Cryptographic Key Establishment and Management is the requirement that governs the full life cycle of the keys your encryption depends on. It is part of the System and Communications Protection (03.13) family, and it makes sure the keys protecting Controlled Unclassified Information (CUI) are generated, distributed, stored, accessed, and destroyed under defined rules. Cryptographic Key Establishment and Management (03.13.10) requires establishing and managing cryptographic keys in the system in accordance with defined key management requirements. Per the NIST discussion, keys can be established and managed using manual procedures or automated mechanisms supported by manual procedures, and organizations satisfy the requirements in accordance with applicable federal laws, Executive Orders, policies, directives, regulations, and standards.
A common difficulty with this requirement is deploying encryption without a defined key management approach, so keys get generated and stored in ad hoc ways with no rules for access or destruction. R3 makes the defining of those requirements an explicit, assessable objective, covering generation, distribution, storage, access, and destruction. Encryption that works but has no documented key management leaves the defining objective open.
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 03.13.10 Cryptographic Key Establishment and Management. Only the formatting has been adjusted for readability. This is a single statement with no lettered parts:
The source control is SC-12 from NIST 800-53. The bracketed assignment is the Organization-Defined Parameter (ODP): the key management requirements for generation, distribution, storage, access, and destruction. Per the NIST discussion, this requirement is related to Cryptographic Protection (03.13.11). You can read the requirement directly at NIST 800-171 R3, 03.13.10 (p. 61).
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.
Where the memo gives guidance rather than a fixed value, the guidance tells you how to approach the decision and the decision itself remains yours to make and document. The memorandum does this in four (4) instances across the whole publication.
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 03.13.10 into three (3) assessment objectives: one (1) Organization-Defined Parameter (ODP) and two (2) determination statements. These AOs are:
The objectives are defining the key management requirements (ODP[01]), establishing keys per those requirements (01), and managing keys per those requirements (02). If you are a DoD contractor, the ODP is specified. Per the DoD-specified ODP guidance in ComplianceForge's NIST 800-171 R3 Transition Guide, at a minimum establish a policy and procedure in line with the latest cryptographic key management guidance. The full guidance on assessment methods and objects, is in NIST 800-171A R3, 03.13.10 (p. 79).
Examine: system and communications protection policy and procedures; procedures for cryptographic key establishment and management; system design documentation; system configuration settings; cryptographic mechanisms; system audit records; system security plan.
Interview: personnel with responsibilities for cryptographic key establishment or management; personnel with information security responsibilities; system administrators.
Test: mechanisms for supporting or implementing cryptographic key establishment and management.
03.13.10 maps from NIST 800-171 R2 requirement 3.13.10 (establish and manage cryptographic keys for cryptography employed in organizational systems):
Mapped against the three (3) AOs, two (2) are direct (minimal effort) and one (1) has no clear mapping (significant effort). Establishing and managing keys carries forward, but the explicit requirement to define the key management rules across generation, distribution, storage, access, and destruction is the new work. Document those requirements rather than assuming your existing key handling satisfies the defining objective.
Source Control in NIST 800-53 R5:
Secure Controls Framework (SCF) Crosswalk
Organizations running a single control set across multiple frameworks can satisfy 03.13.10 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 defining the key life cycle rules, 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 03.13.10 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 03.13.10 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 03.13.10 recording the ODP values you adopted.
With two (2) AOs mapping directly and one with no clear mapping, 03.13.10 is a moderate lift centered on documenting the key life cycle. A realistic sequence:
What value does the DoD require for the organization-defined parameter in NIST 800-171 R3 03.13.10? R3 leaves the value to the organization. For the DIB, the DoD set it in the 10 April 2025 memorandum under ODP identifier 03.13.10: guidance rather than a fixed value. At a minimum, establish a policy and procedure in line with the latest Cryptographic key management guidance.
How many assessment objectives does NIST 800-171 R3 03.13.10 have? NIST 800-171A R3 breaks 03.13.10 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 control does NIST 800-171 R3 03.13.10 come from? SC-12.
Where does NIST 800-171 R3 03.13.10 sit in the NIST 800-171 R3 Kill Chain? Phase 19, Cryptographic Key Management. The Kill Chain is a phased model for sequencing R3 implementation, and it assigns this requirement to that phase.
03.13.10 Cryptographic Key Establishment and Management establishes and manages cryptographic keys in accordance with defined requirements for generation, distribution, storage, access, and destruction. It maps from R2 3.13.10 with establishing and managing keys transitioning directly, while defining the key management rules is the new work. The recurring problem is running encryption with no documented key management. Define the rules across the full key life cycle, establish and manage keys accordingly, and align with your cryptographic protection mechanisms.
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.
