Risk Assessment is the first requirement in the Risk Assessment (03.11) family, and it is the foundation for risk-based decisions across the framework. It requires assessing the risk of unauthorized disclosure of Controlled Unclassified Information (CUI), including supply chain risk, and updating those assessments on a defined frequency. Risk Assessment (03.11.01) is what turns compliance from a checklist into a set of prioritized decisions, because it tells you where your actual exposure is. Per the NIST discussion, establishing the system boundary is a prerequisite, risk assessments consider threats, vulnerabilities, likelihood, and impacts, and they also consider risks from external parties such as contractors, service providers, and outsourcing entities.
A common difficulty with this requirement is treating the risk assessment as a one-time document or omitting supply chain risk. R3 is explicit that supply chain risk is in scope, which pulls contractors, service providers, and the components they provide into the assessment. It also ties updates to a defined frequency, so a risk assessment that is never refreshed does not satisfy the requirement. For Department of Defense (DoD) contractors, the update 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 03.11.01 Risk Assessment. Only the formatting has been adjusted for readability. This requirement has two (2) lettered parts:
The source controls are RA-03, RA-03(01), and SR-06 from NIST 800-53. The bracketed assignment in part b is the Organization-Defined Parameter (ODP): the update frequency. Per the NIST discussion, risk assessments can be conducted at the organization, mission or business process, or system level, and they include supply chain-related risks associated with suppliers or contractors and the components or services they provide. You can read the requirement directly at NIST 800-171 R3, 03.11.01 (p. 53).
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 03.11.01 into three (3) assessment objectives: one (1) Organization-Defined Parameter (ODP) and two (2) determination statements. These AOs are:
The determination statements are assessing the risk and updating the assessment. 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 update 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, 03.11.01 (p. 69).
Examine: risk assessment policy and procedures; security planning policy and procedures; procedures for organizational assessments of risk; risk assessment; risk assessment results; risk assessment reviews; risk assessment updates; SCRM policy and procedures; inventory of critical systems, system components, and system services; procedures for organizational assessments of supply chain risk; acquisition policy; SCRM plan; system security plan.
Interview: personnel with risk assessment responsibilities; personnel with SCRM responsibilities; personnel with security responsibilities.
Test: processes for organizational risk assessments; mechanisms for supporting or conducting, documenting, reviewing, disseminating, and updating risk assessments; mechanisms for supporting or conducting, documenting, reviewing, disseminating, and updating supply chain risk assessments.
03.11.01 maps from NIST 800-171 R2 requirement 3.11.1 (periodically assess the risk to organizational operations, assets, and individuals resulting from the operation of organizational systems and the associated processing, storage, or transmission of CUI):
Mapped against the three (3) AOs, all three (3) are direct (minimal effort), with no net-new AOs and none with no mapping. This is a clean carry-forward. The one substantive addition is the explicit inclusion of supply chain risk in part a, which R2 addressed less directly. Confirm your risk assessment considers supply chain risk and is updated on the defined frequency.
Source Controls in NIST 800-53 R5:
Secure Controls Framework (SCF) Crosswalk
Organizations running a single control set across multiple frameworks can satisfy 03.11.01 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 scope and cadence, 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 03.11.01 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 03.11.01 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 03.11.01 recording the ODP values you adopted.
With all three (3) AOs mapping directly, 03.11.01 is a light lift if you already assess risk. A realistic sequence:
What value does the DoD require for the organization-defined parameter in NIST 800-171 R3 03.11.01? R3 leaves the value to the organization. For the DIB, the DoD set it in the 10 April 2025 memorandum under ODP identifier 03.11.01.b: 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 03.11.01 have? NIST 800-171A R3 breaks 03.11.01 into three (3) assessment objectives: one (1) Organization-Defined Parameters (ODPs) and two (2) 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 03.11.01 come from? RA-03, RA-03(01), SR-06.
Where does NIST 800-171 R3 03.11.01 sit in the NIST 800-171 R3 Kill Chain? Phase 4a, Risk Management Practices. The Kill Chain is a phased model for sequencing R3 implementation, and it assigns this requirement to that phase.
03.11.01 Risk Assessment assesses the risk of unauthorized disclosure of CUI, including supply chain risk, and updates the assessment on a defined frequency. It maps directly from R2 3.11.1, with R3 making supply chain risk explicit. The recurring problem is a one-time assessment that omits the supply chain. Assess the risk including supply chain, and update it (for DoD, at least every twelve months or on significant incidents or risk changes).
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.
