3.13.8Encrypt CUI in transit in Rev. 3

No significant change: 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 3.13.8 Data in Transit

Implement cryptographic mechanisms to prevent unauthorized disclosure of CUI during transmission unless otherwise protected by alternative physical safeguards.

Assessment objectives · 800-171A

[a] cryptographic mechanisms intended to prevent unauthorized disclosure of CUI are identified
[b] alternative physical safeguards intended to prevent unauthorized disclosure of CUI are identified
[c] either cryptographic mechanisms or alternative physical safeguards are implemented to prevent unauthorized disclosure of CUI during transmission

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.

Draws on Rev. 2 3.1.13, 3.8.6, 3.13.8, 3.13.16.

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 3.13.8 → Rev. 3 03.13.08 Transmission and Storage Confidentiality

Implement cryptographic mechanisms to prevent the unauthorized disclosure of CUI during transmission ~~unless otherwise protected by alternative physical safeguards.~~ and while in storage.

11 words kept, 7 removed, 5 added. Rev. 3 statement labels omitted for the comparison.

What NIST says changed

New security requirement title
Incorporate withdrawn requirement: 3.13.16

NIST, SP 800-171 Rev. 2 to Rev. 3 change analysis, class “No significant change”. At adoption, Bedrock files this under “Carries as-is”.

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 3.13.8 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.

Back to the Rev. 2 vs Rev. 3 overview

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[]