NIST 800-171 R3 03.06.04 Incident Response Training at a Glance
- Family: 03.06 Incident Response (IR)
- Requirement ID: 03.06.04 Incident Response Training
- Assessment Objectives (AOs): Eleven (11) total, including the four (4) Organization-Defined Parameters (ODPs) below and seven (7) determination statements
- Organization-Defined Parameters (ODPs): Four (4), specified by the Department of Defense (DoD) for the Defense Industrial Base (DIB)
- Source NIST 800-53 R5 Control: IR-02
- NIST 800-171 R3 Kill Chain Phase: Phase 10, Incident Response (IR)
Incident Response Training makes sure the people who have to act during an incident actually know what to do. It is effectively new for R3, since incident response training was an assumed control in R2 rather than a separately assessed one. Incident Response Training (03.06.04) has two (2) parts: provide incident response training to system users consistent with their assigned roles at defined moments, and review and update the training content on a defined frequency and after defined events. Per the NIST discussion, the content and level of detail match the role: users may only need to recognize an incident and know whom to call, system administrators may need to know how to handle incidents, and incident responders may need training on data collection, forensics, reporting, and recovery.
A common difficulty with this requirement is assuming general security awareness training covers it. It does not. R3 expects role-appropriate incident response training delivered when someone takes on a response role or gains access, refreshed on a schedule, and kept current after events. It follows the same structure as the awareness and training family, and incident response training for users can be delivered as part of Role-Based Training (03.02.02). For Department of Defense (DoD) contractors, the timing and frequency parameters are specified.
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 The withdrawal notice states that R2 "has been withdrawn (archived), and is provided solely for historical purposes," so it will never receive another correction or clarification from NIST.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 03.06.04 Actually Require?
The following is reproduced verbatim from NIST 800-171 R3, requirement 03.06.04 Incident Response Training. Only the formatting has been adjusted for readability. This requirement has two (2) lettered parts, and part a has three numbered sub-parts:
- a. Provide incident response training to system users consistent with assigned roles and responsibilities:
- Within [Assignment: organization-defined time period] of assuming an incident response role or responsibility or acquiring system access,
- When required by system changes, and
- [Assignment: organization-defined frequency] thereafter.
- b. Review and update incident response training content [Assignment: organization-defined frequency] and following [Assignment: organization-defined events].
The source control is IR-02 from NIST 800-53. The bracketed assignments are the Organization-Defined Parameters (ODPs): the initial training time period, the recurring frequency, the content review frequency, and the triggering events. Per the NIST discussion, incident response training for users may be provided as part of 03.02.02, and events that may cause a content update include plan testing, response to an actual incident, and audit or assessment findings. You can read the requirement directly at NIST 800-171 R3, 03.06.04 (p. 40).
What Are the Organization-Defined Parameters (ODPs) Associated with NIST 800-171 R3 03.06.04?
Four (4) values sit inside this requirement. Depending on your contract, your organization may be permitted to define them. Organizations in the DIB subject to CMMC are not, because the DoD has defined them as policy.
The values below come 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 03.06.04.a.01). the time period within which incident response training is to be provided to system users is defined. DoD Position: ten (10) days for privileged users, thirty (30) days for all other roles.
- ODP[02] (DoD memo identifier 03.06.04.a.03). the frequency at which to provide incident response training to users after initial training is defined. DoD Position: at least every 12 months.
- ODP[03] (DoD memo identifier 03.06.04.b.01). the frequency at which to review and update incident response training content is defined. DoD Position: at least every 12 months.
- ODP[04] (DoD memo identifier 03.06.04.b.02). events that initiate a review of the incident response training content are defined. DoD Position: significant, novel incidents, or significant changes to risks.
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 03.06.04?
NIST 800-171A R3 breaks 03.06.04 into eleven (11) assessment objectives: four (4) Organization-Defined Parameters (ODPs) and seven (7) determination statements. These AOs are:
- A.03.06.04.ODP[01]: the time period within which incident response training is to be provided to system users is defined.
