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CMMC guide

NIST SP 800-171: the 14 control families, the 110 requirements and CUI scoping

Every defense supplier that handles CUI is held to the same 110 requirements. This is what they are, how they group into 14 families, which revision applies, and how to draw the boundary so they cover as little of the company as possible.

ColdFeet Inc.Comply · Summary

Continuous compliance

Configuration checks on 62 monitored endpoints, last run 14 minutes ago

Total Active Violations
38
Total Passed Checks
3,090
Monitored Endpoints
62
SOC 2 Type II score
98.8%
ControlSOC 2 Type II requirementSeverityEndpoints failing
Ensure 'Minimum password length' is set to 14 or more charactersCIS Microsoft Windows 11 Enterprise BenchmarkCC6.1High9 of 62
Ensure BitLocker is enabled on the operating system driveCIS Microsoft Windows 11 Enterprise BenchmarkCC6.7Critical1 of 62
Ensure SSH root login is disabledCIS Ubuntu Linux 22.04 LTS BenchmarkCC6.1High2 of 62
Ensure screen locks after 15 minutes of inactivityCIS Microsoft Windows 11 Enterprise BenchmarkCC6.1Medium14 of 62
Ensure audit logs are kept for at least 90 daysCIS Ubuntu Linux 22.04 LTS BenchmarkCC7.2Medium4 of 62
Ensure automatic OS updates are enabledCIS Apple macOS 14 Sonoma BenchmarkCC7.1Medium6 of 62
Ensure the firewall is enabledCIS Apple macOS 14 Sonoma BenchmarkCC6.6Low2 of 62
Sample data

What is NIST SP 800-171?

NIST Special Publication 800-171, “Protecting Controlled Unclassified Information in Nonfederal Systems and Organizations”, turns the federal government’s internal security controls into a shorter set that a private company can implement. Each requirement says what must be true, not which product to buy.

Its companion, NIST SP 800-171A, breaks the 110 requirements into 320 assessment objectives. Those objectives are what an assessor, or you in a self-assessment, actually test.

Who has to comply with NIST SP 800-171?

Any DoD contractor or subcontractor whose contract includes DFARS 252.204-7012 and who stores, processes or sends covered defense information. The clause also requires reporting cyber incidents to DoD within 72 hours and keeping images of affected systems for 90 days. DFARS 252.204-7019 and 7020 add the scored assessment posted in SPRS, and CMMC Level 2 adds the assessment cycle.

Other agencies apply it through their own contract terms, and universities that hold CUI for federal research are often covered too.

The 14 control families and 110 requirements

NIST SP 800-171 Rev 2 families and requirement counts
FamilySectionRequirements
Access Control3.122
Awareness and Training3.23
Audit and Accountability3.39
Configuration Management3.49
Identification and Authentication3.511
Incident Response3.63
Maintenance3.76
Media Protection3.89
Personnel Security3.92
Physical Protection3.106
Risk Assessment3.113
Security Assessment3.124
System and Communications Protection3.1316
System and Information Integrity3.147
Total110

Access control, identification and authentication, and system and communications protection hold 49 of the 110 between them. That is where multi-factor authentication, FIPS-validated encryption and network boundary protection sit, and where most of the remediation budget usually goes.

Rev 2 vs Rev 3: which one applies?

NIST published Revision 3 in May 2024. It reorganizes the requirements into 97 across 17 families, adding Planning, System and Services Acquisition, and Supply Chain Risk Management, and it lets agencies set some parameters, such as how often a review happens.

DoD has kept Revision 2 for DFARS 7012 through a class deviation, and the CMMC rule cites Revision 2 by name. So for a defense contract today, you implement and score the 110 requirements of Rev 2. Reading Rev 3 is still worthwhile: it shows where the next contract update is likely to go.

How to scope CUI

The requirements apply to every system component that processes, stores or transmits CUI, and to the components that protect them. Scoping decides how much of the company that is. The DoD Level 2 scoping guide sorts assets into five groups:

  • CUI assets: anything that holds or moves CUI. Fully in scope.
  • Security protection assets: the firewall, the identity provider, the logging tools that protect CUI assets. In scope.
  • Contractor risk managed assets: can reach CUI but are not meant to, and are covered by policy. Documented in the SSP.
  • Specialized assets: test equipment, operational technology, government-furnished equipment. Documented, with their own risk treatment.
  • Out-of-scope assets: cannot reach CUI at all, separated physically or logically.

