NIST SP 800-171 Rev. 3 3.10.7 — Physical Access Control

What this control requires

This control requires enforcing physical access authorizations at entry and exit points to facilities housing systems that process, store, or transmit Controlled Unclassified Information (CUI). It includes verifying access, controlling ingress and egress with systems or guards, maintaining access logs, escorting visitors, securing keys and access devices, and controlling access to output devices to prevent unauthorized access to CUI. This control supports the Access Control Management capability within the Physical Protection (3.10) family.

In plain English

This control requires enforcing physical access authorizations at entry and exit points to facilities housing systems that process, store, or transmit Controlled Unclassified Information (CUI). 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 critical in the source catalogue. Treat gaps here as production incidents in the risk register, not housekeeping.

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 3.10.7) 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.

Policy Management

Docs. Keep each policy in version-controlled Markdown alongside the code that implements it; ship a signed PDF snapshot at each annual review and link the SHA into the SoA.

Operational checklist

• Access. Document the trigger, the owner and the cadence.
• Information. Document the trigger, the owner and the cadence.
• Access Control. Document the trigger, the owner and the cadence.
• Protection. Document the trigger, the owner and the cadence.
• Physical. Document the trigger, the owner and the cadence.
• Scope: management, store, cui, security, access authorizations, physical access, access control, protection.

Evidence to collect

• Policy Document. A signed and version-controlled policy / standard / procedure document.

Signed policy or standard documents the safeguard. Focus: Physical Access Control.

Common pitfalls

• Policies that no engineer has read; the version in Confluence drifts from the version that's actually being enforced.

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
• ISO/IEC 27001:2022 A.7.1 — Physical security perimeters
• BSI C5:2020 PS-04 — Physical site access control
• HIPAA (45 CFR Part 164) 164.310(a)(2)(iii) — Facility Access Controls - Access Control and Validation Procedures

Related controls in NIST SP 800-171 Rev. 3

• Requirement 3.10.2 — Monitoring Physical Access
• Requirement 3.10.1 — Physical Access Authorizations
• Requirement 3.10.8 — Access Control for Transmission
• Requirement 3.1.2 — Access Enforcement
• Requirement 3.1.9 — System Use Notification
• Requirement 3.10.6 — Alternate Work Site

References

• NIST Computer Security Resource Center — NIST SP 800-171 Rev. 3
• Catalogue identifier: Requirement 3.10.7

Topics: governance riskidentity accessphysical securitypolicy management