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How Do I Implement NIST 800-171 R3 03.08.02 Media Access?

NIST 800-171 R3 03.08.02 Media Access at a Glance

  • Family: 03.08 Media Protection (MP)
  • Requirement ID: 03.08.02 Media Access
  • Assessment Objectives (AOs): One (1) determination statements
  • Organization-Defined Parameters (ODPs): None (0). This requirement contains no organization-defined values
  • Source NIST 800-53 R5 Control: MP-02
  • NIST 800-171 R3 Kill Chain Phase: Phase 8, Segmented Network Architecture

Media Access restricts who can get to the Controlled Unclassified Information (CUI) that lives on system media. Where Media Storage (03.08.01) physically controls and secures the media, Media Access (03.08.02) governs access to the CUI on it. It is a single statement: restrict access to CUI on system media to authorized personnel or roles. Per the NIST discussion, access can be restricted by physically controlling the media through inventories, check-out and return procedures, and accountability, and for digital media, access to CUI can be restricted using cryptographic means, with encryption at rest addressed in Transmission and Storage Confidentiality (03.13.08).

A common difficulty with this requirement is having secure storage but no real restriction on who can access the media. A shared media library that anyone can pull from, or an unencrypted external drive that any user can read, both fail this requirement. Access to the CUI on media has to be limited to the people or roles that are authorized for it.

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 The withdrawal notice states that R2 "has been withdrawn (archived), and is provided solely for historical purposes," so it will never receive another correction or clarification from NIST.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 03.08.02 Actually Require?

The following is reproduced verbatim from NIST 800-171 R3, requirement 03.08.02 Media Access. Only the formatting has been adjusted for readability. This is a single statement with no lettered parts:

  • Restrict access to CUI on system media to authorized personnel or roles.

The source control is MP-02 from NIST 800-53. There are no Organization-Defined Parameters (ODPs). Per the NIST discussion, access to CUI on system media can be restricted by physically controlling the media, and for digital media it can be restricted by cryptographic means, with encryption of data at rest addressed in 03.13.08. You can read the requirement directly at NIST 800-171 R3, 03.08.02 (p. 45).

What Are the Organization-Defined Parameters (ODPs) Associated with NIST 800-171 R3 03.08.02?

None (0). Requirement 03.08.02 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 03.08.02 therefore records how the requirement is implemented rather than a parameter you chose.

What Are the Assessment Objectives (AOs) For NIST 800-171 R3 03.08.02?

NIST 800-171A R3 breaks 03.08.02 into one (1) determination statement, and it has no Organization-Defined Parameters (ODPs). The AO is:

  • A.03.08.02: access to CUI on system media is restricted to authorized personnel or roles.

The single objective is that access to CUI on media is restricted to authorized personnel or roles. An assessor will look at both physical and cryptographic restrictions. The full guidance on assessment methods and objects, is in NIST 800-171A R3, 03.08.02 (p. 58).

Assessment Methods and Objects for NIST 800-171 R3 03.08.02

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

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

Test: processes for restricting information on media; mechanisms for supporting or implementing media access restrictions.

How Does NIST 800-171 R3 03.08.02 Map From NIST 800-171 R2?

03.08.02 maps from NIST 800-171 R2 requirement 3.8.2 (limit access to CUI on system media to authorized users):

  • A.03.08.02 maps directly to R2 3.8.2 (access to CUI on system media is restricted to authorized personnel or roles).

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 and the source control (MP-02) are unchanged. R3 expresses the population as authorized personnel or roles rather than authorized users, which is a wording refinement rather than a substantive change. If you satisfied R2 3.8.2, you are satisfying 03.08.02.

How Does NIST 800-171 R3 03.08.02 Map to NIST 800-53 R5 and the SCF?

Source Control in NIST 800-53 R5:

  • MP-02

Secure Controls Framework (SCF) Crosswalk

Organizations running a single control set across multiple frameworks can satisfy 03.08.02 through the following SCF controls:

  • 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
  • HRS-04 Defined Roles & Responsibilities
  • 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 03.08.02

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

  • Storage is not access control. Media Storage (03.08.01) secures the media, but 03.08.02 restricts who can access the CUI on it. Both are needed.
  • Use cryptographic restriction for digital media. Per the NIST discussion, access to CUI on digital media can be restricted with encryption, which ties to 03.13.08. Unencrypted removable media that any user can read is a gap.
  • Restrict by role. Access should be limited to authorized personnel or roles, not open to everyone with physical proximity to the media library.
  • Cover both physical and digital. Physical check-out procedures and cryptographic controls together restrict access across media types.

What Is Reasonable Evidence For NIST 800-171 R3 03.08.02?

Reasonable objective evidence for an assessment is often subjective. The following examples of evidence to address NIST 800-171 R3 03.08.02 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 03.08.02 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-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-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-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 03.08.02.

Timeline Considerations for NIST 800-171 R3 03.08.02

With the single AO mapping directly, 03.08.02 is a light lift, especially where storage and encryption are already in place. A realistic sequence:

  1. Identify the authorized personnel or roles for CUI on system media.
  2. Restrict physical access to media through check-out procedures and controlled libraries.
  3. Restrict digital access with cryptographic means, coordinating with 03.13.08.
  4. Collect evidence for the one (1) AO, including access restrictions and encryption for CUI on media.

Frequently Asked Questions About NIST 800-171 R3 03.08.02

How many assessment objectives does NIST 800-171 R3 03.08.02 have? NIST 800-171A R3 breaks 03.08.02 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 03.08.02 come from? MP-02.

How many Organization-Defined Parameters (ODPs) does NIST 800-171 R3 03.08.02 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 03.08.02 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 03.08.02

03.08.02 Media Access restricts access to CUI on system media to authorized personnel or roles. It maps directly from R2 3.8.2, so there is no net-new work. The recurring problem is securing the media without restricting who can access the CUI on it. Limit access to authorized personnel or roles using physical procedures and, for digital media, cryptographic controls.

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.