03.02.01: Literacy Training and Awareness

03.02.01: literacy training and awareness requirement means you must train all personnel who can access or handle CUI (or support the systems that process it) so they understand their security responsibilities and can recognize common threats. To operationalize it fast, define role-based training, deliver it on hire and periodically, and retain completion, content, and effectiveness evidence for assessors. (NIST SP 800-171 Rev. 3)

Key takeaways:

• Build a documented training program tied to CUI handling and system access, not a generic “security slide deck.” (NIST SP 800-171 Rev. 3)
• Prove operation with artifacts: rosters, completion logs, training content versions, and exceptions tracking. (NIST SP 800-171 Rev. 3)
• Make it role-based: CUI users, admins, developers, and executives need different emphasis and scenarios. (NIST SP 800-171 Rev. 3)

For federal contractors and any nonfederal organization operating systems that handle Controlled Unclassified Information (CUI), training is a control that assessors test like any other: scope, design, operation, and evidence. The 03.02.01: literacy training and awareness requirement is where many programs fail for a simple reason: teams deliver “annual security training,” but cannot show it was targeted to the actual CUI environment, assigned to the right people, delivered at the right time, and reinforced in day-to-day operations.

Your job as a Compliance Officer, CCO, or GRC lead is to translate a short requirement into a repeatable operational system. That system needs ownership, defined audiences, required modules, delivery and tracking mechanics, and a lightweight way to update content when your environment changes (new CUI flows, new tooling, new threats, a security incident). The goal is assessable readiness: you can show who was trained, what they were trained on, and that training aligns to responsibilities for protecting CUI. (NIST SP 800-171 Rev. 3)

This page gives requirement-level implementation guidance you can put into motion immediately, with the evidence list and audit questions you should prepare for.

Regulatory text

Requirement: “NIST SP 800-171 Rev. 3 requirement 03.02.01 (Literacy Training and Awareness).” (NIST SP 800-171 Rev. 3)

Operator interpretation: You must implement security literacy training and awareness for personnel with responsibilities for, or access that can impact, the confidentiality of CUI and the supporting systems. An assessor will expect you to show: (1) a defined training requirement, (2) delivery to the correct population, and (3) evidence that it happens as a normal operating practice, not a one-time project. (NIST SP 800-171 Rev. 3)

Plain-English interpretation (what 03.02.01 requires)

03.02.01: literacy training and awareness requirement expects your workforce to know how to operate safely in a CUI environment. That includes recognizing likely attack paths (phishing, credential theft, mis-sending CUI), following your handling rules (marking, storage, transmission), and escalating issues quickly (reporting suspected incidents, lost devices, or accidental disclosures). (NIST SP 800-171 Rev. 3)

A practical way to read the requirement:

• “Literacy” = baseline security competence, not just policy acknowledgement.
• “Training and awareness” = structured learning plus reinforcement (job aids, reminders, manager cues, tooling prompts) so the behavior shows up in daily work. (NIST SP 800-171 Rev. 3)

Who it applies to (entity + operational context)

Applies to organizations implementing NIST SP 800-171 for protection of CUI in nonfederal systems. Typical contexts:

• Federal contractors/subcontractors with CUI in email, collaboration tools, ticketing systems, engineering repositories, ERP, or shared drives. (NIST SP 800-171 Rev. 3)
• Managed service providers and IT providers supporting a contractor’s CUI environment, if their staff administer or can access the systems where CUI is stored/processed/transmitted. (NIST SP 800-171 Rev. 3)

In scope people (build your roster from access and duties):

• Any user who creates, receives, stores, transmits, or processes CUI.
• System administrators, helpdesk, security engineers, IAM admins with privileged access to CUI systems.
• Developers/DevOps if they deploy or maintain applications that handle CUI or touch production data.
• Managers who approve access, oversee CUI projects, or handle incident escalation paths.
• Third-party personnel with logical access to the CUI environment (contractors/temps). (NIST SP 800-171 Rev. 3)

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

1) Name an owner and define the training control boundary

Assign a control owner (often Security Awareness lead, HR + Security, or GRC). Document:

• Which business units and systems are “CUI environment” for training scope.
• Which user populations are in scope, based on access and job role. (NIST SP 800-171 Rev. 3)

Output: a short “03.02.01 Training Scope Statement” you can hand to an assessor.

2) Define training objectives tied to your CUI risks and procedures

Write objectives that match how your organization handles CUI. Minimum coverage usually includes:

• CUI definition in your context and how employees identify it.
• Handling rules: storage locations, approved collaboration tools, encryption expectations, printing, and disposal.
• Phishing and social engineering reporting.
• Password/MFA basics and device hygiene for CUI access.
• Incident reporting path and “what to do first” steps for suspected exposure. (NIST SP 800-171 Rev. 3)

Keep a mapping table from objectives to your internal policies/standards and the CUI system boundary documents.

