03.01.16: Wireless Access

To meet the 03.01.16: wireless access requirement, you must control how wireless is introduced, configured, and monitored in any environment that stores, processes, or transmits CUI, so only authorized wireless access is allowed and it is managed as part of your system boundary. Document the wireless design in your SSP, assign owners, collect operating evidence, and track gaps in a POA&M. ¹

Key takeaways:

• Treat wireless as a governed entry point to your CUI environment, not a convenience feature.
• Your assessor will look for authorized wireless architecture, secure configuration, and recurring evidence that controls operate.
• Tie wireless decisions (allow/deny, segmentation, authentication) to your SSP boundary, owners, and POA&M closure. ¹

Wireless is one of the fastest ways for an otherwise well-controlled environment to drift out of compliance: a “temporary” access point, a guest SSID bridged to internal networks, or unmanaged Wi‑Fi on lab gear can quietly create an uncontrolled path into systems handling CUI. The 03.01.16: wireless access requirement in NIST SP 800-171 Rev. 3 forces discipline: define what wireless is permitted, under what conditions, and how you keep it under control over time. ¹

For a CCO, Compliance Officer, or GRC lead, the goal is operational clarity. You need to (1) identify every wireless capability that touches your CUI boundary, (2) decide what is allowed vs. prohibited, (3) implement technical guardrails your IT team can run consistently, and (4) maintain evidence that stands up in an assessment. This page is written to help you translate the requirement into a workable control: scoped, owned, measurable, and provable with artifacts you can produce on demand. ¹

Regulatory text

Requirement: “NIST SP 800-171 Rev. 3 requirement 03.01.16 (Wireless Access).” ¹

What the operator must do (practical interpretation of the text): implement managed controls over wireless access within the system environment that handles CUI, and document how wireless is authorized, configured, and monitored as part of your system security posture and boundary. Your implementation must be concrete enough that an assessor can trace: policy → architecture/controls → evidence of operation. ¹

Plain-English interpretation (what it means day to day)

If wireless can reach your CUI systems (directly or indirectly), you must:

• Know where wireless exists (corporate Wi‑Fi, plant/warehouse Wi‑Fi, IoT radios, hotspots, tethering, wireless bridges).
• Approve it explicitly (no “rogue” access points, no ad hoc SSIDs, no surprise bridges to internal networks).
• Secure it to a defined standard (strong authentication, encryption, segmentation, device management).
• Prove it stays secure through recurring checks, logging, and remediation tracking. ¹

A useful operator test: if you cannot explain, in one page, how a wireless client authenticates and what networks it can and cannot reach, you are not ready for assessment.

Who it applies to (entity + operational context)

This requirement applies to nonfederal organizations handling CUI, including defense contractors and federal contractors, wherever wireless access is part of the environment supporting CUI. ¹

Typical in-scope contexts:

• Offices where endpoints connect over Wi‑Fi and can access CUI repositories.
• Production floors, labs, or warehouses where Wi‑Fi supports scanners, tablets, or test equipment that interfaces with CUI systems.
• Conference rooms and guest networks that share infrastructure with corporate networks.
• Managed service environments where a third party provides wireless infrastructure, monitoring, or on-site IT. ¹

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

Use the steps below as an implementation checklist you can hand to IT and validate through governance.

1) Define the wireless scope and boundary in your SSP

• Identify which enclaves, sites, and networks are in the CUI system boundary.
• Document whether wireless is allowed, prohibited, or conditionally allowed inside that boundary.
• Map wireless components to the SSP: access points/controllers, NAC/AAA, directory services, MDM, logging/SIEM, and firewall/segmentation points.
• Assign a control owner (network/security) and an accountable executive (system owner). ¹

Daydream tip: In Daydream, track this as a requirement-to-SSP mapping task with named system components and an owner, so evidence collection and POA&M items stay attached to the requirement.

2) Publish enforceable wireless rules (policy + standard)

Write a short wireless standard that answers:

• Which wireless technologies are permitted (enterprise Wi‑Fi, BLE devices, cellular hotspots, etc.).
• What is prohibited (personal hotspots bridging to corporate, consumer mesh routers, wireless bridges).
• Minimum security configuration required for any permitted wireless.
• Approval process for exceptions and temporary wireless (who approves, how long it lasts, how it’s removed). ¹

Keep it enforceable. If you can’t test it, rewrite it.

3) Build a defensible technical architecture

A common “clean” pattern assessors understand:

• Separate SSIDs/VLANs for corporate, CUI-eligible, and guest traffic.
• Strong authentication for internal SSIDs (for example, certificate-based or directory-backed).
• Segmentation that prevents wireless clients from laterally moving into sensitive subnets without explicit authorization.
• Administrative access to wireless controllers restricted and logged. ¹

If you allow BYOD at all, be explicit about whether BYOD can access CUI. Many teams simplify compliance by disallowing BYOD access to CUI paths.

4) Implement wireless access controls you can continuously operate

You need controls that stay true after staff turnover and site changes:

• Centralized configuration management for APs/controllers (avoid one-off configs).
• Asset inventory coverage for wireless infrastructure (including remote sites).
• Rogue AP detection or compensating controls (periodic RF scans, switchport controls, NAC alerts).
• Logging and alerting for authentication events and admin changes. ¹

5) Establish recurring operational checks (make it measurable)

Define “what good looks like” as testable criteria, then schedule reviews:

• Approved SSIDs only; no ad hoc SSIDs.
• Encryption/authentication settings match your standard.
• Guest network cannot route to internal/CUI networks.
• Quarterly (or your chosen cadence) review of wireless configs, admin accounts, and alerts, with documented results and remediation tickets. ¹

The cadence is your choice; what matters is you can show it happens consistently and issues close.

