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NIST SP 800-171 CUI Protection Center

03.04.03 — Configuration Change Control

Read the official CUI requirement and assessment content, then use the separately labeled Bare Metal Cyber perspective to connect it to implementation, evidence, and sustained operation.

1Source controls
7Assessment objectives
3Assessment methods

03.04 — Configuration Management · NIST SP 800-171 Revision 3

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Official NIST requirement content

Security requirement

  1. a.Define the types of changes to the system that are configuration-controlled.
  2. b.Review proposed configuration-controlled changes to the system, and approve or disapprove such changes with explicit consideration for security impacts.
  3. c.Implement and document approved configuration-controlled changes to the system.
  4. d.Monitor and review activities associated with configuration-controlled changes to the system.
Official NIST discussion

Discussion

Configuration change control refers to tracking, reviewing, approving or disapproving, and logging changes to the system. Specifically, it involves the systematic proposal, justification, implementation, testing, review, and disposition of changes to the system, including system upgrades and modifications. Configuration change control includes changes to baseline configurations for system components (e.g., operating systems, applications, firewalls, routers, mobile devices) and configuration items of the system, changes to configuration settings, unscheduled and unauthorized changes, and changes to remediate vulnerabilities. This requirement is related to 03.04.04.

Bare Metal Cyber interpretation

Implementation perspective

Treat Configuration Change Control as a CUI protection outcome that must be reflected in the system boundary, documented implementation, operational behavior, and assessment evidence. Pay particular attention to approved baselines, secure configuration, change control, inventories, and drift management within the CUI boundary.

  1. Confirm the requirement is in scope for the CUI system components, services, users, and external connections being assessed.
  2. Resolve every organization-defined parameter through an approved governance and tailoring process.
  3. Map each clause of the requirement to an accountable owner, implementation mechanism, and evidence source.
  4. Verify that inherited and shared implementations are supported by current provider evidence and responsibility boundaries.
  5. Collect evidence during normal operation and review changes, exceptions, and deficiencies on a risk-based cadence.

Questions to ask

  • Which CUI assets, data flows, users, and services are protected by this requirement?
  • Which portions are implemented locally, inherited, shared, or not applicable, and what evidence supports that determination?
  • Do the system security plan, deployed configuration, operating process, and assessment evidence tell the same story?
  • What change, incident, or threshold should trigger reassessment?

Evidence and validation

  • approved baseline configurations
  • change tickets and approvals
  • configuration scan and drift reports
  • software and hardware inventories

Common failure patterns

  • baselines documented but not enforced
  • emergency changes never reconciled
  • cloud or ephemeral assets missing from inventory
  • security impact analysis performed after deployment
Official NIST SP 800-171A content

Assessment objectives and methods

Assessment objectives (7)
  1. a.

    the types of changes to the system that are configuration-controlled are defined.

  2. b.

    proposed configuration-controlled changes to the system are reviewed with explicit consideration for security impacts.

  3. b.

    proposed configuration-controlled changes to the system are approved or disapproved with explicit consideration for security impacts.

  4. d.

    activities associated with configuration-controlled changes to the system are monitored.

  5. d.

    activities associated with configuration-controlled changes to the system are reviewed.

  6. c.

    approved configuration-controlled changes to the system are implemented.

  7. c.

    approved configuration-controlled changes to the system are documented.

Examine

  • configuration management policy and procedures
  • procedures for system configuration change control
  • configuration management plan
  • system architecture
  • configuration settings
  • change control records
  • system audit records
  • change control audit and review reports
  • agenda, minutes, and documentation from configuration change control oversight meetings
  • system security plan
  • other relevant documents or records

Interview

  • personnel with configuration change control responsibilities
  • personnel with information security responsibilities
  • members of change control board or similar
  • system administrators

Test

  • processes for configuration change control
  • mechanisms that implement configuration change control
Official source-control relationships

Source NIST SP 800-53 controls

These controls are referenced by the official SP 800-171 Rev. 3 OSCAL record. Open the corresponding control pages for complete control text, enhancements, D3FEND mappings, and related learning.

Source controlCM-3Open SP 800-53 control →
Source record

Authoritative sources

Bare Metal Cyber is an independent educational publisher and is not affiliated with or endorsed by NIST. The official publications, the responsible federal agency, and the governing contract or agreement determine applicability, tailoring, assessment depth, and required implementation.