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3.9.2Close accounts when people move or leave in Rev. 3

Reworded: 03.09.02 Personnel Termination and Transfer. 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 3.9.2 Personnel Actions

Ensure that organizational systems containing CUI are protected during and after personnel actions such as terminations and transfers.

Assessment objectives · 800-171A

  1. [a] a policy and/or process for terminating system access and any credentials coincident with personnel actions is established
  2. [b] system access and credentials are terminated consistent with personnel actions such as termination and transfer
  3. [c] the system is protected during and after personnel transfer actions

Rev. 3 · not adopted 03.09.02 Personnel Termination and Transfer

a. When individual employment is terminated:

01. Disable system access within [Assignment: organization-defined time period],

02. Terminate or revoke authenticators and credentials associated with the individual, and

03. Retrieve security-related system property.

b. When individuals are reassigned or transferred to other positions in the organization:

01. Review and confirm the ongoing operational need for current logical and physical access authorizations to the system and facility, and

02. Modify access authorization to correspond with any changes in operational need.

Determination statements · 800-171A Rev. 3

  1. 03.09.02.a.01 upon termination of individual employment, system access is disabled within <A.03.09.02.ODP[01]: time period>.
  2. 03.09.02.a.02[01] upon termination of individual employment, authenticators associated with the individual are terminated or revoked.
  3. 03.09.02.a.02[02] upon termination of individual employment, credentials associated with the individual are terminated or revoked.
  4. 03.09.02.a.03 upon termination of individual employment, security-related system property is retrieved.
  5. 03.09.02.b.01[01] upon individual reassignment or transfer to other positions in the organization, the ongoing operational need for current logical and physical access authorizations to the system and facility is reviewed.
  6. 03.09.02.b.01[02] upon individual reassignment or transfer to other positions in the organization, the ongoing operational need for current logical and physical access authorizations to the system and facility is confirmed.
  7. 03.09.02.b.02 upon individual reassignment or transfer to other positions in the organization, access authorization is modified to correspond with any changes in operational need.

Organization-defined parameters

  • A.03.09.02.ODP[01] the time period within which to disable system access is defined.

Draws on Rev. 2 3.9.2.

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 3.9.2 → Rev. 3 03.09.02 Personnel Termination and Transfer

Ensure that organizational systems containing CUI When individual employment is terminated: Disable system access within [Assignment: organization-defined time period], Terminate or revoke authenticators and credentials associated with the individual, and Retrieve security-related system property. When individuals are protected during reassigned or transferred to other positions in the organization: Review and after personnel actions such as terminations confirm the ongoing operational need for current logical and transfers. physical access authorizations to the system and facility, and Modify access authorization to correspond with any changes in operational need.

3 words kept, 15 removed, 68 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 personnel termination and transfer
  • Added new ODP: time period to disable system access

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 03.09.02

Security-related system property includes hardware authentication tokens, system administration technical manuals, keys, identification cards, and building passes. Exit interviews ensure that terminated individuals understand the security constraints imposed by being former employees and that accountability is achieved for the organizational property. Security topics at exit interviews include reminding individuals of potential limitations on future employment and non-disclosure agreements. Exit interviews may not always be possible for some individuals, including in cases related to the unavailability of supervisors, illnesses, or job abandonment. The timely execution of termination actions is essential for individuals who have been terminated for cause. Organizations may consider disabling the accounts of individuals who are being terminated prior to the individuals being notified. This requirement applies to the reassignment or transfer of individuals when the personnel action is permanent or of such extended duration as to require protection. Protections that may be required for transfers or reassignments to other positions within organizations include returning old and issuing new identification cards, keys, and building passes; changing system access authorizations (i.e., privileges); closing system accounts and establishing new accounts; and providing access to official records to which individuals had access at previous work locations in previous system accounts.

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 3.9.2 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.

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 03.09.02
bedrock-cmmc-api@89b8e8e:docs/reference/nist-800-171-rev3/normalized/rev3.json#requirements[]