Physical Access Authorizations is the first requirement in the Physical Protection (03.10) family, and it governs who is allowed into the facility where the system resides. It is the physical counterpart to Account Management (03.01.01): where account management authorizes logical access, Physical Access Authorizations (03.10.01) authorizes physical access. It has four (4) parts: develop, approve, and maintain a list of individuals with authorized facility access, issue authorization credentials for facility access, review the access list on a defined frequency, and remove individuals when access is no longer required. Per the NIST discussion, a facility can include one or more physical locations that process, store, or transmit Controlled Unclassified Information (CUI), authorization applies to employees and visitors, and authorization credentials include identification badges, cards, and smart cards.
A common difficulty with this requirement is treating the facility access list as static. R3 adds explicit objectives to review the list on a schedule and to remove people when access is no longer needed, which many organizations handled informally. A former employee or a departed contractor who still appears on the facility access list is exactly what these new objectives are meant to catch. For Department of Defense (DoD) contractors, the review frequency is specified.
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 03.10.01 Physical Access Authorizations. Only the formatting has been adjusted for readability. This requirement has four (4) lettered parts:
The source control is PE-02 from NIST 800-53. The bracketed assignment in part c is the Organization-Defined Parameter (ODP): the review frequency. Per the NIST discussion, individuals with permanent physical access credentials are not considered visitors, and physical access authorizations may not be necessary for areas designated as publicly accessible. You can read the requirement directly at NIST 800-171 R3, 03.10.01 (p. 50).
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 03.10.01 into seven (7) assessment objectives: one (1) Organization-Defined Parameter (ODP) and six (6) determination statements. These AOs are:
Part a splits into develop, approve, and maintain. 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 review frequency (ODP[01]) is at least every twelve (12) months, or when there are significant incidents or significant changes to risks. The full guidance on assessment methods and objects, is in NIST 800-171A R3, 03.10.01 (p. 64).
Examine: physical protection policy and procedures; procedures for physical access authorizations; authorized personnel access list; physical access list reviews; physical access termination records; authorization credentials; system security plan.
Interview: personnel with physical access authorization responsibilities; personnel with physical access to the facility where the system resides; personnel with information security responsibilities.
Test: processes for physical access authorizations; mechanisms for supporting or implementing physical access authorizations.
03.10.01 maps from NIST 800-171 R2 requirement 3.10.1 (limit physical access to organizational systems, equipment, and the respective operating environments to authorized individuals):
Mapped against the seven (7) AOs, four (4) are direct (minimal effort), two (2) are net new, and one (1) has no clear mapping, with the last two (2) categories both counting as significant effort. Identifying authorized individuals and issuing credentials carry forward, but reviewing the access list and removing individuals when access is no longer required are new, along with the review frequency. Three of the seven (7) objectives are significant effort.
Source Control in NIST 800-53 R5:
Secure Controls Framework (SCF) Crosswalk
Organizations running a single control set across multiple frameworks can satisfy 03.10.01 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 list maintenance, 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 03.10.01 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 03.10.01 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.
Alongside these, keep the System Security Plan (SSP) narrative for 03.10.01 recording the ODP values you adopted.
With four (4) AOs mapping directly, two net new, and one with no clear mapping, 03.10.01 is a moderate lift centered on list maintenance. A realistic sequence:
What value does the DoD require for the organization-defined parameter in NIST 800-171 R3 03.10.01? R3 leaves the value to the organization. For the DIB, the DoD set it in the 10 April 2025 memorandum under ODP identifier 03.10.01.c: at least every 12 months, or when there are significant incidents or significant changes to risks.
How many assessment objectives does NIST 800-171 R3 03.10.01 have? NIST 800-171A R3 breaks 03.10.01 into seven (7) assessment objectives: one (1) Organization-Defined Parameters (ODPs) and six (6) 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 03.10.01 come from? PE-02.
Where does NIST 800-171 R3 03.10.01 sit in the NIST 800-171 R3 Kill Chain? Phase 20, Physical Security. The Kill Chain is a phased model for sequencing R3 implementation, and it assigns this requirement to that phase.
03.10.01 Physical Access Authorizations develops, approves, and maintains a facility access list, issues credentials, reviews the list on a defined frequency, and removes individuals when access is no longer required. It maps from R2 3.10.1 with identification and credentialing transitioning directly, while list review, removal, and the review frequency are new. The recurring problem is a static access list. Maintain and approve the list, review it (for DoD, at least every twelve months), and remove access promptly when it is no longer needed.
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.
