NIST 800-171 R2 To R3 Transition Guide

When NIST 800-171 R3 was releasesd, ComplianceForge teamed up with DEFCERT to write the NIST 800-171 R2 to R3 Transition Guide, an Assessment Objective (AO)-level analysis of NIST 800-171A to NIST 800-171A R3.

NIST 800 171 Rev 3 was released on 14 May 2024 and it contains significant changes from the NIST 800-171 Rev 2. As stated by Ron Ross from NIST, the official government requirements from the Office of Management and Budget (OMB) requires organizations to adopt the most current version of NIST 800-171 one year after its the new version's public release. From a NIST 800-171 perspective, this means NIST 800-171 Rev3 will be used for contracts going forward and starting in May 2025, NIST 800-171 Rev 2 will be deprecated (outdated). Therefore, it is essential for businesses to start now to implement required controls to comply with NIST 800-171 Rev 3. 

CIRCULAR NO. A-130: "For legacy information systems, agencies are expected to meet the requirements of, and be in compliance with, NIST standards and guidelines within one year of their respective publication dates unless otherwise directed by OMB. The one-year compliance date for revisions to NIST publications applies only to new or updated material in the publications. For information systems under development or for legacy systems undergoing significant changes, agencies are expected to meet the requirements of, and be in compliance with, NIST standards and guidelines immediately upon deployment of the systems."

Assessment Objective Level Analysis for NIST 800-171 R3

This transition guide provides an Assessment Objective (AO)-level analysis to address differences for NIST 800-171 R2 to R3:

• Over 1/3 are minimal effort (clear, direct mapping)
• Approximately 1/5 are moderate effort (indirect mapping)
• Approximately 1/2 are significant effort (no clear mapping or new AOs)

This guide also addresses the logical dependencies that exist from "orphaned AOs" that are not in NIST 800-171A R3, but a requirement to demonstrate evidence of due diligence and due care still exists for specific functions (e.g., maintenance operations, roles & responsibilities, inventories, physical security, etc.).