3.11.1Assess your risk periodically in Rev. 3
Reworded: 03.11.01 Risk Assessment. 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 3.11.1 Risk Assessments
Assessment objectives · 800-171A
- [a] risk to organizational operations and assets, and individuals is assessed periodically
- [b] risk assessments consider the operation and use of organizational systems
- [c] risk assessments consider the processing, storage, or transmission of CUI
Rev. 3 · not adopted 03.11.01 Risk Assessment
a. Assess the risk (including supply chain risk) of unauthorized disclosure resulting from the processing, storage, or transmission of CUI.
b. Update risk assessments [Assignment: organization-defined frequency].
Determination statements · 800-171A Rev. 3
- 03.11.01.a the risk (including supply chain risk) of unauthorized disclosure resulting from the processing, storage, or transmission of CUI is assessed.
- 03.11.01.b risk assessments are updated <A.03.11.01.ODP[01]: frequency>.
Organization-defined parameters
- A.03.11.01.ODP[01] the frequency at which to update the risk assessment is defined.
Draws on Rev. 2 3.11.1.
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 3.11.1 → Rev. 3 03.11.01 Risk Assessment
13 words kept, 20 removed, 12 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 risk assessment; explicitly identifies supply chain risk as part of the risk assessment
- Added new ODP: frequency to update risk assessments
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 03.11.01
Establishing the system boundary is a prerequisite to assessing the risk of the unauthorized disclosure of CUI. Risk assessments consider threats, vulnerabilities, likelihood, and adverse impacts to organizational operations and assets based on the operation and use of the system and the unauthorized disclosure of CUI. Risk assessments also consider risks from external parties (e.g., contractors operating systems on behalf of the organization, service providers, individuals accessing systems, and outsourcing entities). Risk assessments can be conducted at the organization level, the mission or business process level, or the system level and at any phase in the system development life cycle. Risk assessments include supply chain-related risks associated with suppliers or contractors and the system, system component, or system service that they provide.
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 3.11.1 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.
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 03.11.01
- bedrock-cmmc-api@89b8e8e:docs/reference/nist-800-171-rev3/normalized/rev3.json#requirements[]