Supply Chain Risk Management Plan is the first requirement in the Supply Chain Risk Management (03.17) family, which is entirely new in R3. There was no supply chain family in R2 at all, so every requirement here is new ground for contractors. Supply Chain Risk Management Plan (03.17.01) has three (3) parts: develop a plan for managing supply chain risks across the full life cycle of the system, review and update the plan on a defined frequency, and protect the plan from unauthorized disclosure. Per the NIST discussion, threat actions that may increase security risks include unauthorized production, the insertion or use of counterfeits, tampering, poor manufacturing and development practices in the supply chain, theft, and the insertion of malicious software, firmware, and hardware.
A common difficulty with this requirement is not realizing the plan must address ten distinct life cycle stages, each of which is its own assessment objective. A one-page supply chain statement will not survive an assessment that walks from research and development through disposal. Per the NIST discussion, the system-level Supply Chain Risk Management (SCRM) plan is implementation-specific and can either be stand-alone or incorporated into system security plans, and SCRM plans are tailored to individual program, organizational, and operational contexts.
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 03.17.01 Supply Chain Risk Management Plan. Only the formatting has been adjusted for readability. This requirement has three (3) lettered parts:
The source control is SR-02 from NIST 800-53. The bracketed assignment in part b is the Organization-Defined Parameter (ODP): the review and update frequency. Per the NIST discussion, SCRM activities include identifying and assessing risks, determining appropriate risk response actions, developing SCRM plans to document response actions, and monitoring performance against the plans. You can read the requirement directly at NIST 800-171 R3, 03.17.01 (p. 72).
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 03.17.01 into fourteen (14) assessment objectives: one (1) Organization-Defined Parameter (ODP) and thirteen (13) determination statements. These AOs are:
Each of the nine life cycle stages named in the requirement becomes its own objective (a[02] through a[10]) on top of developing the plan itself (a[01]). 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 review and 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, 03.17.01 (p. 94).
Examine: SCRM policy and procedures; SCRM plan; system and services acquisition policy and procedures; system and services acquisition procedures; procedures for supply chain protection; procedures for protecting the SCRM plan from unauthorized disclosure; system development life cycle procedures; procedures for the integration of information security requirements into the acquisition process; acquisition documentation; service-level agreements; acquisition contracts for the system, system components, or system services; list of supply chain threats; list of safeguards for supply chain threats; system life cycle documentation, including research and development, design, manufacturing, acquisition, delivery, integration, operations, maintenance, and disposal; inter- organizational agreements and procedures; system security plan.
Interview: personnel with acquisition responsibilities; personnel with SCRM responsibilities; personnel with information security responsibilities.
Test: organizational processes for defining and documenting the system development life cycle (SDLC); organizational processes for identifying SDLC roles and responsibilities; organizational processes for integrating SCRM into the SDLC; mechanisms for supporting or implementing the SDLC.
03.17.01 is net new for R3 and has no corresponding requirement in NIST 800-171 R2, which had no supply chain risk management family:
Mapped against the fourteen (14) AOs, all fourteen (14) are net new (significant effort), with none direct, indirect, or unmapped. The source control, SR-02, has no R2 predecessor, though the transition mapping notes that the plan development objective has elements of the R2 non-federal organization (NFO) control PS-7. This is the single largest block of net-new objectives in any R3 requirement, so treat it as a program to build rather than a document to update.
Source Control in NIST 800-53 R5:
Secure Controls Framework (SCF) Crosswalk
Organizations running a single control set across multiple frameworks can satisfy 03.17.01 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 pitfalls for this net-new requirement are about life cycle coverage and protecting the plan, 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 03.17.01 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 03.17.01 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 03.17.01 recording the ODP values you adopted.
With all fourteen (14) AOs net new, 03.17.01 is the heaviest single lift in R3 and needs real lead time. A realistic sequence:
What value does the DoD require for the organization-defined parameter in NIST 800-171 R3 03.17.01? R3 leaves the value to the organization. For the DIB, the DoD set it in the 10 April 2025 memorandum under ODP identifier 03.17.01.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 03.17.01 have? NIST 800-171A R3 breaks 03.17.01 into fourteen (14) assessment objectives: one (1) Organization-Defined Parameters (ODPs) and thirteen (13) 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 03.17.01 come from? SR-02.
Where does NIST 800-171 R3 03.17.01 sit in the NIST 800-171 R3 Kill Chain? Phase 4b, Risk Management Practices. The Kill Chain is a phased model for sequencing R3 implementation, and it assigns this requirement to that phase.
03.17.01 Supply Chain Risk Management Plan develops a plan covering supply chain risks across nine life cycle stages, reviews and updates it on a defined frequency, and protects it from unauthorized disclosure. The entire Supply Chain Risk Management family is net new for R3, and this requirement carries fourteen new objectives, more than any other. The recurring problem is a thin, generic supply chain statement. Build a real plan, address every life cycle stage explicitly (including the ones you think do not apply to you), protect the document, and review it at least every twelve months.
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.
