03.01.09: System Use Notification

03.01.09: system use notification requirement means you must display a clear, persistent notice on systems that process CUI stating the system is for authorized use, activity may be monitored/recorded, and users have no expectation of privacy. Operationalize it by standardizing approved banner language, deploying it across interactive access points, and retaining configuration evidence and screenshots. ¹

Key takeaways:

• Put an approved “consent-to-monitoring” notice in front of user access, not buried in a policy. ¹
• Cover all access paths: consoles, VPN/VDI, remote access, bastions, SaaS portals, and privileged admin tools. ¹
• Keep assessor-ready proof: baseline configs, screenshots, and change records tied to your SSP/POA&M. ¹

System use notifications are a deceptively small control that often becomes an assessment finding because it touches many technical entry points and can drift over time. For NIST SP 800-171 Rev. 3, your job is straightforward: anyone accessing a system that stores, processes, or transmits CUI must be presented with a notice that sets expectations for authorized use and monitoring, and establishes user consent through continued access. ¹

For a Compliance Officer, CCO, or GRC lead, the fastest path is to treat this as a “banner standard + deployment coverage” requirement. You need one approved message, a scoped list of system components where interactive access occurs, and a method to prove the banner is in place and stays in place after patching, OS upgrades, and identity stack changes. ¹

This page gives you requirement-level implementation guidance you can hand to IT and security engineering, then audit internally with clear evidence expectations. It also shows how to map the requirement to your SSP control narrative and manage gaps in a POA&M without losing track of ownership. ¹

Regulatory text

Requirement: “NIST SP 800-171 Rev. 3 requirement 03.01.09 (System Use Notification).” ¹

Operator interpretation of the text: You must display a system use notification before or at the time of login/connection (or other interactive access) to covered systems. The notice must communicate authorized use conditions and that monitoring/recording may occur, so users understand access is conditional and consent-based. ¹

What an assessor will look for:

• A standardized notice (banner) approved by the organization.
• Technical deployment across the in-scope environment (not a single server).
• Evidence that deployment is maintained (configuration management, periodic checks, and change control). ¹

Plain-English interpretation (what you’re being asked to accomplish)

You are establishing informed consent and deterrence. The banner warns unauthorized users, sets behavioral expectations for authorized users, and supports your legal/disciplinary posture by making monitoring explicit. Practically, the control fails when the notice exists only in a policy or appears only on a subset of entry points. ¹

Who it applies to

In-scope entities

• Defense contractors and federal contractors operating nonfederal systems that handle CUI. ¹
• Any organization implementing NIST SP 800-171 Rev. 3 for CUI protection in nonfederal environments. ¹

In-scope operational context (where banners must exist)

Apply the notification anywhere a user can interactively access an in-scope system, including:

• Endpoints used to access CUI environments (workstations, jump hosts, VDI).
• Network access points (VPN portals/clients, remote access gateways).
• Server logon paths (console, RDP, SSH, hypervisor consoles).
• Privileged access tooling (PAM portals, bastions).
• Web applications that provide authenticated access to CUI workflows or CUI repositories. ¹

A common scoping decision: if a system is out of scope for CUI, you can still deploy the same banner enterprise-wide for simplicity. That is usually easier to operate and prove, but document your boundary either way in the SSP. ¹

What you actually need to do (step-by-step)

Step 1: Write and approve standard banner language

Create one approved notice with legal and HR review. Keep it short enough that people read it, but explicit enough that it establishes consent to monitoring.

Minimum content checklist (practical):

• Authorized use only / no unauthorized access.
• Activity may be monitored and recorded.
• Continued use indicates consent to monitoring.
• No expectation of privacy (or similar plain statement). ¹

Decision point: “Click-through” versus “display only.”

• Display-only is common for OS-level pre-login banners.
• Click-through is common for web apps and VPN portals.
  Either can satisfy the intent if the notice is presented at access time and is not bypassed. Document your approach in the SSP. ¹

Step 2: Build an “access-path inventory” for covered systems

You cannot deploy what you cannot enumerate. Create a table that lists each in-scope system/service and its interactive entry points.

Example inventory columns:

• System/component name
• CUI relevance (stores/processes/transmits)
• Access method (local console, SSH, RDP, web, VPN, VDI, PAM)
• Banner mechanism (GPO, SSHD config, cloud setting, app config)
• Owner (IT ops, cloud team, app team)
• Evidence type (screenshot, exported config, policy object) ¹

Step 3: Implement the banner technically per platform

Treat this as configuration-as-standard:

• Windows: pre-logon interactive logon message via Group Policy where applicable.
• Linux/Unix: SSH pre-login banner (and console where relevant).
• VPN/Zero Trust: portal banner and/or client connection banner.
• SaaS / web apps: authenticated landing-page notice or login screen notice; for custom apps, add to SSO flow or app header.
• PAM/bastions: banner at vault login and session initiation. ¹

If you have third-party hosted environments, push the requirement into the third party control obligations and verify via evidence, not trust. ¹

Step 4: Define measurable implementation criteria (so it’s auditable)

Write acceptance criteria that an engineer can test and an assessor can verify:

• Banner appears prior to granting interactive access for each listed access path. ¹
• Banner text matches the approved standard (allowing minor platform formatting differences).
• Banner cannot be removed without a tracked change.
• Periodic verification occurs and is recorded. ¹

Step 5: Validate coverage with testing, then schedule recurring checks

Run a validation sweep:

• Sample each access path in the inventory and capture proof.
• For configuration-managed environments, export policy objects or configuration states.
• Add a recurring check tied to your configuration compliance or internal control testing program. ¹

Step 6: Map to SSP and manage exceptions in the POA&M

In your SSP, document:

• Where the banner is enforced (systems and access paths).
• The standard language and where it is stored/controlled.
• Who owns deployment and who tests it. ¹

If gaps exist, track them in a POA&M with: scope, owner, target completion, and closure evidence. Close only after validation confirms the banner appears at the relevant access point. ¹

Where Daydream fits (practitioner use case): Daydream can help you keep the access-path inventory, SSP mapping, evidence collection tasks, and POA&M items linked so the banner doesn’t become an annual scavenger hunt during assessments. ¹

Required evidence and artifacts to retain

Keep evidence that proves both design (what you intended) and operation (what is in place now).

