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What Is NIST 800-171
NIST Special Publication 800-171, often called NIST 800-171, is a set of requirements published by the National Institute of Standards and Technology that define how non-federal organizations must protect Controlled Unclassified Information (CUI) in their systems and operations. It is specifically designed for entities outside the U.S. Federal Government that handle, store, or transmit CUI, ensuring that such information maintains confidentiality, integrity, and availability appropriate to the level of risk.
Why NIST 800-171 Matters to Businesses
What Businesses Are Required to Do
- Every non-federal organization (contractors or subcontractors) that processes, stores, or transmits CUI under federal contracts must meet the NIST 800-171 requirements.
- Federal regulations such as DFARS 252.204-7012 require organizations working with the Department of Defense to comply with NIST 800-171.
- Organizations must also ensure that their subcontractors meet these protections when subcontractors handle CUI.
Implementation & Documentation Requirements
- Organizations must implement 110 security controls grouped into 14 control families.
- They must create and maintain documentation: a System Security Plan (SSP) that describes how each control is met, the environment, how CUI flows, what systems are involved.
- A Plan of Action and Milestones (POA&M) is required for any control that is not yet fully implemented.
- Periodic self-assessments or audits to verify that controls are in place and working.
Legal & Regulatory Requirements
- DFARS (Defense Federal Acquisition Regulation Supplement) mandates compliance for contractors in the DoD supply chain.
- Failure to comply may disqualify a business from federal contracts, lead to legal or financial penalties, and expose it to risk of data breaches with liability.
- Though NIST 800-171 itself does not have a formal certification process (as of Rev. 2), organizations may be required to report compliance or show evidence of compliance during contract bidding or continuing performance.
- Revision 3 of SP 800-171 (officially published May 2024) introduces enhanced controls; while not yet required for DFARS compliance, businesses should plan for potential adoption.
How NIST 800-171 Works: Structure & Process
Control Families
NIST 800-171 is organized into 14 control families, each covering specific topics. Some key families include:
- Access Control
- Awareness and Training
- Audit and Accountability
- Configuration Management
- Identification and Authentication
- Incident Response
- Maintenance
- Media Protection
- Personnel Security
- Physical Protection
- Risk Assessment
- Security Assessment
- System and Communications Protection
- System and Information Integrity
Each family contains multiple specific requirements (controls) that describe what must be done.
Assessment & Compliance Process
A typical process to achieve and sustain compliance might include:
- Scoping / CUI Mapping
- Identify what information qualifies as CUI in your organization.
- Map where CUI is stored, processed, or transmitted (systems, networks, people).
- Gap Analysis
- Compare current practices, controls, and policies against NIST 800-171 controls.
- Determine which controls are fully implemented, partially implemented, or missing.
- System Security Plan (SSP) Creation
- Document environment, policies, implementation of controls, responsibilities.
- Plan of Action & Milestones (POA&M)
- For controls not yet met, define remediation steps, resources needed, and deadlines.
- Control Implementation
- Technical, procedural, and administrative work: e.g. access control rules, monitoring/logging, staff training.
- Continuous Monitoring & Assessment
- Regular reviews, audits, self-assessments to ensure ongoing compliance.
- Update SSP, POA&M as needed.
- Preparing for Changes
- Revision 3 introduces new or updated controls; monitoring for regulatory updates (DFARS, CMMC) is important.
Real-World Examples & Use Cases
- A small company contracting with the DoD must process reports containing CUI. To bid, it must implement NIST 800-171: mapping where CUI is stored, tightening access control, auditing system logs, training staff, and providing a System Security Plan and POA&M.
- A subcontractor that provides parts or support for a larger defense contractor may be required by contract to demonstrate NIST 800-171 compliance even if it does not interact directly with all contract data, because the prime contractor must ensure subcontractors uphold protections.
- An educational or research institution receiving federal grants may have to safeguard CUI (e.g. research data, personally identifiable information) and follow NIST 800-171 controls to maintain eligibility and avoid funding issues.
- Vendor management: a vendor that handles CUI for its clients needs to demonstrate compliance both for contractual trust as well as regulatory obligations.
How Apptega Supports NIST 800-171 Compliance
- The NIST 800-171 Compliance Guide on Apptega provides an end-to-end resource including requirements, assessment processes, and best practices.
- Apptega’s platform includes a framework page for NIST 800-171 that enables automated assessments, gathering evidence, crosswalking with related frameworks (such as CMMC).
- Apptega offers resources on NIST 800-171 Revision 3 to help organizations prepare for the new controls, understand changes, and plan ahead.
- There are product demos such as “NIST 800-171 Compliance Simplified” which show how to use tools to organize assessments, track remediation, and prepare reports.
