Access Restrictions for Change controls who is allowed to make changes to the system in the first place. Configuration Change Control (03.04.03) governs how changes are reviewed and approved, and Access Restrictions for Change (03.04.05) restricts the physical and logical access needed to initiate those changes to qualified and authorized individuals. It is a single statement: define, document, approve, and enforce the physical and logical access restrictions associated with changes to the system. Per the NIST discussion, changes to hardware, software, or firmware can have significant security effects, so only qualified and authorized individuals should be permitted to access the system to initiate changes, and access restrictions can include software libraries, media libraries, workflow automation, and change windows.
A common difficulty with this requirement is enforcing logical access but never addressing the physical side, or defining restrictions without approving and enforcing them. R3 assesses physical and logical access separately, and for each it checks that the restriction is defined and documented, approved, and enforced. Skipping any of those pieces on either the physical or logical side leaves an objective open.
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 03.04.05 Access Restrictions for Change. Only the formatting has been adjusted for readability. This is a single statement with no lettered parts:
The source control is CM-05 from NIST 800-53. There are no Organization-Defined Parameters (ODPs). Per the NIST discussion, access restrictions include physical and logical access controls, software libraries, workflow automation, media libraries, abstract layers where changes are implemented into external interfaces rather than directly into the system, and change windows where changes occur only during specified times. You can read the requirement directly at NIST 800-171 R3, 03.04.05 (p. 29).
None (0). Requirement 03.04.05 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 03.04.05 therefore records how the requirement is implemented rather than a parameter you chose.
NIST 800-171A R3 breaks 03.04.05 into six (6) determination statements, and it has no Organization-Defined Parameters (ODPs). These AOs are:
The single statement expands into six (6) objectives because the physical and logical sides are assessed separately, and each side is checked for definition and documentation, approval, and enforcement. An assessor checks all six. The full guidance on assessment methods and objects, is in NIST 800-171A R3, 03.04.05 (p. 35).
Examine: configuration management policy and procedures; procedures for access restrictions for system changes; configuration management plan; system design documentation; system architecture; system configuration settings; logical access approvals; physical access approvals; access credentials; change control records; system audit records; system security plan.
Interview: personnel with logical access control responsibilities; personnel with physical access control responsibilities; personnel with information security responsibilities; system administrators.
Test: processes for managing access restrictions for system changes; mechanisms for supporting, implementing, or enforcing access restrictions associated with system changes.
03.04.05 maps from NIST 800-171 R2 requirement 3.4.5 (define, document, approve, and enforce physical and logical access restrictions associated with changes to organizational systems):
Mapped against the six (6) AOs, all six (6) are direct (minimal effort), with no net-new AOs and none with no mapping. This is a clean carry-forward. The concept, the wording, and the source control (CM-05) are effectively unchanged. If you satisfied R2 3.4.5, you are almost certainly satisfying 03.04.05, provided both the physical and logical restrictions are defined, approved, and enforced.
Source Control in NIST 800-53 R5:
Secure Controls Framework (SCF) Crosswalk
Organizations running a single control set across multiple frameworks can satisfy 03.04.05 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 covering both sides fully, 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 03.04.05 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 03.04.05 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 03.04.05.
With all six (6) AOs mapping directly, 03.04.05 is a light lift if both sides are covered. A realistic sequence:
How many assessment objectives does NIST 800-171 R3 03.04.05 have? NIST 800-171A R3 breaks 03.04.05 into six (6) 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 03.04.05 come from? CM-05.
How many Organization-Defined Parameters (ODPs) does NIST 800-171 R3 03.04.05 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 03.04.05 sit in the NIST 800-171 R3 Kill Chain? Phase 7, Data Protection Practices. The Kill Chain is a phased model for sequencing R3 implementation, and it assigns this requirement to that phase.
03.04.05 Access Restrictions for Change defines, documents, approves, and enforces the physical and logical access restrictions associated with changes to the system. It maps directly from R2 3.4.5 with all six (6) assessment objectives transitioning directly, so there is no net-new work. The recurring problem is covering logical access but neglecting physical, or defining restrictions without approving and enforcing them. Cover both sides fully, and keep the definitions, approvals, and enforcement 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.
