3.13.3Separate admin interfaces from user interfaces in Rev. 3
Withdrawn and incorporated elsewhere: 03.01.01 Account Management, 03.01.02 Access Enforcement, 03.01.03 Information Flow Enforcement, 03.01.04 Separation of Duties, 03.01.05 Least Privilege, 03.01.06 Least Privilege – Privileged Accounts, 03.01.07 Least Privilege – Privileged Functions.
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 3.13.3 Role Separation
Assessment objectives · 800-171A
- [a] user functionality is identified
- [b] system management functionality is identified
- [c] user functionality is separated from system management functionality
Rev. 3 · not adopted 03.01.01 Account Management
a. Define the types of system accounts allowed and prohibited.
b. Create, enable, modify, disable, and remove system accounts in accordance with policy, procedures, prerequisites, and criteria.
c. Specify:
01. Authorized users of the system,
02. Group and role membership, and
03. Access authorizations (i.e., privileges) for each account.
d. Authorize access to the system based on:
01. A valid access authorization and
02. Intended system usage.
e. Monitor the use of system accounts.
f. Disable system accounts when:
01. The accounts have expired,
02. The accounts have been inactive for [Assignment: organization-defined time period],
03. The accounts are no longer associated with a user or individual,
04. The accounts are in violation of organizational policy, or
05. Significant risks associated with individuals are discovered.
g. Notify account managers and designated personnel or roles within:
01. [Assignment: organization-defined time period] when accounts are no longer required.
02. [Assignment: organization-defined time period] when users are terminated or transferred.
03. [Assignment: organization-defined time period] when system usage or the need-to-know changes for an individual.
h. Require that users log out of the system after [Assignment: organization-defined time period] of expected inactivity or when [Assignment: organization-defined circumstances].
Determination statements · 800-171A Rev. 3
- 03.01.01.a[01] system account types allowed are defined.
- 03.01.01.a[02] system account types prohibited are defined.
- 03.01.01.b[01] system accounts are created in accordance with organizational policy, procedures, prerequisites, and criteria.
- 03.01.01.b[02] system accounts are enabled in accordance with organizational policy, procedures, prerequisites, and criteria.
- 03.01.01.b[03] system accounts are modified in accordance with organizational policy, procedures, prerequisites, and criteria.
- 03.01.01.b[04] system accounts are disabled in accordance with organizational policy, procedures, prerequisites, and criteria.
- 03.01.01.b[05] system accounts are removed in accordance with organizational policy, procedures, prerequisites, and criteria.
- 03.01.01.c.01 authorized users of the system are specified.
- 03.01.01.c.02 group and role memberships are specified.
- 03.01.01.c.03 access authorizations (i.e., privileges) for each account are specified.
- 03.01.01.d.01 access to the system is authorized based on a valid access authorization.
- 03.01.01.d.02 access to the system is authorized based on intended system usage.
- 03.01.01.e the use of system accounts is monitored.
- 03.01.01.f.01 system accounts are disabled when the accounts have expired.
- 03.01.01.f.02 system accounts are disabled when the accounts have been inactive for <A.03.01.01.ODP[01]: time period>.
- 03.01.01.f.03 system accounts are disabled when the accounts are no longer associated with a user or individual.
- 03.01.01.f.04 system accounts are disabled when the accounts violate organizational policy.
- 03.01.01.f.05 system accounts are disabled when significant risks associated with individuals are discovered.
- 03.01.01.g.01 account managers and designated personnel or roles are notified within <A.03.01.01.ODP[02]: time period> when accounts are no longer required.
- 03.01.01.g.02 account managers and designated personnel or roles are notified within <A.03.01.01.ODP[03]: time period> when users are terminated or transferred.
- 03.01.01.g.03 account managers and designated personnel or roles are notified within <A.03.01.01.ODP[04]: time period> when system usage or the need-to-know changes for an individual.
- 03.01.01.h users are required to log out of the system after <A.03.01.01.ODP[05]: time period> of expected inactivity or when the following circumstances occur: <A.03.01.01.ODP[06]: circumstances>.
Organization-defined parameters
- A.03.01.01.ODP[01] the time period for account inactivity before disabling is defined.
- A.03.01.01.ODP[02] the time period within which to notify account managers and designated personnel or roles when accounts are no longer required is defined.
- A.03.01.01.ODP[03] the time period within which to notify account managers and designated personnel or roles when users are terminated or transferred is defined.
