3.13.11Use FIPS-validated cryptography in Rev. 3
Reworded: 03.13.11 Cryptographic Protection. 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 3.13.11 CUI Encryption
Assessment objectives · 800-171A
- [a] FIPS-validated cryptography is employed to protect the confidentiality of CUI
Rev. 3 · not adopted 03.13.11 Cryptographic Protection
Implement the following types of cryptography to protect the confidentiality of CUI: [Assignment: organization-defined types of cryptography].
Determination statements · 800-171A Rev. 3
- 03.13.11 the following types of cryptography are implemented to protect the confidentiality of CUI: <A.03.13.11.ODP[01]: types of cryptography>.
Organization-defined parameters
- A.03.13.11.ODP[01] the types of cryptography for protecting the confidentiality of CUI are defined.
Draws on Rev. 2 3.13.11.
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 3.13.11 → Rev. 3 03.13.11 Cryptographic Protection
7 words kept, 4 removed, 10 added. Rev. 3 statement labels omitted for the comparison.
What NIST says changed
- New security requirement title
- Aligned with SP 800-53, Rev 5
- Added new ODP: types of cryptography used to protect confidentiality of CUI
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 03.13.11
Cryptography is implemented in accordance with applicable laws, Executive Orders, directives, regulations, policies, standards, and guidelines. FIPS-validated cryptography is recommended for the protection of CUI.
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 3.13.11 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 03.13.11
- bedrock-cmmc-api@89b8e8e:docs/reference/nist-800-171-rev3/normalized/rev3.json#requirements[]