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3.8.4Mark media in Rev. 3

No significant change: 03.08.04 Media Marking.

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 3.8.4 Media Markings

Mark media with necessary CUI markings and distribution limitations.

Assessment objectives · 800-171A

  1. [a] media containing CUI is marked with applicable CUI markings
  2. [b] media containing CUI is marked with distribution limitations

Rev. 3 · not adopted 03.08.04 Media Marking

Mark system media that contain CUI to indicate distribution limitations, handling caveats, and applicable CUI markings.

Determination statements · 800-171A Rev. 3

  1. 03.08.04[01] system media that contain CUI are marked to indicate distribution limitations.
  2. 03.08.04[02] system media that contain CUI are marked to indicate handling caveats.
  3. 03.08.04[03] system media that contain CUI are marked to indicate applicable CUI markings.

Draws on Rev. 2 3.8.4.

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 3.8.4 → Rev. 3 03.08.04 Media Marking

Mark system media with necessary that contain CUI markings and to indicate distribution limitations, handling caveats, and applicable CUI markings.

5 words kept, 4 removed, 11 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 media marking

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 03.08.04

System media include digital and non-digital media. Marking refers to the use or application of human-readable security attributes. Labeling refers to the use of security attributes for internal system data structures. Digital media include diskettes, magnetic tapes, external or removable solid state or magnetic drives, flash drives, compact discs, and digital versatile discs. Non-digital media include paper and microfilm. CUI is defined by NARA along with marking, safeguarding, and dissemination requirements for such information.

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 3.8.4 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 03.08.04
bedrock-cmmc-api@89b8e8e:docs/reference/nist-800-171-rev3/normalized/rev3.json#requirements[]