- A.03.06.04.ODP[02]: the frequency at which to provide incident response training to users after initial training is defined.
- A.03.06.04.ODP[03]: the frequency at which to review and update incident response training content is defined.
- A.03.06.04.ODP[04]: events that initiate a review of the incident response training content are defined.
- A.03.06.04.a.01: incident response training for system users consistent with assigned roles and responsibilities is provided within <A.03.06.04.ODP[01]: time period> of assuming an incident response role or responsibility or acquiring system access.
- A.03.06.04.a.02: incident response training for system users consistent with assigned roles and responsibilities is provided when required by system changes.
- A.03.06.04.a.03: incident response training for system users consistent with assigned roles and responsibilities is provided <A.03.06.04.ODP[02]: frequency> thereafter.
- A.03.06.04.b[01]: incident response training content is reviewed <A.03.06.04.ODP[03]: frequency>.
- A.03.06.04.b[02]: incident response training content is updated <A.03.06.04.ODP[03]: frequency>.
- A.03.06.04.b[03]: incident response training content is reviewed following <A.03.06.04.ODP[04]: events>.
- A.03.06.04.b[04]: incident response training content is updated following <A.03.06.04.ODP[04]: events>.
If you are a DoD contractor, the ODPs are specified. Per the DoD-specified ODP values in ComplianceForge's NIST 800-171 R3 Transition Guide, the initial training time period (ODP[01]) is ten (10) days for privileged users and thirty (30) days for all other roles, the recurring and content-review frequencies (ODP[02] and ODP[03]) are at least every twelve (12) months, and the triggering events (ODP[04]) are significant or novel incidents or significant changes to risks. The full guidance on assessment methods and objects, is in NIST 800-171A R3, 03.06.04 (p. 52).
Assessment Methods and Objects for NIST 800-171 R3 03.06.04
Examine: incident response policy and procedures; procedures for incident response training; incident response training curriculum; incident response training materials; incident response plan; incident response training records; system security plan.
Interview: personnel with incident response training and operational responsibilities; personnel with information security responsibilities.
How Does NIST 800-171 R3 03.06.04 Map From NIST 800-171 R2?
03.06.04 is effectively new for R3. All eleven (11) assessment objectives are net new, and the requirement has no corresponding assessed requirement in NIST 800-171 R2:
- A.03.06.04.ODP[01] through ODP[04], A.03.06.04.a.01 through a.03, and A.03.06.04.b[01] through b[04] are all net new for R3.
Mapped against the eleven (11) AOs, all eleven (11) are net new (significant effort), with none direct, indirect, or unmapped. The base incident response training control, IR-02, was an assumed control in R2 rather than one that R2 separately assessed, so R3 turns it into explicit, testable objectives. Build a documented incident response training program rather than relying on general awareness training.
How Does NIST 800-171 R3 03.06.04 Map to NIST 800-53 R5 and the SCF?
Source Control in NIST 800-53 R5:
Secure Controls Framework (SCF) Crosswalk
Organizations running a single control set across multiple frameworks can satisfy 03.06.04 through the following SCF controls:
- HRS-04 Defined Roles & Responsibilities
- HRS-08.1 Formal Indoctrination
- IRO-03 Continuous Incident Response Improvements
- IRO-10 Incident Response Training
- IRO-14 Root Cause Analysis (RCA) & Lessons Learned
- SAT-03 Maintaining Workforce Development Relevancy
- SAT-04 Security, Compliance & Resilience Awareness Training
- SAT-05 Role-Based Security, Compliance & Resilience Training
- SAT-06 Cyber Threat Environment Situational Awareness
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 03.06.04
The pitfalls for this effectively new requirement are about role-appropriate training and keeping it current, each of which needs documented evidence of due diligence and due care such as policies, standards, procedures, and configuration screenshots:
- General awareness training is not enough. A.03.06.04.a requires incident response training consistent with assigned roles. Responders need deeper training than general users.
- Train on a timeline. A.03.06.04.a.01 requires training within a defined period of taking on a role or gaining access. For DoD work that is ten days for privileged users and thirty for others.
