3.13.16Encrypt CUI at rest in Rev. 3
Withdrawn and incorporated elsewhere: 03.13.08 Transmission and Storage Confidentiality.
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 3.13.16 Data at Rest
Assessment objectives · 800-171A
- [a] the confidentiality of CUI at rest is protected
Rev. 3 · not adopted 03.13.08 Transmission and Storage Confidentiality
Implement cryptographic mechanisms to prevent the unauthorized disclosure of CUI during transmission and while in storage.
Determination statements · 800-171A Rev. 3
- 03.13.08[01] cryptographic mechanisms are implemented to prevent the unauthorized disclosure of CUI during transmission.
- 03.13.08[02] cryptographic mechanisms are implemented to prevent the unauthorized disclosure of CUI while in storage.
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 3.13.16 → Rev. 3 03.13.08 Transmission and Storage Confidentiality
3 words kept, 4 removed, 13 added. Rev. 3 statement labels omitted for the comparison.
What NIST says changed
Rev. 3 withdraws this requirement as a separate item and folds it into another requirement. NIST's note: Incorporated into 03.13.08.
NIST's Rev. 3 discussion for 03.13.08
This requirement applies to internal and external networks and any system components that can transmit CUI, including servers, notebook computers, desktop computers, mobile devices, printers, copiers, scanners, facsimile machines, and radios. Unprotected communication paths are susceptible to interception and modification. Encryption protects CUI from unauthorized disclosure during transmission and while in storage. Cryptographic mechanisms that protect the confidentiality of CUI during transmission include TLS and IPsec. Information in storage (i.e., information at rest) refers to the state of CUI when it is not in process or in transit and resides on internal or external storage devices, storage area network devices, and databases. Protecting CUI in storage does not focus on the type of storage device or the frequency of access to that device but rather on the state of the information. This requirement relates 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 3.13.16 as written in Rev. 2.
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 03.13.08
- bedrock-cmmc-api@89b8e8e:docs/reference/nist-800-171-rev3/normalized/rev3.json#requirements[]