If your organization works with Controlled Unclassified Information (CUI) or wants to work with the federal government, NIST 800-171 must be adhered to. The framework contains 110 requirements organized across 14 families. Let’s look a bit closer at what you need to understand about the compliance guidelines for NIST 800-171.
What is NIST 800-171 Compliance?
NIST 800-171 is a special publication outlining the requirements that all non-federal systems and organizations that transmit, process, or store CUI must abide by. This includes federal agencies, subcontractors, service providers, and vendors working with government agencies in some way. It’s part of the government risk and compliance standards necessary for those seeking government contracts.
The system bolsters CUI protections on non-federal systems linked to critical government programs, as these are more vulnerable targets of malicious attacks that require sophisticated methods to penetrate defenses. Therefore, this document offers enhanced cybersecurity requirements that should be integrated into established information security programs.
The 110 security requirements have been organized into 14 families. Each covers different security aspects, ranging from access control to system and information integrity, with ten families adding further requirements based on NIST 800-171 that provide higher CUI protection levels.
What's the Purpose of the NIST 800 Documents?
NIST 800-171 is part of the NIST Cybersecurity Framework (CSF). It specifies how potential and current contractors, subcontractors, or business partners who interact with federal agencies should manage CUI. Furthermore, this publication details cybersecurity requirements businesses must fulfill to receive federal government contracts; noncompliance may lead to contract termination.
The NIST 800 documents provide guidelines and security policies businesses must have to be eligible for specific Department of Defense (DoD) contracts. They do not represent an exhaustive list of cybersecurity standards businesses must abide by; they serve as federal contractors' baseline requirements.
NIST SP 800-171 was developed as part of an executive order requiring federal agencies to protect sensitive data more carefully, with guidelines provided for third parties and any companies looking to do business or collaborate on projects with them to follow.
Any company that wants to collaborate must also undergo an evaluation against this framework by an accredited Third-Party Assessment Organization (C3PAO) to see if they can adequately secure federal information.
What is NIST 800-171 For?
As a defense contractor, to do business with the federal government, you must follow the standards of NIST 800-171 compliance. This framework serves as a legal requirement that ensures you safeguard CUI.
Noncompliance can result in penalties, including contract termination. Even if you do not currently have an arrangement with the government, one eventually will arise, so it would be prudent to prepare yourself for a NIST security assessment now.
Who Does the NIST 800-171 Apply To?
NIST 800-171 assessments are mandatory for non-federal organizational systems that process, store, or transmit CUI. If you possess federal contracts or intend to apply for them in the future, being NIST 800-171 compliant is necessary; failing to meet its cybersecurity requirements could thwart new bids and derail ongoing ones.
Most DFARS contract awards require compliance with FISMA's cybersecurity requirements and NIST SP 800-171. To succeed, you will require an effective framework that aligns your other cybersecurity practices with NIST SP 800-171 and related security controls. With a solid risk management strategy, you can stay compliant.
How Does a NIST 800-171 Assessment Work?
NIST 800-171 does not use certification bodies or official audits as evidence of compliance; contractors must self-assess and self-attest for their adherence to its 110 security requirements. Each contractor bears responsibility for showing proof of adherence.
NIST 800-171A organizes 110 security requirements into 14 families of related topics to make understanding and applying the standards easier for organizations. Each family contains 320 objectives to help assessors understand how contractors implemented each control; additionally, an SSP should contain documentation showing whether they have achieved all these objectives.
SSPs should document the contractor's security architecture, providing an overall summary-level score (e.g. 95 out of 110) based on information gleaned from their plan. Finally, SSPs should document when the contractor expects to reach a compliant score of 110.
What Revisions Have Been Made to NIST 800-171?
NIST recently issued a draft version of their third revision of SP 800-171 changes: Protecting Controlled Unclassified Information. Contractors that handle CUI should review the changes and plan to implement any necessary updates to their systems and processes. The latest draft includes significant updates, such as adding security requirements to several control families.
NIST recently issued new security requirements focusing on planning, system and service acquisition, supply chain risk management, and existing requirements being recategorized or removed altogether. They also introduced a prototype CUI Overlay tool to help organizations assess compliance with this standard.
Other key changes include an increased specificity in security requirements and adding organization-defined parameters (ODP) to select controls. These modifications provide greater flexibility during implementation and assessment while meeting security objectives set by NIST SP 800-171.
What is the Difference Between NIST 800-171 and 800-53?
NIST 800-171 and 800-53 are often confusing security standards. While both standards require organizational systems to implement security controls, their requirements and scope differ considerably.
The NIST 800-171 focuses on non-federal organizations handling federal information specifically, while NIST 800-53 provides more technical yet prescriptive Risk Management Framework requirements requiring both security control implementation and a regular risk evaluation process to comply.
One key difference between NIST 800-171 and 800-53 is their respective requirements structures. NIST 800-171 only lists 14 families, while NIST 800-53 provides much greater detail regarding implementing and assessing security controls than NIST SP 800-171.
Requirements for NIST 800-171 Compliance
Whether your contract with DoD is active or future, you must remain compliant with NIST 800-171 requirements. This NIST framework governs how non-federal agencies protect CUI within their systems and organizations. It’s the basis of DFARS cybersecurity requirements that contractors and subcontractors must abide by to maintain data security.
To achieve NIST 800-171 compliance, you must run a self-assessment of your cybersecurity system. Either you do it alone or engage a partner for assistance; either way, proof of compliance should include documentation of self-assessment results, identified deficiencies during remediation plans, and any remaining undeveloped or incomplete controls. Eventually, this documentation should be assembled into a System Security Plan (SSP) or other form of compliance documentation.
Documenting compliance with NIST 800-171 and DFARS regulations is key to showing you are following security best practices, so ensure all documentation is accurate and up-to-date to demonstrate continuous improvement of security practices. Remember that NIST SP 800-171 may not be the only cybersecurity framework you must abide by; all companies handling CUI must meet additional compliance requirements such as the Cybersecurity Maturity Model Certification (CMMC).
Though NIST 800-171 covers an expansive scope, all government contractors and subcontractors should consider certain key aspects when complying with it. These key areas include:
Access Control: Establish who has access to what information and how this access is being managed.
Audit and Accountability: Are you monitoring who accesses your information and recording instances of unauthorized access?
Awareness and Training: Ensure all staff members understand how to handle CUI correctly.
Although the timeline will depend on the complexity of your information system and operating environment, planning must begin immediately if you expect to achieve compliance with NIST SP 800-171.
How can RiskRecon Help Me?
When you need to become NIST 800-171 compliant, RiskRecon by Mastercard is here to help. Our team will provide a full security assessment, implement automatic risk monitoring and prioritizing, and ensure you have the right tools to become and remain compliant. Start with our 30-day trial here.