3.8.5Control media in transit in Rev. 3

Reworded: 03.08.05 Media Transport.

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 3.8.5 Media Accountability

Control access to media containing CUI and maintain accountability for media during transport outside of controlled areas.

Assessment objectives · 800-171A

[a] media containing CUI is controlled during transport outside of controlled areas
[b] accountability for media containing CUI is maintained during transport outside of controlled areas

Rev. 3 · not adopted 03.08.05 Media Transport

a. Protect and control system media that contain CUI during transport outside of controlled areas.

b. Maintain accountability of system media that contain CUI during transport outside of controlled areas.

c. Document activities associated with the transport of system media that contain CUI.

Determination statements · 800-171A Rev. 3

03.08.05.a[01] system media that contain CUI are protected during transport outside of controlled areas.
03.08.05.a[02] system media that contain CUI are controlled during transport outside of controlled areas.
03.08.05.b accountability for system media that contain CUI is maintained during transport outside of controlled areas.
03.08.05.c activities associated with the transport of system media that contain CUI are documented.

Draws on Rev. 2 3.8.5.

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 3.8.5 → Rev. 3 03.08.05 Media Transport

Protect and control ~~access to~~ system media ~~containing~~ that contain CUI ~~and~~ during transport outside of controlled areas. Maintain accountability ~~for~~ of system media that contain CUI during transport outside of controlled areas. Document activities associated with the transport of system media that contain CUI.

12 words kept, 5 removed, 28 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 transport; adds new requirement item to document activities associated with the transport of system media that contains CUI

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 03.08.05

System media include digital and non-digital media. Digital media include flash drives, diskettes, magnetic tapes, external or removable solid state or magnetic drives, compact discs, and digital versatile discs. Non-digital media include microfilm and paper. Controlled areas are spaces for which organizations provide physical or procedural measures to meet the requirements established for protecting CUI and systems. Media protection during transport can include cryptography and/or locked containers. Activities associated with media transport include releasing media for transport, ensuring that media enter the appropriate transport processes, and the actual transport. Authorized transport and courier personnel may include individuals external to the organization. Maintaining accountability of media during transport includes restricting transport activities to authorized personnel and tracking or obtaining the records of transport activities as the media move through the transportation system to prevent and detect loss, destruction, or tampering. This requirement is related to <a href="#/cprt/framework/version/SP_800_171_3_0_0/home?element=03.13.08">03.13.08</a> and <a href="#/cprt/framework/version/SP_800_171_3_0_0/home?element=03.13.11">03.13.11</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 3.8.5 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 03.08.05: bedrock-cmmc-api@89b8e8e:docs/reference/nist-800-171-rev3/normalized/rev3.json#requirements[]