NIST SP 800-171 Rev. 3·Requirement 3.4.10·high·Component: Configuration Management

What this control requires

This control requires the development and documentation of an inventory of system components, including hardware, software, and firmware. It mandates regular reviews and updates of the inventory and ensures that updates are made whenever system components are installed, removed, or updated, ensuring proper accountability of all system components. This control supports the System Inventory Management capability within the Configuration Management (3.4) family.
— NIST SP 800-171 Rev. 3, Requirement 3.4.10

In plain English

This control requires the development and documentation of an inventory of system components, including hardware, software, and firmware. 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 Configuration Management, the assessor will trace your implementation back to the catalogue reference (Requirement 3.4.10) and look for objective evidence on the latest two assessment cycles.

How to implement

Asset Inventory

AWS. AWS Config Aggregator across every account + region gives a real-time inventory; ship the daily snapshot to S3 and surface drift in Security Hub.

Azure. Azure Resource Graph plus Defender for Cloud's inventory blade enumerates every subscription; export to Log Analytics for retention and Workbooks for reporting.

GCP. Cloud Asset Inventory exports a daily feed of every resource and IAM binding; query via BigQuery and alert on appearance/disappearance.

Endpoints. Pipe MDM telemetry (Intune / Jamf / Workspace ONE) into your CMDB so laptops and phones are inventoried with the same rigour as cloud resources.

Operational checklist

  • Access. Document the trigger, the owner and the cadence.
  • Configuration. Document the trigger, the owner and the cadence.
  • System. Document the trigger, the owner and the cadence.
  • Risk. Document the trigger, the owner and the cadence.
  • Scope: management, configuration, software, component inventory, hardware, firmware, system components, development.

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: System Component Inventory.

Common pitfalls

  • Inventories that exclude SaaS, shadow IT and ephemeral cloud resources (Lambda, Cloud Run, K8s pods) miss the assets where most modern incidents start.

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.

Related controls in NIST SP 800-171 Rev. 3

References

Topics: governance riskidentity accessidentity managementaccess reviewprivileged accessasset inventory