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How Do I Implement NIST 800-171 R3 03.04.01 Baseline Configuration?

NIST 800-171 R3 03.04.01 Baseline Configuration at a Glance

  • Family: 03.04 Configuration Management (CM)
  • Requirement ID: 03.04.01 Baseline Configuration
  • Assessment Objectives (AOs): Seven (7) total, including the one (1) Organization-Defined Parameters (ODPs) below and six (6) determination statements
  • Organization-Defined Parameters (ODPs): One (1), specified by the Department of Defense (DoD) for the Defense Industrial Base (DIB)
  • Source NIST 800-53 R5 Control: CM-02
  • NIST 800-171 R3 Kill Chain Phase: Phase 12, Secure Baseline Configurations (SBC)

Baseline Configuration is the first requirement in the Configuration Management (03.04) family, and it is the foundation the rest of the family builds on. A baseline configuration is a documented, formally reviewed, and agreed-upon specification of a system that serves as the basis for future builds, releases, and changes. Baseline Configuration (03.04.01) requires two things: develop and maintain a current baseline configuration of the system under configuration control, and review and update that baseline on a defined frequency and whenever system components are installed or modified. Per the NIST discussion, baseline configurations include information about system components, operational procedures, network topology, and the placement of components in the system architecture, and they reflect the current enterprise architecture.

A common difficulty with this requirement is treating a one-time build document as a baseline. A baseline is only useful if it is current, held under configuration control, and refreshed as the system changes. R3 also separated the inventory work that R2 bundled here into its own requirement (03.04.10), so 03.04.01 is now specifically about the configuration baseline, not the asset list.

Where things stand for companies facing the transition from NIST 800-171 R2 to R3:

  • The National Institute of Standards and Technology (NIST) withdrew R2 on May 14, 2024, the same day R3 was published. The withdrawal notice states that R2 "has been withdrawn (archived), and is provided solely for historical purposes," so it will never receive another correction or clarification from NIST.
  • R2 remains the contractual standard for the Department of Defense (DoD) and the Defense Industrial Base (DIB). Cybersecurity Maturity Model Certification (CMMC) assessments reference it directly: per Title 32 of the Code of Federal Regulations (CFR), section 170.14(c)(3), "the security requirements in CMMC Level 2 are identical to the requirements in NIST SP 800-171 R2."
  • The rulemaking points the other direction. The proposed Controlled Unclassified Information (CUI) rule for the Federal Acquisition Regulation (FAR), published June 23, 2026 as part of the Revolutionary FAR Overhaul, would apply CUI safeguarding requirements government wide rather than only to DoD contracts, and it sets the baseline at R3. That rule is not final, and DoD has separately signaled an interim rule to move CMMC to R3.

What Does NIST 800-171 R3 03.04.01 Actually Require?

The following is reproduced verbatim from NIST 800-171 R3, requirement 03.04.01 Baseline Configuration. Only the formatting has been adjusted for readability. This requirement has two (2) lettered parts:

  • a. Develop and maintain under configuration control, a current baseline configuration of the system.
  • b. Review and update the baseline configuration of the system [Assignment: organization-defined frequency] and when system components are installed or modified.

The source control is CM-02 from NIST 800-53. The bracketed assignment in part b is the Organization-Defined Parameter (ODP): the review and update frequency. Per the NIST discussion, maintaining baseline configurations requires creating new baselines as the system changes over time, and the baseline serves as the basis for future builds, releases, or changes. You can read the requirement directly at NIST 800-171 R3, 03.04.01 (p. 26).

What Are the Organization-Defined Parameters (ODPs) Associated with NIST 800-171 R3 03.04.01?

One (1) value sits inside this requirement. Depending on your contract, your organization may be permitted to define it. Organizations in the DIB subject to CMMC are not, because the DoD has defined it as policy.

The value below comes from Attachment A of the DoD Chief Information Officer (CIO) memorandum dated 10 April 2025 (signed David W. McKeown). The memo identifies each parameter by requirement sub-part, while NIST 800-171A R3 identifies the same parameter by ODP number. Both identifiers appear below so you can match your System Security Plan (SSP) language to either document.

  • ODP[01] (DoD memo identifier 03.04.01.b). the frequency of baseline configuration review and update is defined. DoD Position: at least every 12 months and after any significant incidents or significant changes occur.

The memo states that its values "will be updated as necessary," so confirm against the current version before writing them into policy.

What Are the Assessment Objectives (AOs) For NIST 800-171 R3 03.04.01?

