CUI questions
Can I use ChatGPT with CUI?
Short answer
Not with the standard ChatGPT plans. The standard commercial ChatGPT plans are not the FedRAMP offering. OpenAI says existing Enterprise workspaces cannot be converted to FedRAMP, so CUI work needs the separate FedRAMP workspace.
The FedRAMP version is ChatGPT Enterprise and API Platform for FedRAMP. This is the separate FedRAMP version of ChatGPT Enterprise and the API, certified at Moderate. Moderate is the baseline DFARS 252.204-7012 names for cloud providers handling covered defense information. You must use a newly provisioned FedRAMP workspace and the gov.api.openai.com endpoint. No DoD Impact Level is published.
For CUI, the ones with a "Yes, with conditions" answer are Azure OpenAI in Azure Government, OpenAI models in Amazon Bedrock (AWS GovCloud), ChatGPT Enterprise and API Platform for FedRAMP and Codex (desktop app and CLI) signed in to a FedRAMP workspace.
Generated from our dataset. Sources last re-checked Oct 17, 2026.
Why Moderate matters: DFARS 252.204-7012(b)(2)(ii)(D) says a contractor using an external cloud service provider for covered defense information must ensure the provider meets security requirements equivalent to the FedRAMP Moderate baseline and complies with paragraphs (c) through (g) of the clause (incident reporting, malicious software, media preservation, forensic access and damage assessment). Read the clause on acquisition.gov. A FedRAMP authorization addresses the first part; the (c) through (g) obligations are worth confirming in your contract with the vendor.
The sourced table
| AI offering | FedRAMP | DoD IL | Can I use it with CUI? | Source |
|---|---|---|---|---|
| Azure OpenAI in Azure Government | IL2, IL4, IL5 (IL5 needs customer-managed keys) | Yes, with conditions | fedramp.gov | |
| OpenAI models in Amazon Bedrock (AWS GovCloud) | IL4/IL5 for listed models | Yes, with conditions | aws.amazon.com | |
| ChatGPT Enterprise and API Platform for FedRAMP | Not established | Yes, with conditions | fedramp.gov | |
| Codex (desktop app and CLI) signed in to a FedRAMP workspace | Not established | Yes, with conditions | fedramp.gov | |
| ChatGPT Gov (self-hosted in your Azure tenant) | Unclear | Unclear | Unclear | openai.com |
| ChatGPT Plus, Business and standard Enterprise | Not listed | Not established | Only in a separate environment | fedramp.gov |
| Codex with a commercial ChatGPT plan | Not listed | Not established | Only in a separate environment | help.openai.com |
Every row links to its primary source and full page. Statuses change; open the source before you decide. How we verify.
Related questions
Can I paste CUI into ChatGPT Plus, Team or Enterprise?
Only in a separate environment. The standard commercial ChatGPT plans are not the FedRAMP offering. OpenAI says existing Enterprise workspaces cannot be converted to FedRAMP, so CUI work needs the separate FedRAMP workspace.
Is ChatGPT Enterprise FedRAMP version enough for DFARS 7012?
This is the separate FedRAMP version of ChatGPT Enterprise and the API, certified at Moderate. Moderate is the baseline DFARS 252.204-7012 names. The clause also requires the provider to meet paragraphs (c) through (g), so confirm those terms in your contract.
Can I convert my existing ChatGPT Enterprise workspace to FedRAMP?
Existing commercial ChatGPT Enterprise workspaces cannot be converted; OpenAI offers a one-time migration into a new FedRAMP workspace. Existing API organizations can be converted. Only Chat mode is available in the FedRAMP web app today.
Can I use ChatGPT Gov with CUI?
Unclear. ChatGPT Gov runs inside an agency's own Azure tenant, so its authorization depends on that environment and the agency's own ATO. We could not find a public authorization record specific to ChatGPT Gov, so we do not give a verdict.
Not legal advice. These answers describe what public authorization records and vendor documentation say, not whether your contract, data or configuration is compliant. Confirm with your contracting officer, assessor or counsel.
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