Personnel Termination and Transfer keeps access aligned with employment status as people leave or change roles. It completes the Personnel Security (03.09) family alongside Personnel Screening (03.09.01), and it ties directly to Account Management (03.01.01), since the access being disabled and modified lives in the account lifecycle. Personnel Termination and Transfer (03.09.02) has two (2) parts: on termination, disable system access within a defined time period, terminate or revoke the individual's authenticators and credentials, and retrieve security-related system property; on reassignment or transfer, review and confirm the ongoing need for current access and modify authorizations to match. Per the NIST discussion, security-related property includes authentication tokens, keys, identification cards, and building passes, and timely termination actions are essential for individuals terminated for cause.
A common difficulty with this requirement is slow access removal and forgotten property. An account that stays active for days after someone leaves, or a former employee who keeps a hardware token or building pass, both create real exposure. R3 ties the access-disable step to a defined time period, and for Department of Defense (DoD) contractors that period is short: four hours.
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 03.09.02 Personnel Termination and Transfer. Only the formatting has been adjusted for readability. This requirement has two (2) lettered parts, each with numbered sub-parts:
The source controls are PS-04 and PS-05 from NIST 800-53. The bracketed assignment in part a is the Organization-Defined Parameter (ODP): the time period within which to disable system access. Per the NIST discussion, organizations may disable accounts before notifying individuals being terminated for cause, and protections for transfers include returning old and issuing new cards, keys, and passes and adjusting system access authorizations. You can read the requirement directly at NIST 800-171 R3, 03.09.02 (p. 49).
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.
The memo states that its values "will be updated as necessary," so confirm against the current version before writing them into policy.
NIST 800-171A R3 breaks 03.09.02 into eight (8) assessment objectives: one (1) Organization-Defined Parameter (ODP) and seven (7) determination statements. These AOs are:
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 time period to disable system access (ODP[01]) is four (4) hours. The full guidance on assessment methods and objects, is in NIST 800-171A R3, 03.09.02 (p. 63).
Examine: personnel security policy and procedures; procedures for personnel termination; records of personnel transfer actions; procedures for personnel transfer; list of system and facility access authorizations; records of personnel termination actions; records of terminated or revoked authenticators or credentials; list of system accounts; records of exit interviews; system security plan.
Interview: personnel with personnel security responsibilities; personnel with account management responsibilities; personnel with information security responsibilities; system administrators.
Test: processes for personnel termination; processes for personnel transfer; mechanisms for supporting or implementing personnel transfer notifications; mechanisms for supporting or implementing personnel termination notifications; mechanisms for disabling system access and revoking authenticators.
03.09.02 maps from NIST 800-171 R2 requirement 3.9.2 (ensure that organizational systems containing Controlled Unclassified Information (CUI) are protected during and after personnel actions such as terminations and transfers):
Mapped against the eight (8) AOs, six (6) are indirect (moderate effort), one (1) is net new, and one (1) has no clear mapping, with the last two (2) categories both counting as significant effort. Terminating access and adjusting authorizations for transfers carry forward, but retrieving security-related property is a new objective and the access-disable time period has no R2 predecessor. Re-analyze your termination and transfer process against the R3 structure rather than assuming your R2 evidence transfers.
Source Controls in NIST 800-53 R5:
Secure Controls Framework (SCF) Crosswalk
Organizations running a single control set across multiple frameworks can satisfy 03.09.02 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 speed, property, and transfers, 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 03.09.02 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 03.09.02 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.
Alongside these, keep the System Security Plan (SSP) narrative for 03.09.02 recording the ODP values you adopted.
With six (6) AOs mapping indirectly, one net new, and one with no clear mapping, 03.09.02 is a moderate lift, and the short time period raises the operational bar. A realistic sequence:
What value does the DoD require for the organization-defined parameter in NIST 800-171 R3 03.09.02? R3 leaves the value to the organization. For the DIB, the DoD set it in the 10 April 2025 memorandum under ODP identifier 03.09.02.a.01: four (4) hours.
How many assessment objectives does NIST 800-171 R3 03.09.02 have? NIST 800-171A R3 breaks 03.09.02 into eight (8) assessment objectives: one (1) 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 controls does NIST 800-171 R3 03.09.02 come from? PS-04, PS-05.
Where does NIST 800-171 R3 03.09.02 sit in the NIST 800-171 R3 Kill Chain? Phase 6b, Identify Compliance Stakeholders. The Kill Chain is a phased model for sequencing R3 implementation, and it assigns this requirement to that phase.
03.09.02 Personnel Termination and Transfer disables access within a defined time on termination, revokes authenticators and credentials, retrieves security-related property, and realigns access on transfers. It maps from R2 3.9.2 with termination and transfer actions transitioning indirectly, while property retrieval is net new and the access-disable time period has no R2 predecessor. The recurring problem is slow access removal and forgotten property. Disable access fast (for DoD, within four hours), retrieve property, and realign access on transfers.
Authoritative sources:
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.
