3.4.5Restrict who can change what in Rev. 3

No significant change: 03.04.05 Access Restrictions for Change.

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 3.4.5 Access Restrictions for Change

Define, document, approve, and enforce physical and logical access restrictions associated with changes to organizational systems.

Assessment objectives · 800-171A

[a] physical access restrictions associated with changes to the system are defined
[b] physical access restrictions associated with changes to the system are documented
[c] physical access restrictions associated with changes to the system are approved
[d] physical access restrictions associated with changes to the system are enforced
[e] logical access restrictions associated with changes to the system are defined
[f] logical access restrictions associated with changes to the system are documented
[g] logical access restrictions associated with changes to the system are approved
[h] logical access restrictions associated with changes to the system are enforced

Rev. 3 · not adopted 03.04.05 Access Restrictions for Change

Define, document, approve, and enforce physical and logical access restrictions associated with changes to the system.

Determination statements · 800-171A Rev. 3

03.04.05[01] physical access restrictions associated with changes to the system are defined and documented.
03.04.05[02] physical access restrictions associated with changes to the system are approved.
03.04.05[03] physical access restrictions associated with changes to the system are enforced.
03.04.05[04] logical access restrictions associated with changes to the system are defined and documented.
03.04.05[05] logical access restrictions associated with changes to the system are approved.
03.04.05[06] logical access restrictions associated with changes to the system are enforced.

Draws on Rev. 2 3.4.5.

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 3.4.5 → Rev. 3 03.04.05 Access Restrictions for Change

Define, document, approve, and enforce physical and logical access restrictions associated with changes to ~~organizational systems.~~ the system.

14 words kept, 2 removed, 2 added. Rev. 3 statement labels omitted for the comparison.

What NIST says changed

New security requirement title

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 03.04.05

Changes to the hardware, software, or firmware components of the system or the operational procedures related to the system can have potentially significant effects on the security of the system. Therefore, organizations permit only qualified and authorized individuals to access the system for the purpose of initiating changes. Access restrictions include physical and logical access controls, software libraries, workflow automation, media libraries, abstract layers (i.e., changes implemented into external interfaces rather than directly into the system), and change windows (i.e., changes occur only during specified times).

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 3.4.5 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 03.04.05: bedrock-cmmc-api@89b8e8e:docs/reference/nist-800-171-rev3/normalized/rev3.json#requirements[]