- Content updates are assessed. A.03.06.04.b[01] through b[04] require reviewing and updating content on a frequency and after events. Static training that never changes fails these objectives.
- Coordinate with Role-Based Training. Per the NIST discussion, incident response training for users can be delivered as part of 03.02.02, so align the two programs.
What Is Reasonable Evidence For NIST 800-171 R3 03.06.04?
Reasonable objective evidence for an assessment is often subjective. The following examples of evidence to address NIST 800-171 R3 03.06.04 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 03.06.04 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-HRS-02 Assigned Roles - Application Developers. List of employed or contract personnel assigned to application development roles.
- E-HRS-03 Assigned Roles - Cybersecurity Staff. List of employed or contract personnel assigned to cybersecurity roles.
- E-HRS-04 Assigned Roles - Data Privacy Staff. List of employed or contract personnel assigned to data privacy roles.
- E-HRS-13 Defined Cybersecurity & Data Privacy Responsibilities. A role-based cybersecurity & data privacy responsibilities to ensure personnel are both educated on the role and are responsible for the associated control execution.
- E-HRS-14 Responsibilities Review. A formal review process to ensure assigned responsibilities currently reflect business needs for the assigned role.
- E-HRS-18 Provisioning Checklist (Onboarding). Personnel management practices to formally onboard personnel into their assigned roles.
- E-IRO-06 IRP Training. An incident response plan (irp)-related training activity.
- E-IRO-07 IRP Updates. A periodic review process for the organization's incident response plan (irp) to identify necessary updates.
- E-IRO-08 Root Cause Analysis (RCA). A root cause analysis (rca) from any incident response plan (irp)-related training, testing or significant incident.
- E-SAT-02 Initial User Training. Initial user training for security, compliance and/or resilience topics.
- E-SAT-04 Recurring User Training. Recurring (e.g., annual) user training for security, compliance and/or resilience topics.
- E-SAT-05 Role-Based Training. Specialized user training for privileged users, executives, individuals who handle sensitive/regulated data, etc.
- E-SAT-06 Training Materials. Security awareness training materials (e.g., curriculum, course work, presentations, etc.).
Alongside these, keep the System Security Plan (SSP) narrative for 03.06.04 recording the ODP values you adopted.
Timeline Considerations for NIST 800-171 R3 03.06.04
With all eleven (11) AOs net new, 03.06.04 is a significant lift built as a program. A realistic sequence:
- Define the four (4) ODPs: the initial time period, the recurring frequency, the content-review frequency, and the events, using the DoD-specified values for DoD contracts.
- Build role-appropriate incident response training for users, administrators, and responders.
- Deliver training within the time period, on system changes, and on the recurring frequency (A.03.06.04.a.01 through a.03).
- Review and update content on the frequency and after events (A.03.06.04.b[01] through b[04]).
- Collect evidence for all eleven (11) AOs, including training records and content update history.
Frequently Asked Questions About NIST 800-171 R3 03.06.04
What value does the DoD require for the first parameter in NIST 800-171 R3 03.06.04? R3 leaves the value to the organization. For the DIB, the DoD set it in the 10 April 2025 memorandum under ODP identifier 03.06.04.a.01: ten (10) days for privileged users, thirty (30) days for all other roles.
How many assessment objectives does NIST 800-171 R3 03.06.04 have? NIST 800-171A R3 breaks 03.06.04 into eleven (11) assessment objectives: four (4) Organization-Defined Parameters (ODPs) and seven (7) 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 03.06.04 come from? IR-02.
Where does NIST 800-171 R3 03.06.04 sit in the NIST 800-171 R3 Kill Chain? Phase 10, Incident Response (IR). 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 03.06.04
03.06.04 Incident Response Training provides role-appropriate incident response training on a timeline and keeps the content current. It is effectively new for R3, with all eleven (11) assessment objectives net new. The recurring problem is treating general awareness training as sufficient. Build role-based incident response training, deliver it on the defined timeline (for DoD, ten days for privileged users and thirty for others), and keep the content updated.
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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.