- A.03.01.01.ODP[04] the time period within which to notify account managers and designated personnel or roles when system usage or the need-to-know changes for an individual is defined.
- A.03.01.01.ODP[05] the time period of expected inactivity requiring users to log out of the system is defined.
- A.03.01.01.ODP[06] circumstances requiring users to log out of the system are defined.
Rev. 3 · not adopted 03.01.02 Access Enforcement
Enforce approved authorizations for logical access to CUI and system resources in accordance with applicable access control policies.
Determination statements · 800-171A Rev. 3
- 03.01.02[01] approved authorizations for logical access to CUI are enforced in accordance with applicable access control policies.
- 03.01.02[02] approved authorizations for logical access to system resources are enforced in accordance with applicable access control policies.
Rev. 3 · not adopted 03.01.03 Information Flow Enforcement
Enforce approved authorizations for controlling the flow of CUI within the system and between connected systems.
Determination statements · 800-171A Rev. 3
- 03.01.03[01] approved authorizations are enforced for controlling the flow of CUI within the system.
- 03.01.03[02] approved authorizations are enforced for controlling the flow of CUI between connected systems.
Rev. 3 · not adopted 03.01.04 Separation of Duties
a. Identify the duties of individuals requiring separation.
b. Define system access authorizations to support separation of duties.
Determination statements · 800-171A Rev. 3
- 03.01.04.a duties of individuals requiring separation are identified.
- 03.01.04.b system access authorizations to support separation of duties are defined.
Rev. 3 · not adopted 03.01.05 Least Privilege
a. Allow only authorized system access for users (or processes acting on behalf of users) that is necessary to accomplish assigned organizational tasks.
b. Authorize access to [Assignment: organization-defined security functions] and [Assignment: organization-defined security-relevant information].
c. Review the privileges assigned to roles or classes of users [Assignment: organization-defined frequency] to validate the need for such privileges.
d. Reassign or remove privileges, as necessary.
Determination statements · 800-171A Rev. 3
- 03.01.05.a system access for users (or processes acting on behalf of users) is authorized only when necessary to accomplish assigned organizational tasks.
- 03.01.05.b[01] access to <A.03.01.05.ODP[01]: security functions> is authorized.
- 03.01.05.b[02] access to <A.03.01.05.ODP[02]: security-relevant information> is authorized.
- 03.01.05.c the privileges assigned to roles or classes of users are reviewed <A.03.01.05.ODP[03]: frequency> to validate the need for such privileges.
- 03.01.05.d privileges are reassigned or removed, as necessary.
Organization-defined parameters
- A.03.01.05.ODP[01] security functions for authorized access are defined.
- A.03.01.05.ODP[02] security-relevant information for authorized access is defined.
- A.03.01.05.ODP[03] the frequency at which to review the privileges assigned to roles or classes of users is defined.
Rev. 3 · not adopted 03.01.06 Least Privilege – Privileged Accounts
a. Restrict privileged accounts on the system to [Assignment: organization-defined personnel or roles]..
b. Require that users (or roles) with privileged accounts use non-privileged accounts when accessing non-security functions or non-security information.
Determination statements · 800-171A Rev. 3
- 03.01.06.a privileged accounts on the system are restricted to <A.03.01.06.ODP[01]: personnel or roles>.
- 03.01.06.b users (or roles) with privileged accounts are required to use non-privileged accounts when accessing non-security functions or non-security information.
Organization-defined parameters
- A.03.01.06.ODP[01] personnel or roles to which privileged accounts on the system are to be restricted are defined.
Rev. 3 · not adopted 03.01.07 Least Privilege – Privileged Functions
a. Prevent non-privileged users from executing privileged functions.
b. Log the execution of privileged functions.
Determination statements · 800-171A Rev. 3
- 03.01.07.a non-privileged users are prevented from executing privileged functions.
- 03.01.07.b the execution of privileged functions is logged.
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 each Rev. 3 requirement it feeds into. A mechanical comparison of the two verbatim texts, not an interpretation.
removed in Rev. 3 added in Rev. 3
Rev. 2 3.13.3 → Rev. 3 03.01.01 Account Management
2 words kept, 5 removed, 171 added. Rev. 3 statement labels omitted for the comparison.
Rev. 2 3.13.3 → Rev. 3 03.01.02 Access Enforcement
1 words kept, 6 removed, 17 added. Rev. 3 statement labels omitted for the comparison.
Rev. 2 3.13.3 → Rev. 3 03.01.03 Information Flow Enforcement
1 words kept, 6 removed, 15 added. Rev. 3 statement labels omitted for the comparison.
