03.07.05: Nonlocal Maintenance

To meet the 03.07.05: nonlocal maintenance requirement, you must control and monitor any maintenance performed on your systems from offsite locations, so remote technicians cannot gain unmanaged access to CUI environments. Put a repeatable workflow in place for approving, securing, supervising, logging, and closing out each nonlocal maintenance session, including third-party access. ¹

Key takeaways:

• Treat nonlocal maintenance as a high-risk remote access event: pre-approve it, tightly scope it, and log it end-to-end.
• Require secure session controls (strong authentication, encrypted channels, least privilege, time bounds) and retain evidence.
• Build an assessor-ready package: policy + procedure + tickets + access logs + session records + closure review. ¹

Nonlocal maintenance is one of those requirements that looks narrow but touches many operational seams: IT operations, vendor management, identity, logging, and incident response. If a manufacturer, managed service provider, internal admin, or field technician can “reach in” remotely to run diagnostics, patch firmware, or troubleshoot, that pathway can become a quiet backdoor into CUI systems if you don’t control it.

NIST SP 800-171 Rev. 3 organizes this as a specific requirement: 03.07.05: Nonlocal Maintenance. Your goal is straightforward: remote maintenance must not bypass the controls you rely on to protect CUI. That means you need a defined method to authorize the activity, secure the connection, constrain what the maintainer can do, capture logs that prove what happened, and confirm the session ended cleanly.

This page is written for a Compliance Officer, CCO, or GRC lead who has to operationalize the 03.07.05: nonlocal maintenance requirement quickly. You’ll get a practical implementation pattern, evidence to retain, common audit friction points, and an execution plan you can hand to IT and third-party owners. ¹

Regulatory text

Excerpt (as provided): “NIST SP 800-171 Rev. 3 requirement 03.07.05 (Nonlocal Maintenance).” ¹

Operator interpretation: You must establish controlled conditions for any maintenance performed from a nonlocal (remote/offsite) location. In practice, an assessor will expect you to (1) define what counts as nonlocal maintenance in your environment, (2) require authorization and secure remote access methods, (3) monitor and log the maintenance activity, and (4) retain records that show the maintenance was performed under your rules. ¹

Plain-English interpretation (what the requirement “means” day-to-day)

Nonlocal maintenance is any repair, update, diagnostics, or administrative work performed on systems without the technician being physically present with the device or system. The risk is that remote maintenance tools and privileges can bypass normal user access boundaries.

A compliant operating state looks like this:

• You know who is connecting, why, and what they are allowed to do.
• Remote maintenance happens only through approved pathways (your VPN, bastion host, privileged access tooling, or tightly controlled vendor portal).
• You capture enough telemetry to reconstruct the session if needed: tickets, approvals, session logs, and outcomes.
• You close the loop: access is removed or expires, and the work is validated.

Who it applies to

Entity scope

• Organizations implementing NIST SP 800-171 Rev. 3 for nonfederal systems handling CUI, including federal contractors and their in-scope environments. ¹

Operational scope (where this shows up)

• Remote support from a hardware manufacturer (routers, firewalls, storage arrays).
• MSP / MSSP remote administration for servers, endpoints, and network devices.
• Internal IT administrators performing after-hours remote repairs.
• OT/IoT and building systems with remote vendor diagnostics (if in scope for your CUI boundary).
• Emergency troubleshooting where speed pressures teams to “just let the vendor in.”

Third-party scope This requirement often fails at the boundary between security and procurement: the remote maintainer is frequently a third party. Your third-party risk management program should force the access pattern to conform to your control set, not the third party’s defaults. ¹

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

Use this implementation sequence as your minimum viable, assessor-ready workflow.

1) Define “nonlocal maintenance” and inventory the pathways

Create and maintain a list of:

• Systems in your CUI boundary that require maintenance (servers, network gear, endpoints, hypervisors, security tools).
• Approved remote maintenance methods (VPN + admin jump host, PAM tool, remote support application).
• Disallowed methods (direct inbound RDP from the internet, persistent vendor accounts, shared credentials, “temporary” firewall pinholes without tickets).

