3.8.9Protect your backups in Rev. 3
Reworded: 03.08.09 System Backup – Cryptographic Protection.
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 3.8.9 Protect Backups
Assessment objectives · 800-171A
- [a] the confidentiality of backup CUI is protected at storage locations
Rev. 3 · not adopted 03.08.09 System Backup – Cryptographic Protection
a. Protect the confidentiality of backup information.
b. Implement cryptographic mechanisms to prevent the unauthorized disclosure of CUI at backup storage locations.
Determination statements · 800-171A Rev. 3
- 03.08.09.a the confidentiality of backup information is protected.
- 03.08.09.b cryptographic mechanisms are implemented to prevent the unauthorized disclosure of CUI at backup storage locations.
Draws on Rev. 2 3.8.9.
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 3.8.9 → Rev. 3 03.08.09 System Backup – Cryptographic Protection
9 words kept, 0 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
- Added new foundational part of requirement to protect confidentiality of backup information (part a)
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 03.08.09
The selection of cryptographic mechanisms is based on the need to protect the confidentiality of backup information. Hardware security module (HSM) devices safeguard and manage cryptographic keys and provide cryptographic processing. Cryptographic operations (e.g., encryption, decryption, and signature generation and verification) are typically hosted on the HSM device, and many implementations provide hardware-accelerated mechanisms for cryptographic operations. This requirement is related to <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 3.8.9 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 03.08.09
- bedrock-cmmc-api@89b8e8e:docs/reference/nist-800-171-rev3/normalized/rev3.json#requirements[]