3.6.3Test the plan in Rev. 3
Reworded: 03.06.03 Incident Response Testing. Gains organization-defined parameters.
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 3.6.3 Incident Response Testing
Assessment objectives · 800-171A
- [a] the incident response capability is tested
Rev. 3 · not adopted 03.06.03 Incident Response Testing
Test the effectiveness of the incident response capability [Assignment: organization-defined frequency].
Determination statements · 800-171A Rev. 3
- 03.06.03 the effectiveness of the incident response capability is tested <A.03.06.03.ODP[01]: frequency>.
Organization-defined parameters
- A.03.06.03.ODP[01] the frequency at which to test the effectiveness of the incident response capability for the system is defined.
Draws on Rev. 2 3.6.3.
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 3.6.3 → Rev. 3 03.06.03 Incident Response Testing
5 words kept, 1 removed, 6 added. Rev. 3 statement labels omitted for the comparison.
What NIST says changed
- New security requirement title
- Added new ODP: frequency to test effectiveness of incident response capability
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 03.06.03
Organizations test incident response capabilities to determine their effectiveness and identify potential weaknesses or deficiencies. Incident response testing includes the use of checklists, walk-through or tabletop exercises, and simulations. Incident response testing can include a determination of the effects of incident response on organizational operations, organizational assets, and individuals. Qualitative and quantitative data can help determine the effectiveness of incident response processes.
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 3.6.3 as written in Rev. 2, and if you already choose a value for the parameters above in practice, write it down where your system security plan can find it.
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 03.06.03
- bedrock-cmmc-api@89b8e8e:docs/reference/nist-800-171-rev3/normalized/rev3.json#requirements[]