NIST 800-171 Revision 3: What You Need to Know

In May 2024, the National Institute of Standards and Technology (NIST) released the final publication of Special Publication 800-171 Revision 3. This revision, developed in coordination with the Department of Defense (DoD), introduces enhanced security requirements and updated control baselines to improve the safeguarding of Controlled Unclassified Information (CUI) within non-federal systems and organizations.

Although Rev. 3 provides a forward-looking view of anticipated security expectations, it is not currently authorized for use in demonstrating compliance with DFARS clause 252.204-7012. Contractors should use this release as a reference point to analyze upcoming changes and prepare for eventual integration into future iterations of DFARS and the Cybersecurity Maturity Model Certification (CMMC) framework.

We sat down with Chris Lyons, Sr. Product Manager at Apptega, to learn more about NIST 800-171 Rev. 3 and how organizations can prepare. Here's what you need to know.

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Differences between Rev. 2 and Rev. 3  

See this link for the NIST Analysis of changes.

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How to Leverage NIST SP 800-171 Revision 3 Today

Although NIST SP 800-171 Revision 3 is not yet mandated for DFARS or CMMC compliance, it was released to give organizations a head start in preparing for potential future updates to these frameworks. By evaluating their current cybersecurity posture against the revised controls and structure, companies can proactively identify areas needing improvement and begin aligning with anticipated requirements.

There are several strategic ways to begin using Revision 3 now, including:

• Parallel Assessments: Organizations conducting a new CMMC or NIST SP 800-171 Rev. 2 assessment can run a concurrent assessment using Rev. 3. This approach helps highlight differences between the frameworks and pinpoints additional requirements introduced in the latest revision.

• Gap Analysis Using Historical Data: Organizations can map findings from a previous Rev. 2 assessment to the corresponding controls in Rev. 3. This allows for efficient identification of control gaps and areas requiring enhanced implementation to meet the more rigorous expectations of Revision 3.

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Apptega’s NIST SP 800-171 Revision 3 Rollout

Company 1’s implementation of NIST SP 800-171 Rev. 3 consists of a comprehensive suite of tools designed to help organizations align with the updated framework and build toward full compliance. While Rev. 3 is not currently recognized for DFARS compliance and cannot be used for official DoD score submissions, it serves as a valuable resource for preparing for anticipated regulatory changes.

The rollout package includes:

• A detailed assessment aligned with the updated control set.

• The full Rev. 3 framework, structured for practical implementation.

• An automated task pack to streamline execution and tracking of control activities.

• Crosswalks and mappings to other frameworks, scheduled for release in Q1 2025.

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Conclusion

The NIST SP 800-171 Revision 3 compliance package is designed to help organizations take a proactive approach in preparing for the expanded requirements anticipated in future DFARS and CMMC updates. Although formal adoption may still be years away, early engagement with Rev. 3 enables a smoother transition and reduces the impact of future compliance shifts.

With Revision 3 introducing up to 32% more effort compared to Revision 2, early adoption allows companies to gradually close gaps and strengthen their security posture over time. Beyond compliance readiness, implementing these enhanced controls contributes to a more resilient and secure organization overall.

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