6) Manage exceptions through POA&M, not hallway conversations

When wireless doesn’t meet the standard (legacy scanners, third party-managed Wi‑Fi, building constraints):

• Create a POA&M entry with risk description, compensating controls, owner, and target closure.
• Validate closure with evidence (config export, scan results, screenshots, change record).
• Update SSP language when the boundary or design changes. ¹

Required evidence and artifacts to retain

Assessments often fail on “we did it” without proof. Retain artifacts that show both design and operation:

Governance artifacts

• Wireless access policy/standard and exception process.
• SSP section describing wireless boundary, components, and control implementation.
• Network diagrams showing SSIDs/VLANs, firewall rules, and CUI enclave segmentation.
• Control ownership and RACI notes (who approves changes, who reviews logs). ¹

Technical evidence (operational)

• Wireless controller/AP configuration exports (sanitized if needed).
• Screenshots or reports showing SSID list, security settings, and guest isolation.
• Authentication logs (AAA/RADIUS/IdP) and admin activity logs.
• Rogue AP detection reports or RF scan results, plus investigation tickets.
• Change management records for wireless changes (requests, approvals, implementation notes).
• Periodic review records and resulting remediation tickets.
• POA&M entries for gaps, with closure validation. ¹

Common exam/audit questions and hangups

Expect questions framed like these:

• “Show me all wireless networks that exist at Site A and how you know there aren’t others.”
• “Can a guest or unmanaged device ever reach the CUI enclave? Prove it with firewall rules.”
• “Who can administer the wireless controller, and where is that access logged?”
• “How do you detect a rogue AP plugged into an open switchport?”
• “Where is this described in the SSP, and what evidence shows it operates as written?” ¹

Hangup pattern: teams provide a policy and a diagram but no recurring evidence (logs/reviews) that the controls remain in place.

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails	How to avoid it
“Guest Wi‑Fi” shares routing with corporate networks	Creates an uncontrolled bridge to internal resources	Enforce hard segmentation and prove it with firewall rules and tests
Unmanaged access points at remote sites	Central IT can’t vouch for config or patching	Standardize on centrally managed APs or document compensating controls and monitoring
BYOD allowed without a clear CUI stance	Scope confusion and inconsistent enforcement	Decide: BYOD blocked from CUI, or BYOD must be managed; document and implement
No rogue AP story	Assessors assume unknown wireless exists	Use detection tooling or periodic scans plus documented response playbooks
SSP says “wireless is controlled” but can’t name components	Control is not assessable	Map requirement → systems → owners in the SSP and keep it current 1

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so don’t over-rotate on penalties or case law here.

Practically, wireless failures create the kind of “unbounded access” scenario that assessors flag quickly: unknown entry points, weak authentication, and uncontrolled lateral movement. For CUI environments, that translates into higher likelihood of assessment findings, POA&M burden, and program risk if wireless is pervasive and poorly governed. ¹

Practical 30/60/90-day execution plan

No timeline is mandated by the provided source. Use this phased plan to drive execution without inventing regulatory deadlines. ¹

First 30 days (stabilize and scope)

• Declare a temporary rule: no new SSIDs/APs without approval.
• Inventory wireless infrastructure across sites (owned, third party-managed, and shadow IT candidates).
• Identify which wireless networks can reach the CUI boundary (directly or via routing).
• Draft SSP updates: wireless boundary statement, component list, owner assignment.
• Start evidence collection: config exports, SSID lists, admin account lists, network diagrams. ¹

Days 31–60 (standardize and enforce)

• Publish a wireless standard with clear allow/deny conditions and exception workflow.
• Implement segmentation for guest and noncompliant devices.
• Centralize management and logging for controllers/APs where possible.
• Stand up rogue AP detection or a scheduled scanning process, and document response steps.
• Open POA&M items for gaps that require procurement, redesign, or third party coordination. ¹

Days 61–90 (prove operation and close gaps)

• Run a formal wireless control review: configs, logs, exceptions, and remediation status.
• Validate guest isolation and segmentation with repeatable test steps and saved outputs.
• Close POA&M items that are ready; attach closure evidence and update SSP text where reality changed.
• Package an “assessment-ready” evidence set mapped to 03.01.16 for quick production during audits. Daydream can keep the mapping, evidence, and POA&M status in one place so the story stays consistent. ¹

Frequently Asked Questions

Does 03.01.16 require that wireless be banned in CUI environments?

No. The requirement is about controlling wireless access. If you allow wireless, document how it is secured and monitored within your system boundary. ¹

Our Wi‑Fi is managed by a third party (MSP/facilities). Are we still on the hook?

Yes. You can outsource operations, but you still need governance, SSP accuracy, and evidence that the wireless controls operate. Treat the provider as a third party with contract requirements and evidence delivery expectations. ¹

What evidence is most persuasive to an assessor for wireless access control?

Configuration exports from controllers/APs, segmentation rules, authentication/admin logs, and documented recurring reviews with remediation tickets. A policy alone rarely satisfies assessors. ¹

Is a guest network automatically out of scope?

Not automatically. If guest wireless shares infrastructure, routing, or credentials that could impact the CUI boundary, it becomes relevant. Prove isolation with diagrams and firewall rules. ¹

How do we handle personal hotspots and phone tethering?

Treat them as prohibited or tightly controlled pathways in your standard, then enforce with technical controls where feasible and with monitoring and policy enforcement where technical controls are limited. Document the decision and enforcement approach in your SSP and procedures. ¹

What should go into the POA&M for wireless gaps?

The specific gap (what, where), risk statement, compensating controls, owner, target completion criteria, and closure evidence you will collect (for example, config change record plus validation test output). ¹

Footnotes

1. NIST SP 800-171 Rev. 3