Navigating the Changes in NIST SP 800-171 Rev. 3 – What You Need to Know

April 23, 2024

Navigating the Changes in NIST SP 800-171 Rev. 3 – What You Need to Know

By Sajid Shafique

With new threats emerging almost daily, keeping your organization secure is a constant challenge, especially for government contractors who must navigate the ever-evolving labyrinth of compliance requirements. Previously, we have explained NIST SP 800-171 Compliance and described the basics required to achieve compliance. Our latest blog will summarize the changes introduced in revision 3 of the NIST SP 800-171. As the threat landscape evolves, so does the framework designed to safeguard sensitive information, and as such, staying up to date about the latest requirements is crucial for organizations aiming to maintain resilience in the face of new cyber threats.

NIST SP 800-171 Rev. 3, currently in its Final Draft version, has several changes from its predecessor. These changes aim to provide more clarity and flexibility for users and align the publication with other NIST standards.

The significant changes in the latest revision are outlined below: 

  • 1. Streamlined Introductory Information

NIST SP 800-171 Rev. 3 takes a streamlined approach to the publication's introductory language, intending to enhance clarity and improve users' understanding. 

  • 2. Elimination of Basic and Derived Security Requirements Distinction

The distinction between basic and derived security requirements has been eliminated in Revision 3 to simplify the overall structure and make the publication more user-friendly.

  • 3. Alignment with NIST SP 800-53, Revision 5

The security requirements and families in Revision 3 have been updated to align with the latest NIST SP 800-53, Revision 5. This ensures the controls stay abreast of the most recent developments and align with the NIST SP 800-53B moderate control baseline.

  • 4. Increased Specificity for Improved Effectiveness

To remove ambiguity, improve implementation effectiveness, and clarify assessment scopes, Revision 3 increases the specificity of security requirements. This aims to provide a more precise roadmap for organizations in implementing and assessing controls.

  • 5. Removal of NFO Control Tailoring Category

The final draft of Revision 3 eliminates the NFO (Non-Federal Organization) control tailoring category.

  • 6. Introduction of Other Related Controls (ORC) Category

Revision 3 introduces the ORC category, which is specifically designed for controls addressed by other related controls. This enhances the comprehensiveness of control coverage.

  • 7. Introduction of Organization-Defined Parameters (ODP)

Revision 3 introduces ODP in selected security requirements. ODP provides organizations with increased flexibility in managing risk. The new version has also defined more explicit responsibility guidelines for assigning ODP values.

  • 8. Addition, Removal, and Consolidation of Security Requirements

In Revision 3, Security requirements have been added, deleted, or changed to reflect controls & families in SP 800-53 Rev 5 and moderate baseline in 800-53B.

The final draft version of Revision 3 has 96 requirements, a significant reduction from Revision 2's 110. However, the number of control items has increased considerably, as each requirement in Revision 3 has multiple control items compared to Revision 2's one control item.

NIST has added Transition Mapping Tables and Change Analysis spreadsheets, which are supplemental resources available separately on the NIST publication details website, to describe the changes made to the security requirements in Revision 3.

  • 11. Sequencing of Content

Content in the discussion sections has been sequenced to align with individual parts of the requirements, enhancing the overall logical flow.

  • 12. Modified Tailoring Categories

Selected controls and control items have undergone modifications in their tailoring categories for improved effectiveness.

  • 14. Prototype CUI Overlay:

NIST has developed a prototype CUI overlay using tailored controls in SP 800-53 Rev 5, which is available separately on the NIST publication details website as an additional resource for users.

  • 15. Numbering Consistency

Leading zeros have been added to security requirement numbers for greater consistency with SP 800-171, Revision 3, and SP 800-171A numbering formats. This adjustment supports the usage of automated compliance tools.

In conclusion, the final draft version of NIST SP 800-171, Revision 3, introduces numerous improvements to ensure better alignment with current cybersecurity standards and enhanced usability for organizations aiming to implement robust security controls. Given the complexity involved with the process, one crucial step organizations may take is to start working with a trusted third party like Idenhaus, which understands the latest NIST SP 800-171 requirements inside and out and can help streamline the process and ensure compliance.

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