3.1.2Limit what each person can do once inside in Rev. 3
No significant change: 03.01.02 Access Enforcement.
Status as of 2026-09-08
Rev. 2 is what a contract requires today. DFARS 252.204-7012 and the CMMC rule at 32 CFR 170 point at NIST SP 800-171 Rev. 2, and a standing DoD class deviation keeps it there. NIST has published Rev. 3, but publishing a revision does not change an obligation. A move to Rev. 3 would arrive through the Department's reform process and formal rulemaking, a change to that deviation or an amendment to the rule, not through publication. The Department has published its organization-defined parameter values for Rev. 3 in preparation; that is groundwork, not adoption.
Side by side
Rev. 2 · in force 3.1.2 Transaction & Function Control
Assessment objectives · 800-171A
- [a] the types of transactions and functions that authorized users are permitted to execute are defined
- [b] system access is limited to the defined types of transactions and functions for authorized users
Rev. 3 · not adopted 03.01.02 Access Enforcement
Enforce approved authorizations for logical access to CUI and system resources in accordance with applicable access control policies.
Determination statements · 800-171A Rev. 3
- 03.01.02[01] approved authorizations for logical access to CUI are enforced in accordance with applicable access control policies.
- 03.01.02[02] approved authorizations for logical access to system resources are enforced in accordance with applicable access control policies.
Left: NIST SP 800-171 Rev. 2 and 800-171A, verbatim. Right: NIST SP 800-171 Rev. 3 and 800-171A Rev. 3, verbatim, with organization-defined blanks highlighted.
Word by word
The Rev. 2 requirement compared with its Rev. 3 successor. A mechanical comparison of the two verbatim texts, not an interpretation.
removed in Rev. 3 added in Rev. 3
Rev. 2 3.1.2 → Rev. 3 03.01.02 Access Enforcement
3 words kept, 14 removed, 15 added. Rev. 3 statement labels omitted for the comparison.
What NIST says changed
- New security requirement title
- Aligned with SP 800-53, Rev 5
- Rephrased for clarity; outcome remains unchanged
NIST, SP 800-171 Rev. 2 to Rev. 3 change analysis, class “No significant change”. At adoption, Bedrock files this under “Carries as-is”.
NIST's Rev. 3 discussion for 03.01.02
Access control policies control access between active entities or subjects (i.e., users or system processes acting on behalf of users) and passive entities or objects (i.e., devices, files, records, domains) in organizational systems. Types of system access include remote access and access to systems that communicate through external networks, such as the internet. Access enforcement mechanisms can also be employed at the application and service levels to provide increased protection for CUI. This recognizes that the system can host many applications and services in support of mission and business functions. Access control policies are defined in <a href="#/cprt/framework/version/SP_800_171_3_0_0/home?element=03.15.01">03.15.01</a>.
What this means for you now
Nothing changes in what you are assessed against until a class deviation or a published rule adopts Rev. 3. Keep meeting 3.1.2 as written in Rev. 2.
Bedrock CMMC shows this same comparison against your own package, with your current status on the Rev. 2 side, so the day adoption lands the migration is a review, not a rewrite.
Where this page's facts come from
- Rev. 2 text and objectives
- bedrock-cmmc-api@89b8e8e:migrations/004_reference_requirements.sql#Requirement.basicRequirement@rev2; bedrock-cmmc-api@89b8e8e:migrations/005_reference_objectives.sql#AssessmentObjective.description@rev2
- Mapping and change class
- bedrock-cmmc-api@89b8e8e:docs/reference/nist-800-171-rev3/normalized/r2_r3_transition_map.json#r2_to_r3
- Rev. 3 03.01.02
- bedrock-cmmc-api@89b8e8e:docs/reference/nist-800-171-rev3/normalized/rev3.json#requirements[]