03.04.03: Configuration Change Control

03.04.03: configuration change control requirement means you must control, review, approve, and document changes to system configurations that can affect the protection of CUI, and you must be able to prove it on demand. Operationalize it by defining what “configuration” covers, routing changes through a standardized workflow, and retaining end-to-end evidence from request through validation. ¹

Key takeaways:

• Treat configuration change control as a governed workflow: request, risk review, approval, implementation, validation, and closure.
• Scope matters: define which assets, baselines, and settings are “configuration” for CUI-handling systems and environments.
• Evidence is the exam: tickets, approvals, test/validation results, and updated baselines must reconcile to what actually changed.

A lot of programs claim “we do change management” and still fail 03.04.03 because their process is informal, inconsistently used, or disconnected from CUI-scoped systems. Assessors tend to look for two things: (1) a clear, written expectation that configuration changes are controlled, and (2) proof the expectation is followed for the systems that store, process, or transmit CUI. ¹

For a Compliance Officer, CCO, or GRC lead, the fastest path is to translate “configuration change control” into an auditable operating rhythm: define configuration items and baselines, establish a single workflow for changes (normal, emergency, standard/pre-approved), require risk-based review, and retain artifacts that show approvals and validation happened before the change was considered complete. Done well, this requirement reduces the most common causes of preventable security incidents in regulated environments: undocumented changes, unauthorized changes, and changes that bypass testing and break security settings.

This page gives requirement-level implementation guidance you can hand to IT, security, and engineering and then audit internally with minimal ambiguity, aligned to NIST SP 800-171 Rev. 3. ¹

Regulatory text

Requirement excerpt (as provided): “NIST SP 800-171 Rev. 3 requirement 03.04.03 (Configuration Change Control).” ¹

Operator interpretation: You need a controlled process for changes to configuration settings and configuration items in the environment where CUI is handled. “Controlled” means changes are requested, reviewed for risk/impact, approved by the right authority, implemented by authorized personnel, validated, and recorded so you can reconstruct what changed, when, by whom, and why. ¹

Plain-English interpretation (what this really requires)

03.04.03: configuration change control requirement expects you to prevent “random config drift” and “silent changes.” If someone modifies firewall rules, identity settings, endpoint policies, server hardening, SaaS security settings, or cloud security groups that affect CUI systems, that change must go through your change control workflow and leave a trail. ¹

Your policy can be short. The control fails when the workflow is optional, approvals are unclear, emergency changes never get backfilled, or evidence is scattered across tools with no reconciliation.

Who it applies to

Entity types

• Federal contractors and subcontractors.
• Any nonfederal organization operating systems that handle Controlled Unclassified Information (CUI). ¹

Operational context (where it applies)

• Production environments that store, process, or transmit CUI (on-prem, cloud, hybrid).
• Security tooling and shared services that enforce controls for CUI environments (identity provider, MDM/EDR, SIEM configurations, vulnerability scanning configurations, backups, key management).
• Third-party managed services that administer your CUI environment (managed SOC, MSP, cloud admin, application hosting). Your third party can execute changes, but you still need governance and evidence. ¹

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

Use this as a build sheet for IT and Security Ops.

1) Define scope: what counts as “configuration”

Create a Configuration Items (CI) scope statement for the CUI boundary:

• Systems: servers, endpoints, network devices, cloud accounts/subscriptions/projects, SaaS tenants used for CUI.
• Security configuration domains: identity and access policies, logging/audit settings, encryption settings, network segmentation rules, endpoint hardening, patch/update settings, backup policies.
• Baselines: what “approved” looks like (gold images, secure configuration standards, cloud policy sets). ¹

Deliverable: a short “CUI Configuration Scope” document, or a CMDB export plus annotations.

2) Establish a single change control workflow (and make it the default)

Implement a workflow in your ticketing/change tool (or a tightly controlled alternative) with required fields:

• CI/asset affected (must map to CUI scope or explicitly mark “out of scope”)
• Change description and reason
• Security impact assessment (simple yes/no with notes is acceptable if consistent)
• Testing/validation plan
• Implementation plan + rollback plan
• Approver(s) and approval timestamp
• Evidence attachments (screenshots, diffs, reports, commands output, pipeline logs) ¹

Classify changes

• Standard (pre-approved) changes: low risk, repeatable (example: monthly endpoint policy update that follows a script).
• Normal changes: reviewed and approved before implementation.
• Emergency changes: allowed with expedited approval, but must be reviewed and documented promptly after restoration of service. ¹

3) Set approval authority and separation of duties

Document who can approve what:

• Business/system owner approves impact to service.
• Security approves impact to CUI protection controls.
• Change manager (or delegated role) confirms completeness of the record.

Avoid “the implementer approves their own changes” for high-impact security configurations. Where your team is small, require a second-person review or a manager approval and record it in the ticket. ¹

4) Require validation before closure

Define minimum validation expectations per change type:

• Security settings changes: confirm intended policy is active (for example, confirm MFA policy is enforced, confirm logging is enabled, confirm firewall rule deployed).
• Infrastructure changes: confirm monitoring, logging, and backups still function.
• Application changes touching CUI: confirm access controls and audit logs still capture required events.

Attach the validation evidence to the change record and make “validation completed” a required closure step. ¹

5) Detect and reconcile “out-of-band” changes

Change control is not credible without drift detection. Implement at least one reconciliation mechanism:

• Regular configuration compliance scans against baselines.
• Cloud configuration monitoring (policy findings tied back to change tickets).
• Admin activity logging review (who changed what in SaaS/cloud). ¹

Process requirement: when you find an untracked change, create a backfilled ticket, document why it bypassed the process, and record corrective action.

