media, including banner markings such as “CUI” and category-specific labels. Dissemination instructions must also be applied to control distribution, ensuring compliance with laws and government-wide policies
. In summary, the Authorized Holder —the person or entity creating or managing the information—is responsible for applying CUI markings and dissemination instructions, supported by designated officials and organizational roles to ensure proper handling and protection throughout the information lifecycle
