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How Do I Implement NIST 800-171 R3 03.10.07 Physical Access Control?

NIST 800-171 R3 03.10.07 Physical Access Control at a Glance

  • Family: 03.10 Physical Protection (PE)
  • Requirement ID: 03.10.07 Physical Access Control
  • Assessment Objectives (AOs): Seven (7) determination statements
  • Organization-Defined Parameters (ODPs): None (0). This requirement contains no organization-defined values
  • Source NIST 800-53 R5 Controls: PE-03, PE-05
  • NIST 800-171 R3 Kill Chain Phase: Phase 20, Physical Security

Physical Access Control is the enforcement side of physical protection. Physical Access Authorizations (03.10.01) decides who is allowed in and Monitoring Physical Access (03.10.02) watches what happens, while Physical Access Control (03.10.07) actually enforces access at the doors and secures the physical means of access. It consolidates several R2 physical protection requirements into one and has five (5) parts: enforce physical access authorizations at entry and exit points, maintain physical access audit logs, escort and control visitors, secure keys and other physical access devices, and control physical access to output devices to prevent unauthorized access to Controlled Unclassified Information (CUI). Per the NIST discussion, physical access devices include keys, locks, combinations, and card readers, and controlling access to output devices includes locked rooms, monitored placement, screen filters, and headphones.

A common difficulty with this requirement is the output device objective, which is easy to overlook. A printer that anyone can walk up to, or a monitor visible through a window, both expose CUI regardless of how well the doors are controlled. R3 also makes entry and exit enforcement explicit, so verifying authorizations and controlling ingress and egress are now separately assessed.

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 The withdrawal notice states that R2 "has been withdrawn (archived), and is provided solely for historical purposes," so it will never receive another correction or clarification from NIST.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 03.10.07 Actually Require?

The following is reproduced verbatim from NIST 800-171 R3, requirement 03.10.07 Physical Access Control. Only the formatting has been adjusted for readability. This requirement has five (5) lettered parts, and part a has two numbered sub-parts:

  • a. Enforce physical access authorizations at entry and exit points to the facility where the system resides by:
    1. Verifying individual physical access authorizations before granting access to the facility and
    2. Controlling ingress and egress with physical access control systems, devices, or guards.
  • b. Maintain physical access audit logs for entry or exit points.
  • c. Escort visitors, and control visitor activity.
  • d. Secure keys, combinations, and other physical access devices.
  • e. Control physical access to output devices to prevent unauthorized individuals from obtaining access to CUI.

The source controls are PE-03 and PE-05 from NIST 800-53. There are no Organization-Defined Parameters (ODPs). Per the NIST discussion, physical access points can include exterior and interior access points, audit logs can be procedural or automated, and examples of output devices include monitors, printers, scanners, facsimile machines, audio devices, and copiers. You can read the requirement directly at NIST 800-171 R3, 03.10.07 (p. 52).

What Are the Organization-Defined Parameters (ODPs) Associated with NIST 800-171 R3 03.10.07?

None (0). Requirement 03.10.07 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 03.10.07 therefore records how the requirement is implemented rather than a parameter you chose.

What Are the Assessment Objectives (AOs) For NIST 800-171 R3 03.10.07?

NIST 800-171A R3 breaks 03.10.07 into seven (7) determination statements, and it has no Organization-Defined Parameters (ODPs). These AOs are:

  • A.03.10.07.a.01: physical access authorizations are enforced at entry and exit points to the facility where the system resides by verifying individual physical access authorizations before granting access.
  • A.03.10.07.a.02: physical access authorizations are enforced at entry and exit points to the facility where the system resides by controlling ingress and egress with physical access control systems, devices, or guards.
  • A.03.10.07.b: physical access audit logs for entry or exit points are maintained.
  • A.03.10.07.c[01]: visitors are escorted.
  • A.03.10.07.c[02]: visitor activity is controlled.
  • A.03.10.07.d: keys, combinations, and other physical access devices are secured.
  • A.03.10.07.e: physical access to output devices is controlled to prevent unauthorized individuals from obtaining access to CUI.

The five (5) parts decompose into verifying authorizations and controlling ingress and egress, maintaining logs, escorting and controlling visitors, securing access devices, and controlling output devices. The full guidance on assessment methods and objects, is in NIST 800-171A R3, 03.10.07 (p. 67).

Assessment Methods and Objects for NIST 800-171 R3 03.10.07

Examine: physical protection policy and procedures; procedures for physical access control; physical access control logs or records; inventory records of physical access control devices; system entry and exit points; records of key and lock combination changes; storage locations for physical access control devices; physical access control devices; list of security safeguards controlling access to designated publicly accessible areas within facility; system security plan.

Interview: personnel with physical access control responsibilities; personnel with information security responsibilities.

Test: processes for physical access control; mechanisms for supporting or implementing physical access control; physical access control devices.

How Does NIST 800-171 R3 03.10.07 Map From NIST 800-171 R2?

03.10.07 consolidates several R2 physical protection requirements: 3.10.3 (escort visitors and monitor visitor activity), 3.10.4 (maintain audit logs of physical access), and 3.10.5 (control and manage physical access devices):

  • A.03.10.07.b maps directly to R2 3.10.4 (audit logs of physical access are maintained).
  • A.03.10.07.c[01] maps directly to R2 3.10.3[a] (visitors are escorted).
  • A.03.10.07.c[02] maps indirectly to elements of R2 3.10.3[b] (visitor activity is monitored).
  • A.03.10.07.d maps indirectly to elements of R2 3.10.5 (physical access devices are controlled and managed).
  • A.03.10.07.a.01, A.03.10.07.a.02, and A.03.10.07.e are net new for R3.

