Monitoring Physical Access makes sure that physical access to the facility is watched, logged, and reviewed, not just controlled at the door. Physical Access Authorizations (03.10.01) decides who may enter, and Monitoring Physical Access (03.10.02) detects and responds to what actually happens. It has two (2) parts: monitor physical access to the facility to detect and respond to physical security incidents, and review physical access logs on a defined frequency and upon defined events. Per the NIST discussion, monitoring includes guards, video surveillance, and sensor devices, reviewing logs helps identify suspicious activity such as access outside normal hours or repeated access to unusual areas, and physical access log review can be supported by the audit logging controls when access logs are automated.
A common difficulty with this requirement is having cameras and badge readers that no one reviews. Collecting physical access data is not the same as monitoring it. R3 adds explicit objectives to review physical access logs on a schedule and after events, plus incident detection and response. For Department of Defense (DoD) contractors, the log review frequency is short and specific.
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 03.10.02 Monitoring Physical Access. Only the formatting has been adjusted for readability. This requirement has two (2) lettered parts:
The source control is PE-06 from NIST 800-53. The bracketed assignments in part b are the Organization-Defined Parameters (ODPs): the log review frequency and the events. Per the NIST discussion, physical access monitoring includes publicly accessible areas within facilities, and incident response capabilities include investigating and responding to physical security incidents such as access outside normal work hours or out-of-sequence access. You can read the requirement directly at NIST 800-171 R3, 03.10.02 (p. 50).
Two (2) 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.
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 03.10.02 into six (6) assessment objectives: two (2) Organization-Defined Parameters (ODPs) and four (4) determination statements. These AOs are:
Part a splits into monitoring to detect and responding to incidents, and part b splits into review on a frequency and review on 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 log review frequency (ODP[01]) is at least every forty-five (45) days, and the events (ODP[02]) are significant or novel incidents or significant changes to risks. The full guidance on assessment methods and objects, is in NIST 800-171A R3, 03.10.02 (p. 65).
Examine: physical protection policy and procedures; procedures for physical access monitoring; physical access logs or records; physical access monitoring records; physical access log reviews; system security plan.
Interview: personnel with physical access monitoring responsibilities; personnel with incident response responsibilities; personnel with information security responsibilities.
Test: processes for monitoring physical access; mechanisms for supporting or implementing physical access monitoring; mechanisms for supporting or implementing the review of physical access logs.
03.10.02 maps from NIST 800-171 R2 requirement 3.10.2 (protect and monitor the physical facility and support infrastructure for organizational systems):
Mapped against the six (6) AOs, one (1) is direct (minimal effort), two (2) are net new, and three (3) have no clear mapping, with the last two (2) categories both counting as significant effort. Monitoring the facility carries forward, but reviewing access logs on a frequency and after events, responding to incidents, and defining the parameters are all new. Five of the six (6) objectives are significant effort, which makes this a bigger lift than the two-part requirement suggests.
Source Control in NIST 800-53 R5:
Secure Controls Framework (SCF) Crosswalk
Organizations running a single control set across multiple frameworks can satisfy 03.10.02 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 actually reviewing logs and responding, 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 03.10.02 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 03.10.02 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 03.10.02 recording the ODP values you adopted.
With one AO mapping directly, two net new, and three with no clear mapping, 03.10.02 is a meaningful lift. A realistic sequence:
What value does the DoD require for the first parameter in NIST 800-171 R3 03.10.02? R3 leaves the value to the organization. For the DIB, the DoD set it in the 10 April 2025 memorandum under ODP identifier 03.10.02.b.01: at least every 45 days.
How many assessment objectives does NIST 800-171 R3 03.10.02 have? NIST 800-171A R3 breaks 03.10.02 into six (6) assessment objectives: two (2) Organization-Defined Parameters (ODPs) and four (4) 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 03.10.02 come from? PE-06.
Where does NIST 800-171 R3 03.10.02 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.
03.10.02 Monitoring Physical Access monitors facility access to detect and respond to incidents and reviews physical access logs on a defined frequency and after events. It maps from R2 3.10.2 with facility monitoring transitioning directly, while log review, incident response, and the parameters are new, making five of six (6) objectives significant effort. The recurring problem is unreviewed cameras and logs. Monitor, respond to incidents, and review the logs (for DoD, at least every forty-five days).
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.