3) Build role-based training assignments

Create training “tracks” so the content matches the work. Example tracks:

• General CUI user track: recognizing CUI, permitted storage, sending rules, reporting.
• Privileged/admin track: secure administration, account lifecycle, logging expectations, remote admin hygiene.
• Developer/engineering track: secure code and change hygiene for CUI apps, secrets handling, test data rules.
• Executives/managers track: approving access, supervising exception handling, incident escalation, communicating in an event. (NIST SP 800-171 Rev. 3)

Mechanically, implement this with groups in your LMS, IdP groups, HRIS attributes, or a GRC assignment matrix.

4) Set delivery triggers and frequency rules you can defend

Define when training is required:

• New hire onboarding before or immediately upon being granted access to CUI systems.
• Retraining on a periodic basis.
• Targeted retraining after major changes (new CUI repository, new email protection rules), or after relevant incidents. (NIST SP 800-171 Rev. 3)

Avoid overpromising specific intervals you can’t meet. Write the rule in policy, then configure systems to enforce it.

5) Deliver training with controlled content management

Choose formats you can run reliably:

• LMS modules with quizzes and completion tracking.
• Live instructor sessions for high-risk teams, with attendance capture.
• Micro-learning reminders (posters, internal posts, short videos) as reinforcement.

Control the content like a compliance artifact:

• Version the training deck/module.
• Record approval and publication date.
• Keep the retired version archive for audit lookback. (NIST SP 800-171 Rev. 3)

6) Track completion, exceptions, and enforcement actions

Operationalize a simple workflow:

• Weekly or biweekly completion reports to managers.
• A documented exception process (LOA, contractor offboarding, role change, or system access removed).
• Escalation steps for overdue completion aligned to HR policy (reminders, access suspension, manager escalation). (NIST SP 800-171 Rev. 3)

7) Test effectiveness and continuously tune

Assessors often ask whether training is “effective.” You can show effectiveness without complex metrics:

• Quiz results and remediation for low scores.
• Phishing simulations (if you run them) tied to retraining actions.
• Evidence that incident trends or near-misses triggered content updates. (NIST SP 800-171 Rev. 3)

8) Integrate third-party personnel into the same control

If third parties have access to CUI systems, decide:

• Require your training (preferred when access is substantial or privileged), or
• Accept equivalent training with documented review and confirmation.

Document the rule in third-party onboarding and access request workflows. (NIST SP 800-171 Rev. 3)

Where Daydream fits naturally: Many teams struggle to keep training evidence, role mappings, and recurring collection audit-ready. Daydream can be used to map 03.02.01 to your policy, control implementation, and recurring evidence collection, so you can pull the same artifacts every cycle without rebuilding the package. (NIST SP 800-171 Rev. 3)

Required evidence and artifacts to retain

Use this as your assessor-ready evidence checklist:

• Policy/standard defining security literacy training requirements and applicability. (NIST SP 800-171 Rev. 3)
• Training plan with role-based curriculum outline and learning objectives. (NIST SP 800-171 Rev. 3)
• Population definition: roster logic (HR list + system access list) and the in-scope user list for the CUI boundary. (NIST SP 800-171 Rev. 3)
• Training content: modules/decks, version history, and approval records. (NIST SP 800-171 Rev. 3)
• Completion records: LMS exports, attendance sheets for live sessions, quiz attestations, and timestamps. (NIST SP 800-171 Rev. 3)
• Exception log: deferred training, waivers (if any), and compensating steps (access removal, alternate training). (NIST SP 800-171 Rev. 3)
• Effectiveness artifacts: quiz outcomes, targeted follow-ups, and change log of content updates tied to incidents or environment changes. (NIST SP 800-171 Rev. 3)

Common exam/audit questions and hangups

Assessors commonly probe:

• “Show me your in-scope population. How do you know you didn’t miss admins or contractors?” (NIST SP 800-171 Rev. 3)
• “Is training completed before access to the CUI environment is granted?” (NIST SP 800-171 Rev. 3)
• “How is content tailored to CUI handling, not general security awareness?” (NIST SP 800-171 Rev. 3)
• “What happens when training is overdue? Who escalates it?” (NIST SP 800-171 Rev. 3)
• “How do you update training when tools/processes change?” (NIST SP 800-171 Rev. 3)

Hangups that slow assessments:

