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3.4.3Track changes in Rev. 3

Reworded: 03.04.03 Configuration Change Control.

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 3.4.3 System Change Management

Track, review, approve or disapprove, and log changes to organizational systems.

Assessment objectives · 800-171A

  1. [a] changes to the system are tracked
  2. [b] changes to the system are reviewed
  3. [c] changes to the system are approved or disapproved
  4. [d] changes to the system are logged

Rev. 3 · not adopted 03.04.03 Configuration Change Control

a. Define the types of changes to the system that are configuration-controlled.

b. Review proposed configuration-controlled changes to the system, and approve or disapprove such changes with explicit consideration for security impacts.

c. Implement and document approved configuration-controlled changes to the system.

d. Monitor and review activities associated with configuration-controlled changes to the system.

Determination statements · 800-171A Rev. 3

  1. 03.04.03.a the types of changes to the system that are configuration-controlled are defined.
  2. 03.04.03.b[01] proposed configuration-controlled changes to the system are reviewed with explicit consideration for security impacts.
  3. 03.04.03.b[02] proposed configuration-controlled changes to the system are approved or disapproved with explicit consideration for security impacts.
  4. 03.04.03.c[01] approved configuration-controlled changes to the system are implemented.
  5. 03.04.03.c[02] approved configuration-controlled changes to the system are documented.
  6. 03.04.03.d[01] activities associated with configuration-controlled changes to the system are monitored.
  7. 03.04.03.d[02] activities associated with configuration-controlled changes to the system are reviewed.

Draws on Rev. 2 3.4.3.

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 3.4.3 → Rev. 3 03.04.03 Configuration Change Control

Track, Define the types of changes to the system that are configuration-controlled. Review proposed configuration-controlled changes to the system, and approve or disapprove such changes with explicit consideration for security impacts. Implement and log document approved configuration-controlled changes to organizational systems. the system. Monitor and review activities associated with configuration-controlled changes to the system.

7 words kept, 4 removed, 43 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 implementing configuration change control
  • Updated discussion to show relationship to 03.04.04

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 03.04.03

Configuration change control refers to tracking, reviewing, approving or disapproving, and logging changes to the system. Specifically, it involves the systematic proposal, justification, implementation, testing, review, and disposition of changes to the system, including system upgrades and modifications. Configuration change control includes changes to baseline configurations for system components (e.g., operating systems, applications, firewalls, routers, mobile devices) and configuration items of the system, changes to configuration settings, unscheduled and unauthorized changes, and changes to remediate vulnerabilities. This requirement is related to <a href="#/cprt/framework/version/SP_800_171_3_0_0/home?element=03.04.04">03.04.04</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 3.4.3 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.

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 03.04.03
bedrock-cmmc-api@89b8e8e:docs/reference/nist-800-171-rev3/normalized/rev3.json#requirements[]