NIST 800-171 Compliance

We have a Program to assist Suppliers to the Federal Government with meeting the requirements for Compliance with Executive Order 13556 and NIST 800-171

Our professional services include assisting with:

  • Initial Risk Assessments for Controlled Unclassied Information (CUI)
  • Preparation of a CUI Security Plan and Statement of Applicability
  • Preparation of Policies, Procedures and Control Objectives
  • Personnel Awareness Training
  • Auditing for Compliance to NIST 800-171 and ISO 27001

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Controlled Unclassified Information (CUI) supports federal missions and business functions that affect the economic and national security interests of the United States. Non-federal organizations (e.g. colleges, universities, state, local and tribal governments, federal contractors and subcontractors) often process, store, or transmit CUI.

Executive Order 13556, as issued November 10, 2010, designated the National Archives and Records Administration (NARA) as the Executive Agent to implement the CUI program. NIST Special Publication 800-171 defines the security requirements for protecting CUI in non-federal information systems and organizations. The final draft was made public in April 2015.


Security Requirements for Protecting the Confidentiality of CUI

NIST Special Publication 800-171 contains fourteen families of security requirements (including basic and derived requirements)18 for protecting the confidentiality of CUI in nonfederal information systems and organizations.

The security controls from NIST Special Publication 800-53 associated with the basic and derived requirements are also listed in Appendix D. Organizations can use Special Publication 800-53 to obtain additional, non-prescriptive information related to the CUI security requirements (e.g., supplemental guidance related to each of the referenced security controls, mapping tables to ISO/ IEC security controls, and a catalog of optional controls that can be used to help specify additional CUI requirements if needed).

The security requirements identified in 800-171 are intended to be applied to the non-federal organization’s general-purpose internal information systems that are processing, storing, or transmitting CUI. Some specialized systems such as medical devices, Computer Numerical Control (CNC) machines, or industrial control systems may have restrictions or limitations on the application of certain CUI requirements and may be granted waivers or exemptions from the requirements by the federal agency providing oversight.


Basic Security Requirements:

1.1 Limit information system access to authorized users, processes acting on behalf of authorized users, or devices (including other information systems).

1.2 Limit information system access to the types of transactions and functions that authorized users are permitted to execute.

Derived Security Requirements:

1.3 Control the flow of CUI in accordance with approved authorizations.

1.4 Separate the duties of individuals to reduce the risk of malevolent activity without collusion.

1.5 Employ the principle of least privilege, including for specific security functions and privileged accounts.

1.6 Use non-privileged accounts or roles when accessing nonsecurity functions.

1.7 Prevent non-privileged users from executing privileged functions and audit the execution of such functions.

1.8 Limit unsuccessful logon attempts.

1.9 Provide privacy and security notices consistent with applicable CUI rules.

1.10 Use session lock with pattern-hiding displays to prevent access/viewing of data after period of inactivity.

1.11 Terminate (automatically) a user session after a defined condition.

1.12 Monitor and control remote access sessions.

1.13 Employ cryptographic mechanisms to protect the confidentiality of remote access sessions.

1.14 Route remote access via managed access control points.

1.15 Authorize remote execution of privileged commands and remote access to security-relevant information.

1.16 Authorize wireless access prior to allowing such connections.

1.17 Protect wireless access using authentication and encryption.

1.18 Control connection of mobile devices.

1.19 Encrypt CUI on mobile devices.

1.20 Verify and control/limit connections to and use of external information systems.

1.21 Limit use of organizational portable storage devices on external information systems.

1.22 Control information posted or processed on publicly accessible information systems.


Basic Security Requirements:

2.1 Ensure that managers, systems administrators, and users of organizational information systems are made aware of the security risks associated with their activities and of the applicable policies, standards, and procedures related to the security of organizational information systems.

2.2 Ensure that organizational personnel are adequately trained to carry out their assigned information security-related duties and responsibilities.

Derived Security Requirements:

2.3 Provide security awareness training on recognizing and reporting potential indicators of insider threat.


Basic Security Requirements:

3.1 Create, protect, and retain information system audit records to the extent needed to enable the monitoring, analysis, investigation, and reporting of unlawful, unauthorized, or inappropriate information system activity.

3.2 Ensure that the actions of individual information system users can be uniquely traced to those users so they can be held accountable for their actions.

Derived Security Requirements:

3.3 Review and update audited events.

3.4 Alert in the event of an audit process failure.

3.5 Correlate audit review, analysis, and reporting processes for investigation and response to indications of inappropriate, suspicious, or unusual activity.

