NIST 800-171 Updates: What Contractors Need to Know

Last updated: January 23th, 2025

NIST 800-171 is a vital cybersecurity standard developed to safeguard Controlled Unclassified Information (CUI) in non-federal systems and organizations. Mandated for nearly all government contractors, it establishes the requirements necessary to protect sensitive government data from unauthorized access or disclosure. These standards apply universally, regardless of the contractor's industry or product offerings—be it office supplies, IT systems, or heavy machinery.

While NIST 800-171 ensures the security of CUI, it's not intended to serve as a comprehensive cybersecurity framework for the contractors' entire operations. Instead, it focuses solely on meeting federal requirements for handling CUI.

Table of contents

Recent Updates: NIST 800-171 Revision 3

The latest iteration, Revision 3, introduces several notable changes that contractors must address to remain compliant:

• New Requirements Added: 19 additional controls have been incorporated to strengthen security
• Requirements Removed: 33 controls were eliminated, reducing the total number of requirements from 110 to 97
• Scoring System Changes: The Supplier Performance Risk System (SPRS) scoring mechanism has been replaced, reflecting a new approach to assessing compliance

For contractors previously compliant with Revision 2, these updates necessitate a comprehensive review and reassessment to align with the updated requirements, especially when competing for new contracts.

NIST 800-171 and Its Role in CMMC

The Cybersecurity Maturity Model Certification (CMMC), developed by the Department of Defense (DoD), integrates elements of NIST 800-171 into its framework. While NIST 800-171 serves as a complete catalog of cybersecurity requirements, the CMMC selects and applies specific controls based on contract needs.

As NIST 800-171 evolves, the CMMC framework must adapt accordingly, potentially altering the requirements contractors need to meet for DoD contracts. This interplay underscores the importance of staying informed about updates to both standards.

Key Considerations for Service Providers

Service providers working with contractors should understand that implementing NIST 800-171 requirements ensures compliance with federal guidelines for CUI but does not comprehensively protect the contractor's broader operations. A holistic cybersecurity strategy that goes beyond NIST 800-171 is essential to defend against broader threats.

Supporting Documents for NIST 800-171

Several supplementary documents support the implementation and assessment of NIST 800-171:

• NIST 800-171A: Provides detailed guidelines for assessing compliance with the controls
• NIST 800-172: Offers enhanced security measures for protecting high-value targets such as critical infrastructure
• NIST 800-172A: Details assessment procedures for the enhanced controls in NIST 800-172

These documents provide additional depth for organizations handling high-risk or critical government projects.

Implications for Contractors

The release of Revision 3 highlights the dynamic nature of cybersecurity compliance. Contractors who recently achieved compliance with Revision 2 must now reevaluate and implement updates to adhere to the latest version.

Key takeaways include:

• A need for ongoing assessments to ensure alignment with updated standards
• Awareness of changes in compliance metrics, such as the removal of the SPRS scoring system
• Proactive engagement with service providers to implement both NIST 800-171 requirements and broader cybersecurity measures

Win Government Contracts with Cyber Compliance

Staying compliant with NIST 800-171 is critical for contractors handling CUI. However, Revision 3 introduces significant changes, making it imperative for organizations to reassess their compliance strategies. By addressing these updates and adopting a broader approach to cybersecurity, contractors can ensure they meet federal requirements while also protecting their overall operations.