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How Do I Implement NIST 800-171 R3 03.14.01 Flaw Remediation?

NIST 800-171 R3 03.14.01 Flaw Remediation at a Glance

  • Family: 03.14 System and Information Integrity (SI)
  • Requirement ID: 03.14.01 Flaw Remediation
  • Assessment Objectives (AOs): Seven (7) total, including the two (2) Organization-Defined Parameters (ODPs) below and five (5) determination statements
  • Organization-Defined Parameters (ODPs): One (1), specified by the Department of Defense (DoD) for the Defense Industrial Base (DIB)
  • Source NIST 800-53 R5 Control: SI-02
  • NIST 800-171 R3 Kill Chain Phase: Phase 15, Attack Surface Management (ASM)

Flaw Remediation is the first requirement in the System and Information Integrity (03.14) family, and it is patching discipline written down as a control. It covers finding flaws, telling the right people about them, fixing them, and getting security-relevant updates installed inside a defined window. Flaw Remediation (03.14.01) has two (2) parts: identify, report, and correct system flaws, and install security-relevant software and firmware updates within a defined time period of their release. Per the NIST discussion, security-relevant updates include patches, service packs, hot fixes, and anti-virus signatures, and organizations can take advantage of available resources such as the Common Weakness Enumeration (CWE) or Common Vulnerabilities and Exposures (CVE) databases when remediating system flaws.

A common difficulty with this requirement is patching software on a schedule while firmware quietly falls years behind. R3 separates software updates and firmware updates into distinct assessment objectives with their own time periods, so a patch program that never touches firmware leaves objectives open. For Department of Defense (DoD) contractors the installation windows are specified and tied to flaw risk level.

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 The withdrawal notice states that R2 "has been withdrawn (archived), and is provided solely for historical purposes," so it will never receive another correction or clarification from NIST.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 03.14.01 Actually Require?

The following is reproduced verbatim from NIST 800-171 R3, requirement 03.14.01 Flaw Remediation. Only the formatting has been adjusted for readability. This requirement has two (2) lettered parts:

  • a. Identify, report, and correct system flaws.
  • b. Install security-relevant software and firmware updates within [Assignment: organization-defined time period] of the release of the updates.

The source control is SI-02 from NIST 800-53. The bracketed assignment in part b is the Organization-Defined Parameter (ODP): the update installation time period, which NIST 800-171A R3 splits into separate parameters for software and firmware. Per the NIST discussion, organizations address flaws discovered during security assessments, continuous monitoring, incident response activities, and system error handling, and the time periods may vary based on factors including the criticality of the update. You can read the requirement directly at NIST 800-171 R3, 03.14.01 (p. 63).

What Are the Organization-Defined Parameters (ODPs) Associated with NIST 800-171 R3 03.14.01?

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.

  • ODP[01] (DoD memo identifier 03.14.01.b). the time period within which to install security-relevant software updates after the release of the updates is defined. DoD Position: thirty (30) days for high-risk flaws (including both critical and high), 90 days for moderate-risk flaws, and 180 days for low-risk flaws.
  • ODP[02] (DoD memo identifier 03.14.01.b). the time period within which to install security-relevant firmware updates after the release of the updates is defined. DoD Position: thirty (30) days for high-risk flaws (including both critical and high), 90 days for moderate-risk flaws, and 180 days for low-risk flaws.

Note the asymmetry: NIST 800-171A R3 decomposes this requirement into two (2) Organization-Defined Parameters, while the DoD memorandum addresses them with one (1) entry, because a single bracketed assignment in the requirement text covers more than one parameter under assessment. Each ODP still needs its own answer in the System Security Plan (SSP).

The memo states that its values "will be updated as necessary," so confirm against the current version before writing them into policy.

What Are the Assessment Objectives (AOs) For NIST 800-171 R3 03.14.01?

NIST 800-171A R3 breaks 03.14.01 into seven (7) assessment objectives: two (2) Organization-Defined Parameters (ODPs) and five (5) determination statements. These AOs are:

  • A.03.14.01.ODP[01]: the time period within which to install security-relevant software updates after the release of the updates is defined.
  • A.03.14.01.ODP[02]: the time period within which to install security-relevant firmware updates after the release of the updates is defined.
  • A.03.14.01.a[01]: system flaws are identified.
  • A.03.14.01.a[02]: system flaws are reported.
  • A.03.14.01.a[03]: system flaws are corrected.
  • A.03.14.01.b[01]: security-relevant software updates are installed within <A.03.14.01.ODP[01]: time period> of the release of the updates.
  • A.03.14.01.b[02]: security-relevant firmware updates are installed within <A.03.14.01.ODP[02]: time period> of the release of the updates.