Design/approval artifacts

• Approved banner standard (policy or standard with version control).
• Approval record (ticket/workflow, sign-off).
• SSP control narrative mapping 03.01.09 to responsible components and owners. ¹

Implementation/operation artifacts

• Screenshots of banners for representative systems/access paths (timestamped).
• Exported configurations (GPO reports, SSHD config snippets, VPN portal settings exports, app config).
• Change tickets showing initial deployment and subsequent modifications.
• Periodic verification records (internal control test steps and results). ¹

Exception handling

• Documented exceptions with compensating controls, risk acceptance, and planned remediation (POA&M). ¹

Common exam/audit questions and hangups

Assessors and auditors tend to drill on three areas:

1. “Show me where the user sees it.”
   They will ask you to demonstrate the banner live, or provide screenshots tied to specific assets. A policy alone rarely satisfies this control intent. ¹

2. “Does it cover remote and privileged paths?”
   Teams often cover Windows logon but miss VPN portals, bastions, or cloud consoles. Keep the access-path inventory current. ¹

3. “How do you know it stays in place?”
   Expect questions about drift: OS upgrades, domain changes, new VPN solutions, or new SaaS apps. Show change control and periodic verification. ¹

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails	Fix
Banner exists only in an employee handbook	Users can access systems without seeing it	Deploy technical banners at access points, then reference the policy as backup. 1
One banner covers Windows, but VPN and web apps are ignored	Users can reach CUI apps through alternate paths	Maintain an access-path inventory and test each path. 1
Text differs across platforms without approval	Creates inconsistency and weakens consent language	Create an approved “platform variants” appendix with controlled wording. 1
No evidence beyond a screenshot from years ago	Doesn’t prove current operation	Collect recurring evidence and tie it to configuration management. 1
Exceptions handled informally	Exceptions become permanent	Put exceptions into the POA&M with owner and closure validation. 1

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so this page does not cite specific actions. ¹

Operational risk still matters:

• Without a system use notification, you reduce your ability to show that users were warned about monitoring and authorized-use constraints, which can complicate incident response, HR actions, and legal posture. ¹
• In assessments against NIST SP 800-171, missing or inconsistently deployed banners are common “easy findings” because they are visible and testable. Treat it as a hygiene control with high audit visibility. ¹

Practical 30/60/90-day execution plan

First 30 days (establish the standard and scope)

• Draft banner language and route for approval (legal/HR/security). ¹
• Define the CUI system boundary and list in-scope systems/services. ¹
• Build the access-path inventory and assign owners per entry point.
• Update the SSP control statement for 03.01.09 with intended mechanisms and responsible teams. ¹

Days 31–60 (deploy and validate)

• Implement banners on the highest-risk/highest-traffic entry points first (VPN/VDI, bastions, primary CUI apps). ¹
• Capture baseline evidence (screenshots/config exports) for each access path in the inventory.
• Log gaps in the POA&M with clear closure criteria and validation steps. ¹

Days 61–90 (operationalize and prevent drift)

• Add recurring verification to your control testing cadence and configuration compliance checks. ¹
• Tie banner settings to standard builds (gold images), GPO baselines, and infrastructure-as-code where available.
• Run an internal audit-style walkthrough: pick a sample of systems, demonstrate the banner, and show the evidence trail and change history. ¹

Frequently Asked Questions

Does the banner have to appear before login, or is a post-login pop-up acceptable?

Put the notice at or before the point where interactive access is granted, so the user sees it as a condition of access. If a post-login notice can be bypassed or missed, it is harder to defend in an assessment. ¹

Can we use one enterprise-wide banner even for systems that don’t touch CUI?

Yes, many teams standardize across the enterprise to reduce operational complexity. Document your CUI boundary in the SSP so assessors understand what was required versus what you chose to standardize. ¹

What systems count as “interactive access points” for evidence purposes?

Any path where a human user authenticates or starts a session into the in-scope environment can qualify, including VPN, VDI, SSH/RDP, PAM tools, and authenticated web apps. Build your access-path inventory so nothing is “assumed covered.” ¹

We use SSO for most apps. Is an IdP login-page banner enough?

Sometimes, but only if the IdP banner is consistently presented for access to the in-scope apps and cannot be skipped. If some access paths bypass the IdP banner (direct app auth, API tokens, service accounts), address those separately and document the logic in the SSP. ¹

Do service accounts or non-interactive accounts need to see a banner?

Banners are mainly about interactive user sessions. Still, confirm that administrators do not use non-interactive mechanisms to get interactive access without seeing the notice, and document how you handle non-interactive access in your broader access control design. ¹

What’s the fastest way to prove we meet 03.01.09 in an assessment?

Maintain an access-path inventory, keep approved standard banner language, and store current screenshots/config exports per access path with change tickets. That package answers most assessor questions quickly. ¹

Footnotes

1. NIST SP 800-171 Rev. 3