System Use Notification is the login banner requirement. Before a user is granted access to a system that handles Controlled Unclassified Information (CUI), the system displays a message with privacy and security notices consistent with applicable CUI rules. It is one of the simplest requirements in the Access Control family to implement, because it is a single statement with a single assessment objective and no Organization-Defined Parameters (ODPs). It is also one of the easiest to overlook, because the banner has to say the right things and appear in the right place, not just exist. It is closely related to Rules of Behavior (03.15.03), which governs what users agree to when they use the system.
A common difficulty with this requirement is treating any login message as sufficient. The requirement is specific: the notice has to carry privacy and security content consistent with applicable CUI rules, and it has to be displayed before access is granted, not after login. A generic "authorized users only" banner that does not reflect the CUI rules that apply to your contract does not satisfy the objective.
Where things stand for companies facing the transition from NIST 800-171 R2 to R3:
The following is reproduced verbatim from NIST 800-171 R3, requirement 03.01.09 System Use Notification. Only the formatting has been adjusted for readability. This is a single statement with no lettered parts:
The source control is AC-08 from NIST 800-53. There are no Organization-Defined Parameters (ODPs). Per the NIST discussion, notifications can be implemented as messages or warning banners displayed before individuals log in to a system that processes, stores, or transmits CUI, they are used for access via logon interfaces with human users and are not required where no human interface exists, and posters or other printed materials may be used in lieu of an automated message. The discussion also suggests considering whether a secondary notification is needed to reach applications or other resources after the initial network logon. You can read the requirement directly at NIST 800-171 R3, 03.01.09 (p. 13).
None (0). Requirement 03.01.09 contains no bracketed assignment, so there is no organization-defined value to select and nothing for the DoD to specify. The requirement applies as written.
Your System Security Plan (SSP) narrative for 03.01.09 therefore records how the requirement is implemented rather than a parameter you chose.
NIST 800-171A R3 breaks 03.01.09 into one (1) determination statement, and it has no Organization-Defined Parameters (ODPs). The AO is:
The single objective bundles three testable facts: the message exists, its content carries privacy and security notices consistent with applicable CUI rules, and it appears before access is granted. An assessor will check all three, so a banner that displays after login, or one whose content does not reflect the applicable CUI rules, will not satisfy the objective. The full guidance on assessment methods and objects, is in NIST 800-171A R3, 03.01.09 (p. 15).
Examine: access control policy and procedures; privacy and security policies, procedures for system use notification; documented approval of system use notification messages; system audit records; user acknowledgements of system use notification messages; system design documentation; system configuration settings; system use notification messages; system security plan.
Interview: personnel with information security responsibilities; legal counsel; system developers; system administrators.
Test: mechanisms for implementing system use notifications.
03.01.09 maps from NIST 800-171 R2 requirement 3.1.9 (provide privacy and security notices consistent with applicable CUI rules):
Mapped against the one (1) AO, it is direct (minimal effort), with no net-new AOs and none with no mapping. This is a clean carry-forward. The concept, the intent, and the source control (AC-08) are unchanged. R3 consolidated the R2 objectives into a single determination statement, so if you satisfied 3.1.9 you are almost certainly satisfying 03.01.09, provided your banner content still reflects the CUI rules that apply to your current contract.
Source Control in NIST 800-53 R5:
Secure Controls Framework (SCF) Crosswalk
Organizations running a single control set across multiple frameworks can satisfy 03.01.09 through the following SCF controls:
The crosswalks from NIST 800-171 R3 and NIST 800-171A R3 to the SCF are available at no cost through the SCF Set Theory Relationship Mapping (STRM): https://securecontrolsframework.com/start-here/set-theory-relationship-mapping-strm. The STRM also carries the relationship type for each mapping (Equal, Subset Of, Intersects With), which tells you whether an SCF control fully satisfies the requirement or only part of it. Mapping above taken from SCF 2026.3.
The following are issues teams may encounter rather than certainties. They are about content and placement, each of which needs documented evidence of due diligence and due care such as policies, standards, procedures, and configuration screenshots:
Reasonable objective evidence for an assessment is often subjective. The following examples of evidence to address NIST 800-171 R3 03.01.09 are sourced from the SCF Evidence Request List (ERL), available at https://securecontrolsframework.com/free-content/scf-download. These ERL artifacts are mapped to NIST 800-171 R3 03.01.09 through SCF controls. They establish a starting point for discussions on what an organization needs to have for evidence of due diligence and due care to withstand external scrutiny by an assessor or regulator.
Alongside these, keep the System Security Plan (SSP) narrative for 03.01.09.
With the single AO mapping directly and nothing net new, 03.01.09 is one of the quickest requirements to satisfy. A realistic sequence:
How many assessment objectives does NIST 800-171 R3 03.01.09 have? NIST 800-171A R3 breaks 03.01.09 into one (1) assessment objectives. An assessor works through each one separately, so each needs its own evidence.
Which NIST 800-53 R5 control does NIST 800-171 R3 03.01.09 come from? AC-08.
How many Organization-Defined Parameters (ODPs) does NIST 800-171 R3 03.01.09 have? None (0). The requirement contains no bracketed assignment, so there is no organization-defined value and nothing for the DoD to specify.
Where does NIST 800-171 R3 03.01.09 sit in the NIST 800-171 R3 Kill Chain? Phase 12, Secure Baseline Configurations (SBC). The Kill Chain is a phased model for sequencing R3 implementation, and it assigns this requirement to that phase.
03.01.09 System Use Notification requires a login banner with privacy and security notices consistent with applicable CUI rules, displayed before access is granted. It maps directly from R2 3.1.9 as a single assessment objective, so there is no net-new work. The recurring problem is treating any banner as compliant. Make the content reflect your applicable CUI rules, show it before access, and keep a screen shot and the supporting policy as evidence.
Authoritative sources:
Authoritative sources:
This guide reproduces U.S. Government text from NIST 800-171 R3 and NIST 800-171A R3. It is educational, not legal or assessment advice. Last reviewed: 2026-09-22.
