3.1.6Do ordinary work from ordinary accounts in Rev. 3
Reworded: 03.01.06 Least Privilege – Privileged Accounts. Gains organization-defined parameters.
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 3.1.6 Non-Privileged Account Use
Assessment objectives · 800-171A
- [a] nonsecurity functions are identified
- [b] users are required to use non-privileged accounts or roles when accessing nonsecurity functions
Rev. 3 · not adopted 03.01.06 Least Privilege – Privileged Accounts
a. Restrict privileged accounts on the system to [Assignment: organization-defined personnel or roles]..
b. Require that users (or roles) with privileged accounts use non-privileged accounts when accessing non-security functions or non-security information.
Determination statements · 800-171A Rev. 3
- 03.01.06.a privileged accounts on the system are restricted to <A.03.01.06.ODP[01]: personnel or roles>.
- 03.01.06.b users (or roles) with privileged accounts are required to use non-privileged accounts when accessing non-security functions or non-security information.
Organization-defined parameters
- A.03.01.06.ODP[01] personnel or roles to which privileged accounts on the system are to be restricted are defined.
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 3.1.6 → Rev. 3 03.01.06 Least Privilege – Privileged Accounts
6 words kept, 3 removed, 24 added. Rev. 3 statement labels omitted for the comparison.
What NIST says changed
- New security requirement title
- Aligned with SP 800-53, Rev 5 to provide more comprehensive detail on and foundational tasks to implement least privilege for privileged accounts
- Added new ODP: personnel or roles to restrict privileged accounts to
- Updated discussion for improved flow with requirement and clarity
NIST, SP 800-171 Rev. 2 to Rev. 3 change analysis, class “Significant change”. At adoption, Bedrock files this under “Rework”.
NIST's Rev. 3 discussion for 03.01.06
Privileged accounts refer to accounts that are granted elevated privileges to access resources (including security functions or security-relevant information) that are otherwise restricted for non-privileged accounts. These accounts are typically described as system administrator or super user accounts. For example, a privileged account is often required in order to perform privileged functions such as executing commands that could modify system behavior. Restricting privileged accounts to specific personnel or roles ensures that only those authorized users can access and manipulate security functions or security-relevant information. Requiring the use of non-privileged accounts when such access is not needed can limit unauthorized access to and manipulation of security functions or security-relevant information.
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 3.1.6 as written in Rev. 2, and if you already choose a value for the parameters above in practice, write it down where your system security plan can find it.
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 03.01.06
- bedrock-cmmc-api@89b8e8e:docs/reference/nist-800-171-rev3/normalized/rev3.json#requirements[]