Rev. 2 3.13.3 → Rev. 3 03.01.04 Separation of Duties
1 words kept, 6 removed, 15 added. Rev. 3 statement labels omitted for the comparison.
Rev. 2 3.13.3 → Rev. 3 03.01.05 Least Privilege
1 words kept, 6 removed, 59 added. Rev. 3 statement labels omitted for the comparison.
Rev. 2 3.13.3 → Rev. 3 03.01.06 Least Privilege – Privileged Accounts
1 words kept, 6 removed, 29 added. Rev. 3 statement labels omitted for the comparison.
Rev. 2 3.13.3 → Rev. 3 03.01.07 Least Privilege – Privileged Functions
1 words kept, 6 removed, 12 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 other requirements. NIST's note: Addressed by 03.01.01, 03.01.02, 03.01.03, 03.01.04, 03.01.05, 03.01.06, and 03.01.07.
NIST's Rev. 3 discussion for 03.01.01
This requirement focuses on account management for systems and applications. The definition and enforcement of access authorizations other than those determined by account type (e.g., privileged access, non-privileged access) are addressed in <a href="#/cprt/framework/version/SP_800_171_3_0_0/home?element=03.01.02">03.01.02</a>. System account types include individual, group, temporary, system, guest, anonymous, emergency, developer, and service. Users who require administrative privileges on system accounts receive additional scrutiny by personnel responsible for approving such accounts and privileged access. Types of accounts that organizations may prohibit due to increased risk include group, emergency, guest, anonymous, and temporary. Organizations may choose to define access privileges or other attributes by account, type of account, or a combination of both. Other attributes required for authorizing access include restrictions on the time of day, day of the week, and point of origin. When defining other system account attributes, organizations consider system requirements (e.g., system upgrades, scheduled maintenance) and mission and business requirements (e.g., time zone differences, remote access to facilitate travel requirements). Users who pose a significant security risk include individuals for whom reliable evidence indicates either the intention to use authorized access to the system to cause harm or that adversaries will cause harm through them. Close coordination among mission and business owners, system administrators, human resource managers, and legal staff is essential when disabling system accounts for high-risk individuals. Time periods for the notification of organizational personnel or roles may vary. Inactivity logout is behavior- or policy-based and requires users to take physical action to log out when they are expecting inactivity longer than the defined period. Automatic enforcement of inactivity logout is addressed by <a href="#/cprt/framework/version/SP_800_171_3_0_0/home?element=03.01.10">03.01.10</a>.
NIST's Rev. 3 discussion for 03.01.02
Access control policies control access between active entities or subjects (i.e., users or system processes acting on behalf of users) and passive entities or objects (i.e., devices, files, records, domains) in organizational systems. Types of system access include remote access and access to systems that communicate through external networks, such as the internet. Access enforcement mechanisms can also be employed at the application and service levels to provide increased protection for CUI. This recognizes that the system can host many applications and services in support of mission and business functions. Access control policies are defined in <a href="#/cprt/framework/version/SP_800_171_3_0_0/home?element=03.15.01">03.15.01</a>.
NIST's Rev. 3 discussion for 03.01.03
Information flow control regulates where CUI can transit within a system and between systems (in contrast to who is allowed to access the information) and without regard to subsequent accesses to that information. Flow control restrictions include keeping CUI from being transmitted in the clear to the internet, blocking external communications traffic that claims to be sourced from within the organization, restricting requests to the internet that are not from the internal web proxy server, and limiting CUI transfers between organizations based on data structures and content. Transferring CUI between organizations may require an agreement that specifies how the information flow is enforced (see <a href="#/cprt/framework/version/SP_800_171_3_0_0/home?element=03.12.05">03.12.05</a>). Transferring CUI between systems that represent different security domains with different security policies introduces the risk that such transfers violate one or more domain security policies. In such situations, information owners or stewards provide guidance at designated policy enforcement points between interconnected systems. Organizations consider mandating specific architectural solutions when required to enforce specific security policies. Enforcement includes prohibiting CUI transfers between interconnected systems (i.e., allowing information access only), employing hardware mechanisms to enforce one-way information flows, and implementing trustworthy regrading mechanisms to reassign security attributes and security labels. Organizations commonly use information flow control policies and enforcement mechanisms to control the flow of CUI between designated sources and destinations (e.g., networks, individuals, and devices) within systems and between interconnected systems. Flow control is based on characteristics of the information or the information path. Enforcement occurs in boundary protection devices (e.g., encrypted tunnels, routers, gateways, and firewalls) that use rule sets or establish configuration settings that restrict system services, provide a packet-filtering capability based on header information, or provide a message-filtering capability based on message content (e.g., implementing key word searches or using document characteristics). Organizations also consider the trustworthiness of filtering and inspection mechanisms (i.e., hardware, firmware, and software components) that are critical to information flow enforcement.