3.6 Provide audit reduction and report generation to support on-demand analysis and reporting.

3.7 Provide an information system capability that compares and synchronizes internal system clocks with an authoritative source to generate time stamps for audit records.

3.8 Protect audit information and audit tools from unauthorized access, modification, and deletion.

3.9 Limit management of audit functionality to a subset of privileged users.


Basic Security Requirements:

4.1 Establish and maintain baseline configurations and inventories of organizational information systems (including hardware, software, firmware, and documentation) throughout the respective system development life cycles.

4.2 Establish and enforce security configuration settings for information technology products employed in organizational information systems.

Derived Security Requirements:

4.3 Track, review, approve/disapprove, and audit changes to information systems.

4.4 Analyze the security impact of changes prior to implementation.

4.5 Define, document, approve, and enforce physical and logical access restrictions associated with changes to the information system.

4.6 Employ the principle of least functionality by configuring the information system to provide only essential capabilities.

4.7 Restrict, disable, and prevent the use of nonessential programs, functions, ports, protocols, and services.

4.8 Apply deny-by-exception (blacklist) policy to prevent the use of unauthorized software or deny-all, permit-by-exception (whitelisting) policy to allow the execution of authorized software.

4.9 Control and monitor user-installed software.


Basic Security Requirements:

5.1 Identify information system users, processes acting on behalf of users, or devices.

5.2 Authenticate (or verify) the identities of those users, processes, or devices, as a prerequisite to allowing access to organizational information systems.

Derived Security Requirements:

5.3 Use multifactor authentication for local and network access to privileged accounts and for network access to non-privileged accounts.

5.4 Employ replay-resistant authentication mechanisms for network access to privileged and non-privileged accounts.

5.5 Prevent reuse of identifiers for a defined period.

5.6 Disable identifiers after a defined period of inactivity.

5.7 Enforce a minimum password complexity and change of characters when new passwords are created.

5.8 Prohibit password reuse for a specified number of generations.

5.9 Allow temporary password use for system logons with an immediate change to a permanent password.

5.10 Store and transmit only encrypted representation of passwords.

5.11 Obscure feedback of authentication information.


Basic Security Requirements:

6.1 Establish an operational incident-handling capability for organizational information systems that includes adequate preparation, detection, analysis, containment, recovery, and user response activities.

6.2 Track, document, and report incidents to appropriate officials and/or authorities both internal and external to the organization.

Derived Security Requirements:

6.3 Test the organizational incident response capability.


Basic Security Requirements:

7.1 Perform maintenance on organizational information systems.24

7.2 Provide effective controls on the tools, techniques, mechanisms, and personnel used to conduct information system maintenance.

Derived Security Requirements:

7.3 Ensure equipment removed for off-site maintenance is sanitized of any CUI.

7.4 Check media containing diagnostic and test programs for malicious code before the media are used in the information system.

7.5 Require multifactor authentication to establish nonlocal maintenance sessions via external network connections and terminate such connections when nonlocal maintenance is complete.

7.6 Supervise the maintenance activities of maintenance personnel without required access authorization.


Basic Security Requirements:

8.1 Protect (i.e., physically control and securely store) information system media containing CUI, both paper and digital.

8.2 Limit access to CUI on information system media to authorized users.

8.3 Sanitize or destroy information system media containing CUI before disposal or release for reuse.

Derived Security Requirements:

8.4 Mark media with necessary CUI markings and distribution limitations.25

8.5 Control access to media containing CUI and maintain accountability for media during transport outside of controlled areas.

8.6 Implement cryptographic mechanisms to protect the confidentiality of CUI stored on digital media during transport unless otherwise protected by alternative physical safeguards.

8.7 Control the use of removable media on information system components.

8.8 Prohibit the use of portable storage devices when such devices have no identifiable owner.

8.9 Protect the confidentiality of backup CUI at storage locations.


Basic Security Requirements:

9.1 Screen individuals prior to authorizing access to information systems containing CUI.

9.2 Ensure that CUI and information systems containing CUI are protected during and after personnel actions such as terminations and transfers.

Derived Security Requirements: None.


Basic Security Requirements:

10.1 Limit physical access to organizational information systems, equipment, and the respective operating environments to authorized individuals.

