NIST SP 800-171 Rev. 3 3.11.1 — Risk Assessment

What this control requires

This control requires assessing the risk of unauthorized disclosure of Controlled Unclassified Information (CUI) resulting from the processing, storage, or transmission of CUI. It includes updating risk assessments regularly and considering risks from external parties, such as contractors and service providers, in relation to supply chain security.

In plain English

This control requires assessing the risk of unauthorized disclosure of Controlled Unclassified Information (CUI) resulting from the processing, storage, or transmission of CUI. In practice, this means you can prove you information 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 Risk Assessment, the assessor will trace your implementation back to the catalogue reference (Requirement 3.11.1) and look for objective evidence on the latest two assessment cycles.

How to implement

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

• Information. Document the trigger, the owner and the cadence.
• Risk. Document the trigger, the owner and the cadence.
• Security. Document the trigger, the owner and the cadence.
• Transmission. Document the trigger, the owner and the cadence.
• Policy. Document the trigger, the owner and the cadence.
• Scope: management, cui, security, storage, transmission, assessment, contractors, service providers.

Evidence to collect

• Vendor Risk Management. vendor_risk_management evidence
• Policy Document. A signed and version-controlled policy / standard / procedure document.

Third-party risk management evidence (assessments, contracts, due diligence) shows supplier oversight. Signed policy or standard documents the safeguard. Focus: Risk Assessment.

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.

• ISO/IEC 27001:2022 A.5.19 — Information security in supplier relationships
• NIST SP 800-53 Rev. 5 CP-2(7) — Coordinate With External Service Providers
• CIS Controls v8 3.8 — Document Data Flows
• SOC 2 (2017 TSC) CC9.2 — Vendor Risk Management
• GDPR Article 28 — Processor

Related controls in NIST SP 800-171 Rev. 3

• Requirement 3.16.3 — External System Services
• Requirement 3.16.2 — Unsupported System Components
• Requirement 3.11.4 — Risk Response
• Requirement 3.1.20 — Use of External Systems
• Requirement 3.12.1 — Security Assessment
• Requirement 3.12.5 — Information Exchange

References

• NIST Computer Security Resource Center — NIST SP 800-171 Rev. 3
• Catalogue identifier: Requirement 3.11.1

Topics: governance riskvendor riskvendor managementsupply chain securitypolicy managementthird party monitoring