NIST 800-171A R3 breaks 03.04.01 into seven (7) assessment objectives: one (1) Organization-Defined Parameter (ODP) and six (6) determination statements. These AOs are:

  • A.03.04.01.ODP[01]: the frequency of baseline configuration review and update is defined.
  • A.03.04.01.a[01]: a current baseline configuration of the system is developed.
  • A.03.04.01.a[02]: a current baseline configuration of the system is maintained under configuration control.
  • A.03.04.01.b[01]: the baseline configuration of the system is reviewed <A.03.04.01.ODP[01]: frequency>.
  • A.03.04.01.b[02]: the baseline configuration of the system is updated <A.03.04.01.ODP[01]: frequency>.
  • A.03.04.01.b[03]: the baseline configuration of the system is reviewed when system components are installed or modified.
  • A.03.04.01.b[04]: the baseline configuration of the system is updated when system components are installed or modified.

Part b becomes four (4) objectives because review and update are separate, and each is triggered both by the frequency and by component installation or modification. If you are a DoD contractor, the ODP is specified. Per the DoD-specified ODP value in ComplianceForge's NIST 800-171 R3 Transition Guide, the review and update frequency (ODP[01]) is at least every twelve (12) months and after any significant incidents or significant changes occur. The full guidance on assessment methods and objects, is in NIST 800-171A R3, 03.04.01 (p. 32).

Assessment Methods and Objects for NIST 800-171 R3 03.04.01

Examine: configuration management policy and procedures; procedures for the baseline system configuration; configuration management plan; enterprise architecture; system design documentation; system architecture; system configuration settings; system component inventory; change control records; system security plan.

Interview: personnel with configuration management responsibilities; personnel with information security responsibilities; system administrators.

Test: processes for managing baseline configurations; mechanisms for supporting configuration control of the baseline configuration.

How Does NIST 800-171 R3 03.04.01 Map From NIST 800-171 R2?

03.04.01 maps from NIST 800-171 R2 requirement 3.4.1 (establish and maintain baseline configurations and inventories of organizational systems, including hardware, software, firmware, and documentation, throughout the respective system development life cycles):

  • A.03.04.01.a[01] and A.03.04.01.a[02] map directly to R2 3.4.1[a], 3.4.1[b], and 3.4.1[c] (establishing and maintaining the baseline configuration).
  • A.03.04.01.ODP[01] and A.03.04.01.b[01] through b[04] map indirectly to elements of R2 3.4.1[c] (maintaining the baseline through review and update).

Mapped against the seven (7) AOs, two (2) are direct (minimal effort) and five (5) are indirect (moderate effort), with no net-new AOs and none with no mapping. The baseline configuration work carries forward, but R2 3.4.1 also covered the system inventory (3.4.1[d] through [f]). R3 moved that inventory work to System Component Inventory (03.04.10), so do not expect this requirement to cover your asset list. The indirect mapping on the review-and-update objectives means you should confirm your baseline maintenance cadence meets the R3 wording.

How Does NIST 800-171 R3 03.04.01 Map to NIST 800-53 R5 and the SCF?

Source Control in NIST 800-53 R5:

  • CM-02

Secure Controls Framework (SCF) Crosswalk

Organizations running a single control set across multiple frameworks can satisfy 03.04.01 through the following SCF controls:

  • CFG-02 Configuration Management Program
  • CFG-03.1 Baseline Tailoring
  • CFG-04 Secure Baseline Configurations
  • CFG-05 Configure Technology Assets, Applications and/or Services (TAAS) for High-Risk Areas
  • CFG-06 Approved Configuration Deviations
  • CFG-07 Baseline Configuration Reviews & Updates

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.

Common Pitfalls with NIST 800-171 R3 03.04.01

The following are issues teams may encounter rather than certainties. They are about currency and configuration control, each of which needs documented evidence of due diligence and due care such as policies, standards, procedures, and configuration screenshots:

  • A baseline is not a one-time document. A.03.04.01.a[02] requires the baseline to be maintained under configuration control, and b[01] through b[04] require review and update. A build sheet written once and never revisited does not satisfy these objectives.
  • Two triggers, two actions. The baseline must be reviewed and updated both on the defined frequency and when components are installed or modified. Doing the annual review but skipping updates after a component change leaves objectives open.
  • Inventory is elsewhere now. R3 moved the asset inventory to 03.04.10, so use this requirement for the configuration baseline and coordinate with 03.04.10 for the component list.
  • Define the frequency. For DoD work, the review and update frequency is at least every twelve months and after significant incidents or significant changes, so set and document it.