Deliverable: “Nonlocal Maintenance Access Matrix” mapping system categories to allowed tools and owners.

2) Put a gate in front of every maintenance session (request → approve → schedule)

Require a ticket (ITSM or equivalent) for each remote maintenance event, including:

• Requestor, business reason, impacted assets, planned actions.
• Whether a third party is involved and their named technicians.
• Start/end window, rollback plan, and validation steps.

Approval rule: Approval must come from an authorized system owner (and security for high-impact assets).

3) Enforce secure connection and strong identity (no shared maintainer access)

Operational expectations assessors commonly look for:

• Unique accounts for maintainers (named individuals, not “VendorAdmin”).
• Strong authentication for privileged remote access (for example, MFA where feasible).
• Encrypted remote sessions.
• Least privilege: maintainer access scoped to the specific system and function needed.
• Time-bounded access: access expires after the maintenance window.

Practical pattern: Route all remote maintenance through a controlled “choke point” (bastion host or PAM). If you cannot, document compensating controls and prove logs are still complete.

4) Supervise and monitor the session (technical + procedural)

Your monitoring should answer: “What did the maintainer do?”

• Capture session logs from remote tools (connection start/stop, commands where supported, files transferred where supported).
• Ensure system logs are enabled on the target assets (auth logs, admin actions, configuration changes).
• For high-risk sessions, require live supervision (an employee on the bridge) and document attendance in the ticket.

5) Closeout: validate changes, remove access, and retain evidence

After the session:

• Confirm work performed matches the approved scope.
• Validate the system is functioning and within baseline configuration expectations.
• Confirm access was removed or expired.
• Attach key evidence to the ticket and store it per retention practices.

Closeout checklist: “ticket updated,” “logs collected,” “access terminated,” “post-maintenance validation performed,” “issues escalated if anomalies found.”

6) Extend the workflow to third parties via contract and onboarding

For any third party that may perform nonlocal maintenance:

• Contractually require your remote access method (or equivalent security controls).
• Require named technicians and notification expectations.
• Ensure your security team can obtain logs and session records on request.

Daydream fit (earned mention): Many teams lose evidence across ITSM, IAM, VPN, and vendor emails. Daydream can act as the system-of-record that maps 03.07.05 to the control, owners, and recurring evidence requests, then tracks whether each maintenance event has the required artifacts attached before you enter an assessment cycle. ¹

Required evidence and artifacts to retain

Assessors will ask you to prove both design (rules exist) and operating effectiveness (rules were followed). Keep:

Policy and procedure

• Nonlocal maintenance policy / standard (scope, approvals, allowed tools, logging, retention).
• Step-by-step procedure (request/approve/connect/monitor/closeout).
• Role definitions (system owner, security approver, IT operations executor).

Technical configuration evidence

• Screenshots or exports showing remote access control settings (VPN, PAM, bastion host configs).
• MFA/SSO enforcement evidence for privileged remote access (where applicable).
• Logging configuration for remote access tools and target systems.

Per-event operational evidence (sampled by auditors)

• Maintenance tickets with approvals, scope, and timestamps.
• Named technician identity and access grant records.
• Remote session logs (start/stop, activity metadata).
• Target system logs showing admin actions during the window.
• Post-maintenance validation notes and closeout confirmation.

Common exam/audit questions and hangups

Expect these lines of questioning:

• “Show me the last few nonlocal maintenance events for in-scope systems and the associated approvals and logs.”
• “How do you prevent a third party from keeping persistent access after maintenance?”
• “What remote tools are approved, and how do you detect someone using an unapproved tool?”
• “How do you ensure activity is attributable to an individual, not a shared account?”
• “Where are session logs stored, and who reviews them?”

