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3.10.1Limit physical access in Rev. 3

Reworded: 03.10.01 Physical Access Authorizations. 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 3.10.1 Limit Physical Access

Limit physical access to organizational systems, equipment, and the respective operating environments to authorized individuals.

Assessment objectives · 800-171A

  1. [a] authorized individuals allowed physical access are identified
  2. [b] physical access to organizational systems is limited to authorized individuals
  3. [c] physical access to equipment is limited to authorized individuals
  4. [d] physical access to operating environments is limited to authorized individuals

Rev. 3 · not adopted 03.10.01 Physical Access Authorizations

a. Develop, approve, and maintain a list of individuals with authorized access to the facility where the system resides.

b. Issue authorization credentials for facility access.

c. Review the facility access list [Assignment: organization-defined frequency].

d. Remove individuals from the facility access list when access is no longer required.

Determination statements · 800-171A Rev. 3

  1. 03.10.01.a[01] a list of individuals with authorized access to the facility where the system resides is developed.
  2. 03.10.01.a[02] a list of individuals with authorized access to the facility where the system resides is approved.
  3. 03.10.01.a[03] a list of individuals with authorized access to the facility where the system resides is maintained.
  4. 03.10.01.b authorization credentials for facility access are issued.
  5. 03.10.01.c the facility access list is reviewed <A.03.10.01.ODP[01]: frequency>.
  6. 03.10.01.d individuals from the facility access list are removed when access is no longer required.

Organization-defined parameters

  • A.03.10.01.ODP[01] the frequency at which to review the access list detailing authorized facility access by individuals is defined.

Draws on Rev. 2 3.10.1.

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 3.10.1 → Rev. 3 03.10.01 Physical Access Authorizations

Limit physical Develop, approve, and maintain a list of individuals with authorized access to organizational systems, equipment, and the respective operating environments to authorized facility where the system resides. Issue authorization credentials for facility access. Review the facility access list [Assignment: organization-defined frequency]. Remove individuals from the facility access list when access is no longer required.

4 words kept, 11 removed, 41 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 for implementing physical access authorizations
  • Added new ODP: frequency to review facility access list

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 03.10.01

A facility can include one or more physical locations containing systems or system components that process, store, or transmit CUI. Physical access authorizations apply to employees and visitors. Individuals with permanent physical access authorization credentials are not considered visitors. Authorization credentials include identification badges, identification cards, and smart cards. Organizations determine the strength of the authorization credentials consistent with applicable laws, Executive Orders, directives, regulations, policies, standards, and guidelines. Physical access authorizations may not be necessary to access certain areas within facilities that are designated as publicly accessible.

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 3.10.1 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.

Back to the Rev. 2 vs Rev. 3 overview

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 03.10.01
bedrock-cmmc-api@89b8e8e:docs/reference/nist-800-171-rev3/normalized/rev3.json#requirements[]