Information Management and Retention is a net-new requirement in R3 that closes out the System and Information Integrity (03.14) family, and it addresses a problem most contractors have never formally handled: how long Controlled Unclassified Information (CUI) sticks around and under what rules. Information Management and Retention (03.14.08) requires managing and retaining CUI within the system and CUI output from the system in accordance with applicable laws, Executive Orders, directives, regulations, policies, standards, guidelines, and operational requirements. Per the NIST discussion, retaining CUI on nonfederal systems after contracts or agreements have concluded increases the attack surface for those systems and the risk of the information being compromised, and the National Archives and Records Administration (NARA) provides federal policy and guidance on records retention and schedules.
A common difficulty with this requirement is keeping CUI forever. Old contract data sits on file shares and in backups years after the work ended, which is exactly the risk the NIST discussion calls out. This requirement is new for R3, so most organizations have no CUI-specific retention rules and no process for disposing of CUI when the retention period expires. The requirement also reaches beyond the system itself to CUI output from the system, which is the part teams most often miss.
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 03.14.08 Information Management and Retention. Only the formatting has been adjusted for readability. This is a single statement with no lettered parts:
The source control is SI-12 from NIST 800-53. There are no Organization-Defined Parameters (ODPs). Per the NIST discussion, federal agencies consider data retention requirements for nonfederal organizations, and NARA provides federal policy and guidance on records retention and schedules. You can read the requirement directly at NIST 800-171 R3, 03.14.08 (p. 67).
None (0). Requirement 03.14.08 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 03.14.08 therefore records how the requirement is implemented rather than a parameter you chose.
NIST 800-171A R3 breaks 03.14.08 into four (4) determination statements, and it has no Organization-Defined Parameters (ODPs). These AOs are:
The single statement expands into a two-by-two grid: managing and retaining, applied to CUI within the system and to CUI output from the system. An assessor checks all four. The full guidance on assessment methods and objects, is in NIST 800-171A R3, 03.14.08 (p. 88).
Examine: system and information integrity policy and procedures; laws, Executive Orders, directives, policies, regulations, standards, and operational requirements applicable to information management and retention; records retention and disposition policy; records retention and disposition procedures; media protection policy; media protection procedures; audit findings; system security plan.
Interview: personnel with information and records management, retention, and disposition responsibilities; personnel with information security responsibilities; system administrators.
Test: processes for information management, retention, and disposition; mechanisms for supporting or implementing information management, retention, and disposition.
03.14.08 is net new for R3 and has no corresponding requirement in NIST 800-171 R2:
Mapped against the four (4) AOs, all four (4) are net new (significant effort), with none direct, indirect, or unmapped. The source control, SI-12, was an assumed control in R2 rather than one that R2 separately assessed, so there is no transition path. Build a documented CUI management and retention approach rather than assuming your general records retention policy covers it.
Source Control in NIST 800-53 R5:
Secure Controls Framework (SCF) Crosswalk
Organizations running a single control set across multiple frameworks can satisfy 03.14.08 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 pitfalls for this net-new requirement are about scope and disposal, 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 03.14.08 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 03.14.08 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 03.14.08.
With all four (4) AOs net new, 03.14.08 is a significant lift built as a program rather than a setting. A realistic sequence:
How many assessment objectives does NIST 800-171 R3 03.14.08 have? NIST 800-171A R3 breaks 03.14.08 into four (4) assessment objectives. An assessor works through each one separately, so each needs its own evidence.
Which NIST 800-53 R5 control does NIST 800-171 R3 03.14.08 come from? SI-12.
How many Organization-Defined Parameters (ODPs) does NIST 800-171 R3 03.14.08 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 03.14.08 sit in the NIST 800-171 R3 Kill Chain? Phase 8, Segmented Network Architecture. The Kill Chain is a phased model for sequencing R3 implementation, and it assigns this requirement to that phase.
03.14.08 Information Management and Retention manages and retains CUI both within the system and output from the system according to applicable laws, regulations, and operational requirements. It is net new for R3 with no R2 predecessor, so all four (4) objectives are new work. The recurring problem is keeping CUI indefinitely and forgetting that exports and reports are in scope. Identify the authorities that govern your CUI, set management and retention rules covering data inside and outside the system, and prove that CUI actually gets disposed of when its time is up.
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.