Note that the single time period in the requirement text becomes two separate parameters in the assessment: one for software (ODP[01]) and one for firmware (ODP[02]). If you are a DoD contractor, the ODPs are specified. Per the DoD-specified ODP value in ComplianceForge's NIST 800-171 R3 Transition Guide, the installation time period is thirty (30) days for high-risk flaws (including both critical and high), ninety (90) days for moderate-risk flaws, and one hundred eighty (180) days for low-risk flaws. The full guidance on assessment methods and objects, is in NIST 800-171A R3, 03.14.01 (p. 83).

Assessment Methods and Objects for NIST 800-171 R3 03.14.01

Examine: system and information integrity policy and procedures; procedures for flaw remediation; procedures for configuration management; list of recent security flaw remediation actions performed on the system; list of flaws and vulnerabilities that may potentially affect the system; test results from the installation of software and firmware updates to correct system flaws; installation and change control records for security-relevant software and firmware updates; system security plan.

Interview: personnel responsible for installing, configuring, or maintaining the system; personnel responsible for flaw remediation; personnel with configuration management responsibilities; personnel with information security responsibilities; system administrators.

Test: processes for identifying, reporting, and correcting system flaws; processes for installing software and firmware updates; mechanisms for supporting or implementing the reporting and correction of system flaws; mechanisms for supporting or implementing the testing software and firmware updates.

How Does NIST 800-171 R3 03.14.01 Map From NIST 800-171 R2?

03.14.01 maps from NIST 800-171 R2 requirement 3.14.1 (identify, report, and correct system flaws in a timely manner):

  • A.03.14.01.a[01] maps directly to R2 3.14.1[b] (system flaws are identified).
  • A.03.14.01.a[02] maps directly to R2 3.14.1[d] (system flaws are reported).
  • A.03.14.01.a[03] maps directly to R2 3.14.1[f] (system flaws are corrected).
  • A.03.14.01.ODP[01], A.03.14.01.ODP[02], and A.03.14.01.b[01] have no clear mapping to any R2 assessment objective.
  • A.03.14.01.b[02] is net new for R3.

Mapped against the seven (7) AOs, three (3) are direct (minimal effort), three (3) have no clear mapping, and one (1) is net new, with the last two (2) categories both counting as significant effort. Identifying, reporting, and correcting flaws carries forward cleanly. What changed is where the clock lives: R2 attached timeframes to identifying, reporting, and correcting flaws, while R3 attaches defined time periods to installing security-relevant software and firmware updates. Four of the seven (7) objectives are significant effort, and firmware update installation is the fully net-new one.

How Does NIST 800-171 R3 03.14.01 Map to NIST 800-53 R5 and the SCF?

Source Control in NIST 800-53 R5:

  • SI-02

Secure Controls Framework (SCF) Crosswalk

Organizations running a single control set across multiple frameworks can satisfy 03.14.01 through the following SCF controls:

  • IAO-12 Capabilities Deficiency Tracking
  • TDA-02 Technology Development & Acquisition
  • TDA-17 Security, Compliance & Resilience Testing Throughout Development
  • THR-02 Threat Intelligence Program
  • THR-12 Vulnerability Disclosure Program (VDP)
  • VPM-02 Vulnerability & Patch Management Program (VPMP)
  • VPM-03 Attack Surface Scope
  • VPM-06 Vulnerability Remediation Process
  • VPM-06.2 Continuous Vulnerability Remediation Activities
  • VPM-08 Software & Firmware Patching
  • VPM-12 Vulnerability Scanning

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 03.14.01

The following are issues teams may encounter rather than certainties. They are about firmware and the defined windows, each of which needs documented evidence of due diligence and due care such as policies, standards, procedures, and configuration screenshots:

  • Firmware is its own objective. A.03.14.01.b[02] is net new and covers firmware updates specifically, so a patch program that only addresses operating systems and applications leaves this objective open.
  • Define both time periods. A.03.14.01.ODP[01] and ODP[02] require separate defined windows for software and firmware, and DoD ties them to flaw risk level at thirty, ninety, and one hundred eighty days.
  • Reporting is separate from correcting. A.03.14.01.a[02] requires flaws to be reported to designated personnel, so fixing a flaw quietly without reporting it leaves an objective open.
  • Feed from your other controls. Per the NIST discussion, flaws surface during security assessments, continuous monitoring, incident response, and error handling, so connect Vulnerability Monitoring and Scanning (03.11.02) and Continuous Monitoring (03.12.03) into this process.

