NIST SP 800-171 Rev. 3 3.13.2 — Recategorized as NCO

What this control requires

Employ architectural designs, software development techniques, and systems engineering principles that strengthen information security across organizational systems. This control supports the Secure Engineering Practices capability within the Situational Awareness (3.13) family.

In plain English

Employ architectural designs, software development techniques, and systems engineering principles that strengthen information security across organizational systems. 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 Situational Awareness, the assessor will trace your implementation back to the catalogue reference (Requirement 3.13.2) 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.

Secure Development

Pipeline. Require code review, SAST (Semgrep / Snyk Code), SCA (Dependabot / Renovate), secret-scanning and IaC scanning in the merge pipeline.

Branch protection. Protected branches enforce reviews, signed commits and passing CI before merge; document the protection rules as the control evidence.

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.
• Policy. Document the trigger, the owner and the cadence.
• Scope: management, software, security, nco., development.

Evidence to collect

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

Signed policy or standard documents the safeguard. Focus: Recategorized as NCO.

Common pitfalls

• Policies that no engineer has read; the version in Confluence drifts from the version that's actually being enforced.
• CI security checks set to warn-only; the merge button is faster than the security feedback.

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.8.25 — Secure development life cycle
• SOC 2 (2017 TSC) CC1.2 — Board Independence and Oversight
• BSI C5:2020 DEV-01 — Policies for the development/procurement of information systems
• HIPAA (45 CFR Part 164) 164.308(a)(5)(i) — Security Awareness and Training
• CIS Controls v8 2.6 — Allowlist Authorized Libraries

Related controls in NIST SP 800-171 Rev. 3

• Requirement 3.16.1 — Security Engineering Principles
• Requirement 3.13.10 — Cryptographic Key Establishment and Management
• Requirement 3.17.3 — Supply Chain Requirements and Processes
• Requirement 3.13.13 — Mobile Code
• Requirement 3.13.15 — Session Authenticity
• Requirement 3.4.1 — Baseline Configuration

References

• NIST Computer Security Resource Center — NIST SP 800-171 Rev. 3
• Catalogue identifier: Requirement 3.13.2

Topics: governance riskpolicy managementsecure development