3.5.3Require multi-factor authentication in Rev. 3
Reworded: 03.05.03 Multi-Factor Authentication.
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 3.5.3 Multifactor Authentication
Assessment objectives · 800-171A
- [a] privileged accounts are identified
- [b] multifactor authentication is implemented for local access to privileged accounts
- [c] multifactor authentication is implemented for network access to privileged accounts
- [d] multifactor authentication is implemented for network access to non-privileged accounts
Rev. 3 · not adopted 03.05.03 Multi-Factor Authentication
Implement multi-factor authentication for access to privileged and non-privileged accounts.
Determination statements · 800-171A Rev. 3
- 03.05.03[01] multi-factor authentication for access to privileged accounts is implemented.
- 03.05.03[02] multi-factor authentication for access to non-privileged accounts is implemented.
Draws on Rev. 2 3.5.3.
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 3.5.3 → Rev. 3 03.05.03 Multi-Factor Authentication
8 words kept, 10 removed, 2 added. Rev. 3 statement labels omitted for the comparison.
What NIST says changed
- New security requirement title
- Aligned with SP 800-53, Rev 5
- Change in applicability to all system accounts
NIST, SP 800-171 Rev. 2 to Rev. 3 change analysis, class “Minor change”. At adoption, Bedrock files this under “Review”.
NIST's Rev. 3 discussion for 03.05.03
This requirement applies to user accounts. Multi-factor authentication requires the use of two or more different factors to achieve authentication. The authentication factors are defined as follows: something you know (e.g., a personal identification number [PIN]), something you have (e.g., a physical authenticator, such as a cryptographic private key), or something you are (e.g., a biometric). Multi-factor authentication solutions that feature physical authenticators include hardware authenticators that provide time-based or challenge-response outputs and smart cards. In addition to authenticating users at the system level, organizations may also employ authentication mechanisms at the application level to provide increased information security.
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 3.5.3 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 03.05.03
- bedrock-cmmc-api@89b8e8e:docs/reference/nist-800-171-rev3/normalized/rev3.json#requirements[]