10.2 Protect and monitor the physical facility and support infrastructure for those information systems.

Derived Security Requirements:

10.3 Escort visitors and monitor visitor activity.

10.4 Maintain audit logs of physical access.

10.5 Control and manage physical access devices.

10.6 Enforce safeguarding measures for CUI at alternate work sites (e.g., telework sites).


Basic Security Requirements:

11.1 Periodically assess the risk to organizational operations (including mission, functions, image, or reputation), organizational assets, and individuals, resulting from the operation of organizational information systems and the associated processing, storage, or transmission of CUI.

Derived Security Requirements:

11.2 Scan for vulnerabilities in the information system and applications periodically and when new vulnerabilities affecting the system are identified.

11.3 Remediate vulnerabilities in accordance with assessments of risk.


Basic Security Requirements:

12.1 Periodically assess the security controls in organizational information systems to determine if the controls are effective in their application.

12.2 Develop and implement plans of action designed to correct deficiencies and reduce or eliminate vulnerabilities in organizational information systems.

12.3 Monitor information system security controls on an ongoing basis to ensure the continued effectiveness of the controls.

Derived Security Requirements: None.


Basic Security Requirements:

13.1 Monitor, control, and protect organizational communications (i.e., information transmitted or received by organizational information systems) at the external boundaries and key internal boundaries of the information systems.

13.2 Employ architectural designs, software development techniques, and systems engineering principles that promote effective information security within organizational information systems.

Derived Security Requirements:

13.3 Separate user functionality from information system management functionality.

13.4 Prevent unauthorized and unintended information transfer via shared system resources.

13.5 Implement subnetworks for publicly accessible system components that are physically or logically separated from internal networks.

13.6 Deny network communications traffic by default and allow network communications traffic by exception (i.e., deny all, permit by exception).

13.7 Prevent remote devices from simultaneously establishing non-remote connections with the information system and communicating via some other connection to resources in external networks.

13.8 Implement cryptographic mechanisms to prevent unauthorized disclosure of CUI during transmission unless otherwise protected by alternative physical safeguards.

13.9 Terminate network connections associated with communications sessions at the end of the sessions or after a defined period of inactivity.

13.10 Establish and manage cryptographic keys for cryptography employed in the information system.

13.11 Employ FIPS-validated cryptography when used to protect the confidentiality of CUI.

13.12 Prohibit remote activation of collaborative computing devices and provide indication of devices in use to users present at the device.

13.13 Control and monitor the use of mobile code.

13.14 Control and monitor the use of Voice over Internet Protocol (VoIP) technologies.

13.15 Protect the authenticity of communications sessions.

13.16 Protect the confidentiality of CUI at rest.


Basic Security Requirements:

14.1 Identify, report, and correct information and information system flaws in a timely manner.

14.2 Provide protection from malicious code at appropriate locations within organizational information systems.

14.3 Monitor information system security alerts and advisories and take appropriate actions in response.

Derived Security Requirements:

14.4 Update malicious code protection mechanisms when new releases are available.

14.5 Perform periodic scans of the information system and real-time scans of files from external sources as files are downloaded, opened, or executed.

14.6 Monitor the information system including inbound and outbound communications traffic, to detect attacks and indicators of potential attacks.

14.7 Identify unauthorized use of the information system.


(14 DERIVED FROM 800-53)


Access Control Access Control
Awareness and Training Awareness and Training
Audit and Accountability Audit and Accountability
Configuration Management Configuration Management
(Not required by NIST 800-171) Contingency Planning
Identification and Authentication Identification and Authentication
Incident Response Incident Response
Maintenance Maintenance
Media Protection Media Protection
Personnel Security Personnel Security
Physical Protection Physical Protection and Environmental Protection
(Not required by NIST 800-171) Planning
(Not required by NIST 800-171) Program Management
Risk Assessment Risk Assessment
Security Assessment Security Assessment and Authorization
System and Communications Protection System and Communications Protection
System and Information Integrity System and Information Integrity
(Not required by NIST 800-171) System and Services Acquisitions

The development of the CUI security requirements and the expectation of federal agencies in working with nonfederal entities include:

  • Nonfederal organizations have information technology infrastructures in place, and are not necessarily developing or acquiring information systems specifically for the purpose of processing, storing, or transmitting CUI;
  • Nonfederal organizations have specific safeguarding measures in place to protect their information which may also be sufficient to satisfy the CUI security requirements;
  • Nonfederal organizations can implement a variety of potential security solutions either directly or through the use of managed services, to satisfy CUI security requirements; and
  • Nonfederal organizations may not have the necessary organizational structure or resources to satisfy every CUI security requirement and may implement alternative, but equally effective, security measures to compensate for the inability to satisfy a particular requirement.