What Is Reasonable Evidence For NIST 800-171 R3 03.14.01?

Reasonable objective evidence for an assessment is often subjective. The following examples of evidence to address NIST 800-171 R3 03.14.01 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 03.14.01 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.

  • E-MNT-03 Patch Management. Maintenance activities for technology assets, applications and/or services (taas) (e.g., patch management).
  • E-RSK-03 Plan of Actions & Milestones (POA&M) / Risk Register. A poa&m, or risk register, that tracks control deficiencies from identification through remediation.
  • E-TDA-02 Secure Engineering & Data Privacy (SEDP). A secure engineering & data privacy (sedp) program. this is program-level documentation in the form of a runbook, playbook or a similar format provides guidance on organizational practices that support existing policies and standards.
  • E-TDA-03 Application Security Testing (AST). Application security testing (e.g., dast, sast, fuzzing, etc.).
  • E-TDA-16 Vulnerability Disclosure Program (VDP). A vulnerability disclosure program (vdp) (e.g., bug bounty).
  • E-THR-04 Threat Intelligence Program (TIP). A formal capability that intakes and analysis threat information to determine specific threat to the organization and necessary actions to mitigate the threat(s).
  • E-THR-05 Threat Mitigation. Steps taken to mitigate identified threats.
  • E-VPM-01 Vulnerability & Patch Management Program (VPMP). A vulnerability & patch management program (vpmp). this is program-level documentation in the form of a runbook, playbook or a similar format provides guidance on organizational practices that support existing policies and standards.
  • E-VPM-06 Attack Surface Scope. The organization defining its attack surface (e.g., may be in the form of graphical network diagrams or other forms of written documentation).
  • E-VPM-07 Flaw Remediation Change Control. Installation/change control records for security-relevant software and firmware updates.
  • E-VPM-09 Flaw Remediation Actions. List of recent security flaw remediation actions performed on the system (e.g., list of installed patches, service packs, hot fixes, and other software updates to correct system flaws).
  • E-VPM-11 Vulnerability Scanning. Internal and external vulnerability scans being performed.

Alongside these, keep the System Security Plan (SSP) narrative for 03.14.01 recording the ODP values you adopted.

Timeline Considerations for NIST 800-171 R3 03.14.01

With three (3) AOs mapping directly, three with no clear mapping, and one net new, 03.14.01 is a significant lift concentrated on update windows and firmware. A realistic sequence:

  1. Define the installation time periods for security-relevant software and firmware updates (A.03.14.01.ODP[01] and ODP[02], using the DoD windows of thirty, ninety, and one hundred eighty days by risk level).
  2. Confirm the process identifies, reports, and corrects system flaws (A.03.14.01.a[01] through a[03]).
  3. Confirm security-relevant software updates are installed within the defined window (A.03.14.01.b[01]).
  4. Extend the program to firmware and confirm those updates are installed within the defined window (A.03.14.01.b[02]), the net-new objective.
  5. Collect evidence for all seven (7) AOs, including the defined windows and installation records showing updates landed inside them.

Frequently Asked Questions About NIST 800-171 R3 03.14.01

What value does the DoD require for the organization-defined parameter in NIST 800-171 R3 03.14.01? R3 leaves the value to the organization. For the DIB, the DoD set it in the 10 April 2025 memorandum under ODP identifier 03.14.01.b: thirty (30) days for high-risk flaws (including both critical and high), 90 days for moderate-risk flaws, and 180 days for low-risk flaws.

How many assessment objectives does NIST 800-171 R3 03.14.01 have? NIST 800-171A R3 breaks 03.14.01 into seven (7) assessment objectives: two (2) Organization-Defined Parameters (ODPs) and five (5) 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 03.14.01 come from? SI-02.

Where does NIST 800-171 R3 03.14.01 sit in the NIST 800-171 R3 Kill Chain? Phase 15, Attack Surface Management (ASM). 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 03.14.01

03.14.01 Flaw Remediation identifies, reports, and corrects system flaws, and installs security-relevant software and firmware updates within defined time periods. It maps from R2 3.14.1 with the identify, report, and correct objectives transitioning directly, while the update installation windows are new work and firmware updates are net new. The recurring problem is patching software on schedule and letting firmware drift. Define both windows (for DoD, thirty days for high-risk, ninety for moderate, one hundred eighty for low), report flaws as well as fix them, and prove updates landed inside the window.

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.