NIST SP 800-171 Rev. 3 3.10.1 — Physical Access Authorizations

What this control requires

This control requires the development, approval, and Maintenance of a list of individuals authorized for physical access to the facility where the system resides. It includes issuing access credentials, reviewing the access list regularly, and removing individuals from the list when access is no longer required. This control supports the Physical Access Management capability within the Physical Protection (3.10) family.

In plain English

This control requires the development, approval, and Maintenance of a list of individuals authorized for physical access to the facility where the system resides. In practice, this means you can prove you access management-level controls on a defined cadence.

Why it matters

DoD contractors and their subcontractors must implement all 100 SP 800-171 requirements to keep CUI handling contracts. Gaps are scored against the SPRS scoring methodology; below a 110-point starting score, each unmet requirement deducts points and a below-threshold score can disqualify a bid.

This control is rated high. Auditors expect a named owner, a remediation SLA, and a tooling artefact that evidences continuous operation.

What an auditor looks for

A C3PAO conducting a CMMC Level 2 assessment uses NIST SP 800-171A objectives. They expect a System Security Plan (SSP), Plan of Action & Milestones (POA&M) for any gaps, and objective evidence (configurations, ticket records, training records) for every requirement.

Within Physical Protection, the assessor will trace your implementation back to the catalogue reference (Requirement 3.10.1) and look for objective evidence on the latest two assessment cycles.

How to implement

Physical Security

Inheritance. For cloud-only operations, inherit physical controls from the provider's SOC 2 / ISO 27001 report and document the inheritance in the SoA.

Operational checklist

• Access. Document the trigger, the owner and the cadence.
• Protection. Document the trigger, the owner and the cadence.
• Authorized. Document the trigger, the owner and the cadence.
• System. Document the trigger, the owner and the cadence.
• Maintenance. Document the trigger, the owner and the cadence.
• Scope: management, credentials, security, individuals, maintenance, access authorizations, physical access, protection.

Evidence to collect

• Identity Scan. IAM / IdP exports — Entra ID, Okta, IAM Identity Center, Workspace directory — showing accounts, roles, MFA state and last sign-in.
• Infra Scan. Continuous infrastructure-posture telemetry — AWS Config, Azure Policy compliance, GCP Organisation Policy, Wiz / Prisma findings.

Identity analytics (Okta, SailPoint, Access Analyzer) demonstrates least-privilege. Focus: Physical Access Authorizations.

How it maps to other frameworks

Computed from shared tags, control component and key-operation subjects — handy when you are reconciling controls across an audit.

• NIST SP 800-53 Rev. 5 PE-2 — Physical Access Authorizations
• BSI C5:2020 PS-04 — Physical site access control
• SOC 2 (2017 TSC) CC6.6 — Boundary Protection
• ISO/IEC 27001:2022 A.5.15 — Access control
• CIS Controls v8 6.8 — Define and Maintain Role-Based Access Control

Related controls in NIST SP 800-171 Rev. 3

• Requirement 3.10.8 — Access Control for Transmission
• Requirement 3.10.7 — Physical Access Control
• Requirement 3.9.2 — Personnel Termination and Transfer
• Requirement 3.1.6 — Least Privilege - Privileged Accounts
• Requirement 3.8.2 — Media Access
• Requirement 3.10.2 — Monitoring Physical Access

References

• NIST Computer Security Resource Center — NIST SP 800-171 Rev. 3
• Catalogue identifier: Requirement 3.10.1

Topics: governance riskidentity accessphysical securityidentity managementaccess reviewprivileged access