Two decisions move the scope more than anything else: whether CUI stays inside an enclave rather than spreading across the whole network, and where email and files live. A cloud service that stores CUI must meet the FedRAMP Moderate baseline or its equivalent under DFARS 7012, which is why many suppliers move CUI to Microsoft 365 GCC High or a dedicated enclave.

The documents you need

  • System Security Plan (SSP): the boundary, the environment and how each requirement is met. Requirement 3.12.4.
  • Plan of Action and Milestones (POA&M): each open requirement with its fix, owner and date. Requirement 3.12.2.
  • Policies and procedures for each family, kept current.
  • Evidence: configurations, logs, screenshots, training records and reviews that show each of the 320 objectives is met.
  • The scored assessment posted in SPRS. See how the SPRS score works.

With AccuSights: we scope the CUI, recommend an enclave when it shrinks the work, write the SSP and POA&M, and keep the evidence for all 320 objectives current so the next assessment is a review, not a rebuild.

Quick questions

How many controls are in NIST SP 800-171?
Revision 2, the version DFARS 7012 and CMMC Level 2 use, has 110 security requirements in 14 families. Revision 3, published in May 2024, has 97 requirements in 17 families but is not yet the contractual baseline for DoD.
What is the difference between NIST 800-171 and CMMC?
NIST SP 800-171 is the list of requirements. CMMC is DoD’s program for verifying them: who assesses, how often, the scoring thresholds and the annual affirmation. CMMC Level 2 uses the 110 requirements of Rev 2 unchanged.
What changed in NIST SP 800-171 Revision 3?
Revision 3 reorganizes the requirements into 97 across 17 families, adds three families (Planning, System and Services Acquisition, and Supply Chain Risk Management) and lets agencies set some parameters, such as how often a review happens.
When was NIST 800-171 Revision 3 released, and does DoD use it yet?
NIST published Revision 3 in May 2024. DoD has kept Revision 2 for DFARS 7012 through a class deviation, and the CMMC rule cites Revision 2 by name, so for a defense contract today you implement and score the 110 requirements of Revision 2.
Is NIST SP 800-171 mandatory?
It is mandatory when your contract requires it, which DFARS 252.204-7012 does for DoD contractors handling covered defense information. It is not a law that applies to every company.
What is the difference between NIST 800-171 and NIST 800-53?
NIST SP 800-53 is the full control catalog for federal systems, with hundreds of controls. NIST SP 800-171 is derived from it for nonfederal systems that hold CUI, and keeps the requirements that protect its confidentiality.
How long does NIST SP 800-171 compliance take?
It depends on scope and starting point. Writing the SSP and scoring the gaps usually takes weeks; closing the gaps, especially multi-factor authentication, encryption and logging, often takes several months. An enclave can shorten both.

Sources

Requirement counts and rules on this page were checked against these primary sources in October 2026.

  1. NIST SP 800-171 Rev 2
  2. NIST SP 800-171 Rev 3
  3. NIST SP 800-171A: assessing the requirements
  4. DFARS 252.204-7012: safeguarding covered defense information
  5. DFARS 252.204-7019: notice of NIST SP 800-171 DoD assessment requirements
  6. DoD CIO: CMMC Level 2 Scoping Guide
  7. 32 CFR Part 170: the CMMC Program rule
  8. National Archives: CUI Registry

Written by the AccuSights compliance team and updated October 2026. Figures are quoted from the sources named here and were current when checked. This page is general information, not legal advice. AccuSights is not a C3PAO, is not affiliated with the Cyber AB or the Department of Defense, and does not certify or guarantee certification. We prepare you for your CMMC assessment; we do not conduct it. Third-party assessments are subject to DoD and Cyber AB rules as published, which may change.

Next step

Want the 110 mapped to your environment?

Tell us where your CUI lives. We’ll scope the boundary on a 30-minute call and put the readiness fee in writing.

The regulator has the final say. We help interpret, scope and get you ready; we do not certify.

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