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How Do I Implement NIST 800-171 R3 03.08.01 Media Storage?

NIST 800-171 R3 03.08.01 Media Storage at a Glance

  • Family: 03.08 Media Protection (MP)
  • Requirement ID: 03.08.01 Media Storage
  • Assessment Objectives (AOs): Two (2) determination statements
  • Organization-Defined Parameters (ODPs): None (0). This requirement contains no organization-defined values
  • Source NIST 800-53 R5 Control: MP-04
  • NIST 800-171 R3 Kill Chain Phase: Phase 8, Segmented Network Architecture

Media Storage is the first requirement in the Media Protection (03.08) family, and it addresses the physical security of media that hold Controlled Unclassified Information (CUI). System media covers both digital media, such as flash drives, external drives, magnetic tapes, and discs, and non-digital media, such as paper and microfilm. Media Storage (03.08.01) requires two things: physically control system media that contain CUI, and securely store it. Per the NIST discussion, physically controlling media includes inventories, check-out and return procedures, and maintaining accountability, and secure storage includes a locked drawer, desk, or cabinet or a controlled media library.

A common difficulty with this requirement is remembering digital media but forgetting paper, or storing media in a way that is not actually controlled. A stack of printouts containing CUI on a desk, or a box of backup tapes in an unlocked closet, both fail this requirement. Media that contains CUI has to be both accounted for and physically secured.

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 The withdrawal notice states that R2 "has been withdrawn (archived), and is provided solely for historical purposes," so it will never receive another correction or clarification from NIST.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 03.08.01 Actually Require?

The following is reproduced verbatim from NIST 800-171 R3, requirement 03.08.01 Media Storage. Only the formatting has been adjusted for readability. This is a single statement with no lettered parts:

  • Physically control and securely store system media that contain CUI.

The source control is MP-04 from NIST 800-53. There are no Organization-Defined Parameters (ODPs). Per the NIST discussion, system media include digital media such as flash drives, tapes, and discs and non-digital media such as paper and microfilm, and controlled areas provide physical and procedural controls to meet the requirements for protecting information and systems. You can read the requirement directly at NIST 800-171 R3, 03.08.01 (p. 44).

What Are the Organization-Defined Parameters (ODPs) Associated with NIST 800-171 R3 03.08.01?

None (0). Requirement 03.08.01 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 03.08.01 therefore records how the requirement is implemented rather than a parameter you chose.

What Are the Assessment Objectives (AOs) For NIST 800-171 R3 03.08.01?

NIST 800-171A R3 breaks 03.08.01 into two (2) determination statements, and it has no Organization-Defined Parameters (ODPs). These AOs are:

  • A.03.08.01[01]: system media that contain CUI are physically controlled.
  • A.03.08.01[02]: system media that contain CUI are securely stored.

The two (2) objectives are physical control and secure storage, each of which must hold for both digital and non-digital media. The full guidance on assessment methods and objects, is in NIST 800-171A R3, 03.08.01 (p. 57).

Assessment Methods and Objects for NIST 800-171 R3 03.08.01

Examine: physical protection policy and procedures; media protection policy and procedures; procedures for media storage; access control policy and procedures; system media; system security plan.

Interview: personnel with system media protection and storage responsibilities; personnel with information security responsibilities.

Test: processes for storing information media; mechanisms for supporting or implementing secure media storage/media protection.

How Does NIST 800-171 R3 03.08.01 Map From NIST 800-171 R2?

03.08.01 maps from NIST 800-171 R2 requirement 3.8.1 (protect, that is physically control and securely store, system media containing CUI, both paper and digital):

  • A.03.08.01[01] maps directly to R2 3.8.1[a] and 3.8.1[b] (paper and digital media are physically controlled).
  • A.03.08.01[02] maps directly to R2 3.8.1[c] and 3.8.1[d] (paper and digital media are securely stored).

Mapped against the two (2) AOs, both (2) are direct (minimal effort), with no net-new AOs and none with no mapping. This is a clean carry-forward. The concept, the coverage of both paper and digital media, and the source control (MP-04) are unchanged. If you satisfied R2 3.8.1, you are satisfying 03.08.01, provided both media types are physically controlled and securely stored.

How Does NIST 800-171 R3 03.08.01 Map to NIST 800-53 R5 and the SCF?