What Is Reasonable Evidence For NIST 800-171 R3 03.04.01?

Reasonable objective evidence for an assessment is often subjective. The following examples of evidence to address NIST 800-171 R3 03.04.01 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 03.04.01 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.

  • E-AST-12 Secure Baseline Configurations Reviews. A review process to ensure secure baseline configurations (sbc) are current and applicable (e.g., system configuration settings and associated documentation).
  • E-AST-13 Secure Baseline Configurations - Cloud-Based Services. Secure baseline configurations for all deployed types of cloud-based services or applications.
  • E-AST-14 Secure Baseline Configurations - Databases. Secure baseline configurations for all deployed types of databases.
  • E-AST-15 Secure Baseline Configurations - Embedded Technologies. Secure baseline configurations for all deployed types of embedded technologies.
  • E-AST-16 Secure Baseline Configurations - Major Applications. Secure baseline configurations for all deployed types of major applications.
  • E-AST-17 Secure Baseline Configurations - Minor Applications. Secure baseline configurations for all deployed types of minor applications.
  • E-AST-18 Secure Baseline Configurations - Mobile Devices. Secure baseline configurations for all deployed types of mobile devices.
  • E-AST-19 Secure Baseline Configurations - Network Devices. Secure baseline configurations for all deployed types of network devices.
  • E-AST-20 Secure Baseline Configurations - Server Class Systems. Secure baseline configurations for all deployed types of server-class operating systems.
  • E-AST-21 Secure Baseline Configurations - Workstation Class Systems. Secure baseline configurations for all deployed types of workstation-class operating systems.
  • E-AST-27 Configuration Management. Standardized configuration management practices.
  • E-AST-33 Tailored Baselines. Documented evidence exists for tailored baseline configurations to address unique business and/or technical requirements (e.g., kiosk, hazardous environments, etc.).

Alongside these, keep the System Security Plan (SSP) narrative for 03.04.01 recording the ODP values you adopted.

Timeline Considerations for NIST 800-171 R3 03.04.01

With two (2) AOs mapping directly and five indirectly, 03.04.01 is a moderate lift centered on baseline maintenance. A realistic sequence:

  1. Develop the current baseline configuration of the system and place it under configuration control (A.03.04.01.a[01] and a[02]).
  2. Define the review and update frequency (A.03.04.01.ODP[01]). For DoD contracts, adopt at least every twelve months and after significant incidents or significant changes. For non-DoD scopes, define and document your own.
  3. Review and update the baseline on that frequency (A.03.04.01.b[01] and b[02]).
  4. Review and update the baseline when components are installed or modified (A.03.04.01.b[03] and b[04]).
  5. Coordinate with 03.04.10 for the system component inventory.
  6. Collect evidence for all seven (7) AOs, including the baseline under version control and dated review and update records.

Frequently Asked Questions About NIST 800-171 R3 03.04.01

What value does the DoD require for the organization-defined parameter in NIST 800-171 R3 03.04.01? R3 leaves the value to the organization. For the DIB, the DoD set it in the 10 April 2025 memorandum under ODP identifier 03.04.01.b: at least every 12 months and after any significant incidents or significant changes occur.

How many assessment objectives does NIST 800-171 R3 03.04.01 have? NIST 800-171A R3 breaks 03.04.01 into seven (7) assessment objectives: one (1) Organization-Defined Parameters (ODPs) and six (6) determination statements. An assessor works through each one separately, so each needs its own evidence.

Which NIST 800-53 R5 control does NIST 800-171 R3 03.04.01 come from? CM-02.

Where does NIST 800-171 R3 03.04.01 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.

Bottom Line on NIST 800-171 R3 03.04.01

03.04.01 Baseline Configuration develops and maintains a current, configuration-controlled baseline and keeps it current on a defined frequency and after component changes. It maps from R2 3.4.1 with the baseline objectives transitioning directly and the review-and-update objectives indirectly, and R3 moved the inventory work to 03.04.10. The recurring problem is a static build document. Put the baseline under configuration control, set the review frequency (for DoD, at least every twelve months and after significant incidents or changes), and update it on that schedule and after component changes.

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Authoritative sources:

This guide reproduces U.S. Government text from NIST 800-171 R3 and NIST 800-171A R3 and references the DoD ODP memorandum of 10 April 2025. It is educational, not legal or assessment advice. Last reviewed: 2026-09-22.