Hangup to anticipate: Teams have a policy but no repeatable evidence package. The assessor experience becomes a scavenger hunt across email threads and ad hoc screenshots.

Frequent implementation mistakes (and how to avoid them)

1. Allowing “temporary” vendor accounts to become permanent
   Fix: enforce time-bound access and a closure control that checks access removal.

2. Logging exists, but you can’t correlate it to the ticket
   Fix: require ticket IDs in VPN/PAM session metadata or record the session identifier in the ticket.

3. Unapproved remote tools on endpoints
   Fix: application allowlisting (where feasible) and endpoint monitoring for remote admin software; document exceptions.

4. No definition of what qualifies as maintenance vs. normal admin work
   Fix: define nonlocal maintenance events as privileged remote activity on in-scope assets that changes configuration, patches, firmware, or diagnostics.

5. Third party says they can’t provide logs
   Fix: bake log access and cooperation into contract terms and onboarding requirements.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this specific requirement. The practical risk is still concrete: nonlocal maintenance is a common initial access path because it combines privileged access, external parties, and time pressure. A weak process can create unauthorized access to CUI, incomplete audit trails, and assessment findings that cascade into broader control failures. ¹

Practical execution plan (30/60/90)

Use this as an operator’s plan. Treat the phases as sequencing, not promises about elapsed time.

First 30 days (stabilize and stop the bleeding)

• Identify all tools and pathways used for remote maintenance (including shadow methods).
• Publish an interim rule: “No nonlocal maintenance on in-scope systems without a ticket and approval.”
• Pick the standard pathway (VPN + jump host, or PAM) and block obvious unsafe inbound access where feasible.
• Start collecting per-event evidence for every session, even if it’s manual.

Days 31–60 (standardize and instrument)

• Finalize the nonlocal maintenance procedure and embed it into ITSM workflows (required fields, approvers, closure checklist).
• Implement individual identities for maintainers and remove shared accounts.
• Turn on and centralize logging for remote access and target systems; test log retrieval for an audit sample.
• Update third-party onboarding: named technicians, access method, notification, log availability.

Days 61–90 (prove operating effectiveness)

• Run an internal audit-style sample: pick recent maintenance events and confirm every artifact exists.
• Train IT operations and vendor managers on the workflow, with escalation paths for emergencies.
• Add continuous checks: periodic review for stale vendor accounts, remote tool drift, and missing ticket attachments.
• Use Daydream (or your GRC system) to map 03.07.05 to owners, evidence tasks, and a recurring collection cadence so assessment prep is routine. ¹

Frequently Asked Questions

Does 03.07.05 apply to internal IT staff doing remote admin work, or only third parties?

It applies to nonlocal maintenance regardless of who performs it. Treat internal admins the same way: approved method, least privilege, logging, and closeout evidence. ¹

What counts as “maintenance” versus normal remote access?

Draw the line at privileged activities that diagnose, repair, patch, update firmware, or change configuration on in-scope systems. Document your definition and apply it consistently in ticketing and logging. ¹

Can we allow vendor remote access directly to a device if they insist?

Prefer a controlled entry point you manage (VPN/jump host/PAM). If you must allow an exception, document why, add compensating controls, and retain stronger session evidence for those events. ¹

What evidence is usually easiest to produce during an assessment?

A closed maintenance ticket with approvals, the remote session record, and target system logs for the same window. Build your workflow so those artifacts are attached before the ticket can be closed. ¹

How do we handle emergency maintenance outside normal approvals?

Use an emergency change path that still requires documentation, a rapid approver, and after-the-fact review. The key is that “emergency” does not mean “no logs” or “no accountability.” ¹

We have logs, but nobody reviews them. Is that a problem for 03.07.05?

The requirement focus is controlled nonlocal maintenance; an assessor will still test whether logs are adequate and retrievable. Add a lightweight review step for high-risk sessions and document the review in the ticket. ¹

Footnotes

1. NIST SP 800-171 Rev. 3