Source Control in NIST 800-53 R5:

  • MP-04

Secure Controls Framework (SCF) Crosswalk

Organizations running a single control set across multiple frameworks can satisfy 03.08.01 through the following SCF controls:

  • DCH-02 Data Protection
  • DCH-04 Data & Asset Classification
  • DCH-06 Data Stewardship
  • DCH-06.1 Defining Access Authorizations for Sensitive / Regulated Data
  • DCH-07 Sensitive / Regulated Data Protection
  • DCH-07.1 Restrict Sensitive / Regulated Data Access To Authorized Individuals
  • DCH-12.1 Making Sensitive / Regulated Data Unreadable In Storage
  • DCH-13 Media Storage
  • DCH-14 Physically Secure All Media Containing Sensitive / Regulated Data
  • PES-02 Physical & Environmental Protections
  • PES-06 Physical Access Authorizations
  • PES-07 Role-Based Physical Access
  • PES-10 Physical Security of Offices, Rooms & Facilities
  • PES-11 Working in Secure Areas

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 03.08.01

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

  • Paper counts. A.03.08.01 covers non-digital media, so printouts and other paper containing CUI must be physically controlled and securely stored, not just digital media.
  • Control means accountability. Per the NIST discussion, physical control includes inventories, check-out and return procedures, and accountability, not merely locking media away.
  • Secure storage is a defined thing. A locked drawer, desk, or cabinet or a controlled media library qualifies. Media left in the open does not.
  • Coordinate with sanitization. Media that is no longer needed is handled by Media Sanitization (03.08.03), so tie storage to the end of the media lifecycle.

What Is Reasonable Evidence For NIST 800-171 R3 03.08.01?

Reasonable objective evidence for an assessment is often subjective. The following examples of evidence to address NIST 800-171 R3 03.08.01 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 03.08.01 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-DCH-01 Data Classification Scheme. An organization-specific data classification scheme.
  • E-DCH-02 Data Handling Practices. An organization-specific data handling practices (e.g., guidance specific the data classification scheme).
  • E-DCH-08 Authorization Documentation. That identifies authorized users and processes acting on behalf of authorized users.
  • E-DCH-09 Assigned Responsibilities. Data stewardship being assigned and communicated to individuals entrusted with sensitive and/or regulated data.
  • E-DCH-13 Media Storage Facilities. Media storage facilities.
  • E-HRS-28 Authorized Personnel Access List. An authorized personnel access list.
  • E-IAC-02 Defined Roles & Authorizations (RBAC). Defined access control-specific roles (e.g., role based access control (rbac)) that affect both logical and physical access authorizations.
  • E-PES-03 Defined Physical Security Roles. Defined physical access control-specific roles that limit physical access to rooms and/or facilities.
  • E-PES-04 Physical Security Plan. A physical security plan.
  • E-PES-10 Physical Access Authorizations. Physical access authorization activities (e.g., list reviews, termination changes, etc.).
  • E-PES-11 Physical Security Zones. Security safeguards controlling access to designated physical security zones within facilities.

Alongside these, keep the System Security Plan (SSP) narrative for 03.08.01.

Timeline Considerations for NIST 800-171 R3 03.08.01

With both AOs mapping directly, 03.08.01 is a light lift if media handling is mature. A realistic sequence:

  1. Identify the digital and non-digital media that contain CUI.
  2. Physically control that media with inventories, check-out and return procedures, and accountability (A.03.08.01[01]).
  3. Securely store the media in locked storage or a controlled media library (A.03.08.01[02]).
  4. Collect evidence for both (2) AOs, including media inventories and storage arrangements.

Frequently Asked Questions About NIST 800-171 R3 03.08.01

How many assessment objectives does NIST 800-171 R3 03.08.01 have? NIST 800-171A R3 breaks 03.08.01 into two (2) 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 03.08.01 come from? MP-04.

How many Organization-Defined Parameters (ODPs) does NIST 800-171 R3 03.08.01 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 03.08.01 sit in the NIST 800-171 R3 Kill Chain? Phase 8, Segmented Network Architecture. 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 03.08.01

03.08.01 Media Storage physically controls and securely stores system media, both digital and non-digital, that contain CUI. It maps directly from R2 3.8.1, so there is no net-new work. The recurring problem is forgetting paper or storing media without real control. Account for both media types, control them with inventories and procedures, and store them securely.

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.