Mapped against the seven (7) AOs, two (2) are direct (minimal effort), two (2) are indirect (moderate effort), and three (3) are net new (significant effort), with none having no mapping. Audit logs, visitor escorting, and access device control carry forward, but the explicit entry and exit enforcement and the output device control are new. Three of the seven (7) objectives are significant effort.

How Does NIST 800-171 R3 03.10.07 Map to NIST 800-53 R5 and the SCF?

Source Controls in NIST 800-53 R5:

  • PE-03
  • PE-05

Secure Controls Framework (SCF) Crosswalk

Organizations running a single control set across multiple frameworks can satisfy 03.10.07 through the following SCF controls:

  • DCH-27 Media & Data Retention
  • PES-02 Physical & Environmental Protections
  • PES-06 Physical Access Authorizations
  • PES-08 Physical Access Control
  • PES-09 Controlled Ingress & Egress Points
  • PES-09.1 Physical Access Logs
  • PES-10 Physical Security of Offices, Rooms & Facilities
  • PES-11 Working in Secure Areas
  • PES-12 Access To Critical Systems
  • PES-14 Visitor Control
  • PES-14.1 Distinguish Visitors from On-Site Personnel
  • PES-14.2 Identification Requirement
  • PES-14.3 Restrict Unescorted Access
  • PES-14.6 Visitor Access Revocation
  • PES-16 Equipment Siting & Protection
  • PES-17 Access Control for Output Devices

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 03.10.07

The following are issues teams may encounter rather than certainties. They are about the new entry-exit and output device objectives, each of which needs documented evidence of due diligence and due care such as policies, standards, procedures, and configuration screenshots:

  • Output device control is net new. A.03.10.07.e requires controlling physical access to output devices so unauthorized individuals cannot obtain CUI. Unattended printers and visible monitors are the common gap.
  • Enforce at entry and exit. A.03.10.07.a.01 and a.02 are net new and separate: verify authorizations before granting access, and control ingress and egress with systems, devices, or guards.
  • Escort and control visitors. A.03.10.07.c[01] and c[02] require both escorting visitors and controlling their activity, not just signing them in.
  • Secure the physical access devices. A.03.10.07.d requires securing keys, combinations, and similar devices, so uncontrolled master keys are a finding.

What Is Reasonable Evidence For NIST 800-171 R3 03.10.07?

Reasonable objective evidence for an assessment is often subjective. The following examples of evidence to address NIST 800-171 R3 03.10.07 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 03.10.07 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-AST-11 Data Retention Program. A formal data retention program that governs the retention and destruction of data types.
  • E-HRS-28 Authorized Personnel Access List. An authorized personnel access list.
  • E-PES-02 Visitor Logbook. A visitor management and logging visitor activities.
  • 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-05 Physical Security Operations. The organization's physical security capabilities as it pertains to operating and monitoring physical access control (pac) mechanisms.
  • E-PES-06 Physical Access Control Logs. Physical access control logs or records.
  • E-PES-07 Physical Access Control Devices. Physical access control (pac) mechanisms.
  • E-PES-09 Key & Combination Changes. Key and lock combination changes.
  • 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.
  • E-PES-12 Entry and Exist Points. Physical entry and exit points.

Alongside these, keep the System Security Plan (SSP) narrative for 03.10.07.

Timeline Considerations for NIST 800-171 R3 03.10.07

With two (2) AOs mapping directly, two indirectly, and three net new, 03.10.07 is a meaningful lift. A realistic sequence:

  1. Enforce physical access at entry and exit points: verify authorizations and control ingress and egress (A.03.10.07.a.01 and a.02).
  2. Maintain physical access audit logs for entry or exit points (A.03.10.07.b).
  3. Escort visitors and control visitor activity (A.03.10.07.c[01] and c[02]).
  4. Secure keys, combinations, and other physical access devices (A.03.10.07.d).
  5. Control physical access to output devices to prevent unauthorized CUI access (A.03.10.07.e).
  6. Collect evidence for all seven (7) AOs, including access enforcement, logs, visitor records, device security, and output device controls.

Frequently Asked Questions About NIST 800-171 R3 03.10.07

How many assessment objectives does NIST 800-171 R3 03.10.07 have? NIST 800-171A R3 breaks 03.10.07 into seven (7) assessment objectives. An assessor works through each one separately, so each needs its own evidence.

Which NIST 800-53 R5 controls does NIST 800-171 R3 03.10.07 come from? PE-03, PE-05.

How many Organization-Defined Parameters (ODPs) does NIST 800-171 R3 03.10.07 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 03.10.07 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.

Bottom Line on NIST 800-171 R3 03.10.07

03.10.07 Physical Access Control enforces access at entry and exit points, maintains physical access logs, escorts and controls visitors, secures physical access devices, and controls access to output devices. It consolidates R2 3.10.3, 3.10.4, and 3.10.5, with audit logs and visitor escorting transitioning directly, while entry-exit enforcement and output device control are net new. The recurring problem is unattended output devices and visible screens. Enforce at the doors, log access, control visitors, secure keys, and protect output devices from unauthorized CUI access.

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.