NIST SP 800-171

NIST Special Publication 800-171 lists the security requirements for protecting CUI on nonfederal information systems. DFARS 252.204-7012 makes it contractual for defense work — held at Revision 2 by class deviation — and its 110 requirements are the CMMC Level 2 baseline.

NIST wrote 800-171 as the requirements catalog for contractor systems that process, store, or transmit CUI. Revision 2 contains 110 requirements across families like access control, incident response, and system integrity. Revision 3, published May 2024, reorganizes the set into 17 families and adds organization-defined parameters — values the government fills in — and superseded Revision 2 at NIST the same day.

Contracts are where the version question bites. DFARS 252.204-7012 points to the edition in effect when the solicitation issues, but class deviation 2024-O0013 holds DoD contracts to Revision 2, and it stays operative until rescinded. Clauses 252.204-7019 and -7020 require a DoD Assessment Methodology score posted in SPRS, and CMMC Level 2 assesses the same 110 requirements.

A system security plan and a POA&M are not compliance, though contractors keep treating them that way. The posted score has to reflect what is implemented on the day it is affirmed; a Medium or High government assessment re-derives it from evidence, not paperwork.

Regulatory Reference

NIST SP 800-171 Rev. 2; DFARS 252.204-7012; DFARS 252.204-7019; DFARS 252.204-7020; DoD Class Deviation 2024-O0013

RFO Status

The June 2026 proposed FAR CUI framework (FAR Case 2026-001) would carry 800-171 governmentwide, its standard form specifying organization-defined parameters for Revision 3, while DoD's class deviation keeps DFARS work on Revision 2.

Category

Regulations & Policy

How AcqBot Helps

AcqBot flags when a requirement triggers 800-171, applies the revision the operative deviation actually imposes, and verifies an offeror's SPRS assessment date and score during evaluation rather than after award.