• Training exists, but there’s no defensible roster method.
• Completion data is partial because teams use multiple platforms and can’t reconcile identity.
• Contractors trained “by their employer” with no documentation review. (NIST SP 800-171 Rev. 3)

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails	Fix
One generic annual module for everyone	Doesn’t show role relevance or CUI context	Create tracks and map each to responsibilities and access types. (NIST SP 800-171 Rev. 3)
Roster built only from HR	Misses admins, shared accounts, third-party users	Build the roster from HR + IdP + key CUI systems access lists. (NIST SP 800-171 Rev. 3)
No version control on training content	You can’t prove what was taught during the audit period	Store versions and approval records; archive prior versions. (NIST SP 800-171 Rev. 3)
Exceptions handled informally	Creates gaps assessors treat as control failures	Maintain an exception log with reason, duration, and compensating action. (NIST SP 800-171 Rev. 3)
Completion is tracked, but not enforced	Overdue training becomes “normal”	Tie overdue status to manager escalation and access governance. (NIST SP 800-171 Rev. 3)

Enforcement context and risk implications

No public enforcement cases are provided in the source catalog for this requirement. Practically, the risk is operational: weak training increases the likelihood of mishandling CUI (misdelivery, improper storage, delayed incident reporting) and creates an assessment finding because the control is easy to test through evidence sampling. (NIST SP 800-171 Rev. 3)

Practical execution plan (30/60/90)

Use phases rather than dated promises, and align them to evidence readiness.

First 30 days (stabilize scope + minimum viable control)

• Define CUI environment training scope and in-scope population logic. (NIST SP 800-171 Rev. 3)
• Publish or update the training policy section that covers 03.02.01 requirements. (NIST SP 800-171 Rev. 3)
• Select delivery mechanism(s) and confirm you can export completion logs. (NIST SP 800-171 Rev. 3)
• Launch a baseline CUI user module and a privileged/admin module, even if short. (NIST SP 800-171 Rev. 3)

By 60 days (make it repeatable and auditable)

• Implement role-based assignment rules using HR attributes and access groups. (NIST SP 800-171 Rev. 3)
• Build the evidence package: content versions, approvals, and roster snapshots. (NIST SP 800-171 Rev. 3)
• Create an exception workflow and a manager escalation path for overdue training. (NIST SP 800-171 Rev. 3)
• Add a targeted developer/engineering module if they touch CUI applications. (NIST SP 800-171 Rev. 3)

By 90 days (prove effectiveness + operational integration)

• Run an internal audit-style sample: pick a set of users, validate role assignment, completion, and evidence integrity end-to-end. (NIST SP 800-171 Rev. 3)
• Add reinforcement: job aids for CUI labeling/sending, reporting instructions, and a short refresher for common failure modes. (NIST SP 800-171 Rev. 3)
• Establish a change trigger: training updates required when CUI tools, repositories, or procedures change. (NIST SP 800-171 Rev. 3)
• Set recurring evidence collection so you can respond to assessments quickly; Daydream can automate mapping 03.02.01 to artifacts and collection cycles. (NIST SP 800-171 Rev. 3)

Frequently Asked Questions

Who exactly needs to take training for 03.02.01?

Anyone who handles CUI or can affect the security of the systems that store/process/transmit it, including admins and third-party personnel with access. Define this population using HR role data plus access lists from your IdP and key CUI systems. (NIST SP 800-171 Rev. 3)

Does “annual security awareness training” satisfy the 03.02.01: literacy training and awareness requirement?

Only if it clearly covers your CUI-specific handling rules and is assigned to the right roles with retained evidence. Generic training without CUI procedures and role relevance is a common assessment weakness. (NIST SP 800-171 Rev. 3)

What evidence is the fastest way to pass an assessor sampling test?

Provide the training policy requirement, the roster method, the training content version taught, and the completion report showing dates and user identities. Add your exception log if any users were deferred. (NIST SP 800-171 Rev. 3)

How do we handle contractors or other third parties who access our CUI systems?

Require them to complete your training or collect proof of equivalent training and document your review and approval. Tie the requirement to onboarding and access provisioning so it can’t be skipped. (NIST SP 800-171 Rev. 3)

What makes training “effective” for audit purposes?

Show that you test understanding (quizzes, knowledge checks) and that you update training based on real issues such as incidents, near-misses, or tool/process changes. Keep the change log and the updated module version history. (NIST SP 800-171 Rev. 3)

We have multiple business units; can we decentralize training?

Yes, but keep centralized minimum requirements: common learning objectives, evidence standards, and a single view of completion. Decentralization fails when units cannot produce consistent artifacts on request. (NIST SP 800-171 Rev. 3)