NIST 800-171 R2 To R3 Transition Guide

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.

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."

From a NIST 800-171 perspective, this means NIST 800-171 Rev3 will be expected to be used for contracts going forward and at that time NIST 800-171 Rev 2 will be deprecated (outdated).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. 

Seeing is believing when you look at the differences between NIST 800-171 R2 and R3. The new content in R3 is expected to be a heavy lift by many in the Defense Industrial Base (DIB), but ComplianceForge's NIST 800-171 & CMMC compliance solutions are an affordable and editable collection documentation templates that can help ease the transition to R3.

ComplianceForge provides a free resource for organizations migrating from NIST 800-171 R2 to R3. This guide provides an Assessment Objective (AO)-level analysis to address differences:

• 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.).