NIST's Rev. 3 discussion for 03.01.04
Separation of duties addresses the potential for abuse of authorized privileges and reduces the risk of malevolent activity without collusion. Separation of duties includes dividing mission functions and support functions among different individuals or roles, conducting system support functions with different individuals or roles (e.g., quality assurance, configuration management, network security, system management, assessments, and programming), and ensuring that personnel who administer access control functions do not also administer audit functions. Because separation of duty violations can span systems and application domains, organizations consider the entirety of their systems and system components when developing policies on separation of duties. This requirement is enforced by <a href="#/cprt/framework/version/SP_800_171_3_0_0/home?element=03.01.02">03.01.02</a>.
NIST's Rev. 3 discussion for 03.01.05
Organizations employ the principle of least privilege for specific duties and authorized access for users and system processes. Least privilege is applied to the development, implementation, and operation of the system. Organizations consider creating additional processes, roles, and system accounts to achieve least privilege. Security functions include establishing system accounts and assigning privileges, installing software, configuring access authorizations, configuring settings for events to be audited, establishing vulnerability scanning parameters, establishing intrusion detection parameters, and managing audit information. Security-relevant information includes threat and vulnerability information, filtering rules for routers or firewalls, configuration parameters for security services, security architecture, cryptographic key management information, access control lists, and audit information.
NIST's Rev. 3 discussion for 03.01.06
Privileged accounts refer to accounts that are granted elevated privileges to access resources (including security functions or security-relevant information) that are otherwise restricted for non-privileged accounts. These accounts are typically described as system administrator or super user accounts. For example, a privileged account is often required in order to perform privileged functions such as executing commands that could modify system behavior. Restricting privileged accounts to specific personnel or roles ensures that only those authorized users can access and manipulate security functions or security-relevant information. Requiring the use of non-privileged accounts when such access is not needed can limit unauthorized access to and manipulation of security functions or security-relevant information.
NIST's Rev. 3 discussion for 03.01.07
Privileged functions include establishing system accounts, performing system integrity checks, conducting patching operations, changing system configuration settings, or administering cryptographic key management activities. Non-privileged users do not possess the authorizations to execute privileged functions. Bypassing intrusion detection and prevention mechanisms or malicious code protection mechanisms are examples of privileged functions that require protection from non-privileged users. This requirement represents a condition achieved by the definition of authorized privileges in <a href="#/cprt/framework/version/SP_800_171_3_0_0/home?element=03.01.01">03.01.01</a> and privilege enforcement in <a href="#/cprt/framework/version/SP_800_171_3_0_0/home?element=03.01.02">03.01.02</a>. The misuse of privileged functions — whether intentionally or unintentionally by authorized users or by unauthorized external entities that have compromised system accounts — is a serious and ongoing concern that can have significant adverse impacts on organizations. Logging the use of privileged functions is one way to detect such misuse and mitigate risks from advanced persistent threats and insider threats.
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 3.13.3 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 03.01.01
- bedrock-cmmc-api@89b8e8e:docs/reference/nist-800-171-rev3/normalized/rev3.json#requirements[]
- Rev. 3 03.01.02
- bedrock-cmmc-api@89b8e8e:docs/reference/nist-800-171-rev3/normalized/rev3.json#requirements[]
- Rev. 3 03.01.03
- bedrock-cmmc-api@89b8e8e:docs/reference/nist-800-171-rev3/normalized/rev3.json#requirements[]
- Rev. 3 03.01.04
- bedrock-cmmc-api@89b8e8e:docs/reference/nist-800-171-rev3/normalized/rev3.json#requirements[]
- Rev. 3 03.01.05
- bedrock-cmmc-api@89b8e8e:docs/reference/nist-800-171-rev3/normalized/rev3.json#requirements[]
- Rev. 3 03.01.06
- bedrock-cmmc-api@89b8e8e:docs/reference/nist-800-171-rev3/normalized/rev3.json#requirements[]
- Rev. 3 03.01.07
- bedrock-cmmc-api@89b8e8e:docs/reference/nist-800-171-rev3/normalized/rev3.json#requirements[]