6) Tie third parties into your change control

For third parties with admin access:

• Contractually require change records and approvals for CUI-scoped changes.
• Require notification and evidence delivery (ticket export, change summary, validation proof).
• Periodically sample third-party changes and verify they match your internal approvals. ¹

7) Make it assessable: map the requirement to policy, control, and recurring evidence

Your GRC system should show a clean line from requirement → policy statement → operational procedure → evidence cadence. This is where Daydream fits naturally: it helps you map 03.04.03 to an owned control and run recurring evidence collection so audits don’t turn into screenshot hunts. ¹

Required evidence and artifacts to retain

Retain artifacts that let an assessor reconstruct the full change lifecycle for a sample set of changes.

Minimum evidence set (keep in one place or linked):

• Configuration change control policy/procedure for CUI-scoped systems. ¹
• Defined scope of CUI systems and configuration items (inventory/CMDB extract + boundary notes). ¹
• Change records (tickets) showing:
  • requestor, implementer, approver(s)
  • impact/risk notes
  • implementation and rollback plan
  • timestamps (requested, approved, implemented, validated, closed)
  • validation evidence attachments (test results, logs, config diffs) ¹
• Emergency change records with documented post-implementation review. ¹
• Baselines/standards used (secure configuration standards, gold images, cloud policies) and proof they are updated when changes are approved. ¹
• Drift detection outputs and reconciliation tickets for out-of-band changes. ¹

Common exam/audit questions and hangups

Expect these lines of questioning for 03.04.03: configuration change control requirement:

1. “Show me your change control process for the CUI boundary.” They will test whether your documented process matches real practice. ¹
2. “Give me a sample of recent configuration changes that affected security controls.” They will look for approvals and validation, not just a ticket title. ¹
3. “How do you handle emergency changes?” A common hangup is emergency changes that never get documented after the fact. ¹
4. “How do you know changes aren’t happening outside the process?” If you have no drift detection or log review, your control looks paper-only. ¹
5. “What about cloud/SaaS configuration changes?” Teams often apply change control to servers but ignore SaaS admin consoles and cloud policies. ¹

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails	Fix
Change control exists, but engineers bypass it for “small changes”	“Small” changes can disable logging, weaken access controls, or open networks	Define “configuration” broadly for CUI scope and require tickets for any security-relevant change 1
Tickets lack validation evidence	Assessors treat “implemented” as incomplete	Make validation an explicit workflow step with required attachments 1
Emergency changes never get reviewed	Creates permanent blind spots	Add a required post-change review step and track exceptions 1
No linkage between baseline and change	Baseline becomes stale; config drift grows	Require baseline update or attestation in the ticket closure criteria 1
Third party admins change settings without your approvals	You lose control of CUI protections	Contract for change evidence and integrate third-party changes into your workflow 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 or penalties.

Operationally, weak configuration change control creates predictable risk:

• Unauthorized changes can weaken access controls or logging in CUI environments.
• Unreviewed changes can break required security functions or create exposure that persists until discovered.
• In an assessment, inability to produce change records and validation evidence is commonly treated as control failure because it prevents objective verification. ¹

Practical execution plan (30/60/90)

You asked for speed. Use this phased plan as a checklist, then track it as control maturity.

First 30 days (stabilize and make it mandatory)

• Define CUI configuration scope: systems, SaaS tenants, cloud accounts, and security tooling in scope. ¹
• Publish a short configuration change control procedure with roles and required ticket fields. ¹
• Configure the change workflow in your ticketing tool; make required fields non-optional for in-scope changes. ¹
• Start collecting evidence immediately: select a small set of recent changes and make sure each has approval + validation attachments. ¹

Next 60 days (make it testable and cover cloud/SaaS)

• Establish standard change templates for repeatable changes (patching, endpoint policy updates, certificate rotations).
• Implement emergency change backfill and post-review; track exceptions.
• Add at least one drift detection or admin activity review process for out-of-band change discovery. ¹
• Integrate third-party change reporting requirements for any third party with admin access. ¹

By 90 days (operational maturity and assessment readiness)

• Perform an internal mini-assessment: sample change tickets from different teams and verify they meet the evidence standard.
• Reconcile baselines to reality: confirm documented baselines match current enforced configurations for key security domains. ¹
• Implement recurring evidence collection and control mapping in your GRC workflow so you can answer assessor requests quickly; Daydream can reduce manual evidence chasing by structuring the mapping and collection cycle around 03.04.03. ¹

Frequently Asked Questions

What counts as a “configuration change” for 03.04.03?

Treat any change to settings that affect security posture or system behavior in the CUI boundary as in scope, including cloud/SaaS admin settings. Document your scope so teams don’t decide case-by-case. ¹

Do we need a formal Change Advisory Board (CAB)?

NIST SP 800-171 Rev. 3 does not require a CAB by name. You do need defined approval authority and consistent evidence that approvals and validation occurred for in-scope changes. ¹

How should we handle emergency changes without failing the control?

Allow expedited implementation to restore service, then require a documented post-change review and attach the same evidence you would for a normal change. Track emergency changes so they don’t become the default path. ¹

Our engineers use CI/CD and Infrastructure as Code. Does that satisfy change control?

It can, if you can show review/approval (for example, pull request approvals), a controlled deployment process, and validation evidence tied to each change. Preserve logs and approvals so an assessor can trace a change from request to deployment. ¹

What evidence is “enough” for an assessor?

Aim for end-to-end traceability: who requested it, who approved it, what changed, when it was implemented, and how you validated the outcome. Missing validation and unclear approvals are the most common gaps. ¹

How do we manage third-party administrators in our CUI environment?

Treat third-party changes as first-class changes: require tickets, approvals, and validation artifacts, and make them contractually obligated to provide change records. Periodically sample third-party changes to confirm they match your approvals. ¹

Footnotes

1. NIST SP 800-171 Rev. 3