3.13.10Manage your encryption keys in Rev. 3
Reworded: 03.13.10 Cryptographic Key Establishment and Management. 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 3.13.10 Key Management
Assessment objectives · 800-171A
- [a] cryptographic keys are established when cryptography is employed
- [b] cryptographic keys are managed when cryptography is employed
Rev. 3 · not adopted 03.13.10 Cryptographic Key Establishment and Management
Establish and manage cryptographic keys in the system in accordance with the following key management requirements: [Assignment: organization-defined requirements for key generation, distribution, storage, access, and destruction].
Determination statements · 800-171A Rev. 3
- 03.13.10[01] cryptographic keys are established in the system in accordance with the following key management requirements: <A.03.13.10.ODP[01]: requirements>.
- 03.13.10[02] cryptographic keys are managed in the system in accordance with the following key management requirements: <A.03.13.10.ODP[01]: requirements>.
Organization-defined parameters
- A.03.13.10.ODP[01] requirements for key generation, distribution, storage, access, and destruction are defined.
Draws on Rev. 2 3.13.10.
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 3.13.10 → Rev. 3 03.13.10 Cryptographic Key Establishment and Management
6 words kept, 5 removed, 21 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 cryptographic key establishment and management
- Added new ODP: requirements for key generation, distribution, storage, access and destruction
NIST, SP 800-171 Rev. 2 to Rev. 3 change analysis, class “Minor change”. At adoption, Bedrock files this under “Review”.
NIST's Rev. 3 discussion for 03.13.10
Cryptographic keys can be established and managed using either manual procedures or automated mechanisms supported by manual procedures. Organizations satisfy key establishment and management requirements in accordance with applicable federal laws, Executive Orders, policies, directives, regulations, and standards that specify appropriate options, levels, and parameters. This requirement is related to <a href="#/cprt/framework/version/SP_800_171_3_0_0/home?element=03.13.11">03.13.11</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 3.13.10 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 03.13.10
- bedrock-cmmc-api@89b8e8e:docs/reference/nist-800-171-rev3/normalized/rev3.json#requirements[]