03.10.01: ad

To operationalize the 03.10.01: ad requirement, you need a documented control that maps this NIST SP 800-171 Rev. 3 requirement to your policies, technical implementation, and recurring evidence collection, then prove it works through repeatable artifacts in your CUI environment. Treat it as an assessment-readiness requirement: define ownership, implement, collect evidence, and keep it current. ¹

Key takeaways:

• The fastest path is a control-to-evidence map that ties 03.10.01 to systems handling CUI, owners, and proof.
• Auditors care less about intent and more about repeatable evidence tied to scope and frequency.
• “Implemented” without artifacts is a common failure mode; run 03.10.01 as a recurring compliance operation, not a one-time project.

03.10.01 is presented in your source material only as “NIST SP 800-171 Rev. 3 requirement 03.10.01 (ad)” without the specific control statement text. That creates a practical problem for a CCO or GRC lead: you still need to stand up a defensible, testable program position for 03.10.01 even when internal trackers (or tooling exports) don’t include the full requirement wording.

This page solves that operationally. You’ll build a requirement-level implementation package that (1) anchors to NIST SP 800-171 Rev. 3 as the authoritative source, (2) documents scope (which systems, users, and third parties touch CUI), (3) maps 03.10.01 to a concrete control design, and (4) produces evidence on a cadence you can sustain.

If you use Daydream in your compliance workflow, the practical win is consistency: one requirement record becomes the hub for policy references, implementation notes, and evidence requests so 03.10.01 doesn’t degrade over time when staff, systems, and vendors change.

Regulatory text

Provided excerpt: “NIST SP 800-171 Rev. 3 requirement 03.10.01 (ad).” ¹

Operator interpretation (what you must do): Because the excerpt you provided does not include the underlying requirement statement, your operational obligation is to (a) retrieve and maintain the authoritative requirement text from NIST SP 800-171 Rev. 3, and (b) maintain a documented, implemented, and evidenced control that satisfies 03.10.01 within the boundary of your nonfederal system(s) that process, store, or transmit CUI. ¹

Minimum “assessment-ready” expectation: An assessor should be able to open one record for the 03.10.01: ad requirement and see: scope, responsible owner, how the control is implemented in your environment, and current evidence that the control operates as described. ¹

Plain-English interpretation of the 03.10.01: ad requirement

Treat 03.10.01 as a requirement you must translate into your environment. That translation has four deliverables:

1. Authoritative text on file (so there’s no ambiguity about what “03.10.01” requires). ¹
2. A control statement in your own words that explains how you meet it for CUI systems.
3. Implementation proof (configurations, workflows, tickets, screenshots, reports, etc.).
4. Ongoing evidence that shows the control still works after changes.

If you can’t show these four items quickly, the risk is not only nonconformance. It’s also failed governance: you won’t be able to prove that your CUI protection program remains effective as your technology stack and third parties evolve. ¹

Who it applies to

Entity types

• Federal contractors and other nonfederal organizations handling CUI in nonfederal systems. ¹

Operational context

• Any business unit, program, enclave, or shared service where CUI is processed, stored, or transmitted.
• Any enabling function that impacts those systems (identity, endpoint management, SOC operations, networking, application teams, and GRC).
• Third parties that can access your CUI environment or operate components in scope (managed service providers, SaaS admins, hosting providers, incident response retainers).

Practical scoping test

• If a system is inside your CUI boundary, 03.10.01 applies to it.
• If a third party administers that system or can access it, 03.10.01 also becomes a third-party due diligence and contract-flowdown concern, because you need evidence that your control still operates with them in the loop.

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

The goal is to operationalize 03.10.01 even when the requirement label is all you have in your tracker.

1) Pull the authoritative requirement statement and lock it

• Retrieve the exact 03.10.01 statement from the NIST SP 800-171 Rev. 3 publication and store it in your control library. ¹
• Record the source reference and version so you can show what you implemented against. ¹

Output: “03.10.01 requirement text” artifact in your GRC repository.

2) Write your control implementation statement (CIS) for 03.10.01

Create a short, testable control statement that answers:

• What you do to meet 03.10.01
• Where it applies (CUI boundary systems)
• Who owns operation and who reviews
• How you measure success (evidence sources)
• How changes are handled (change management trigger for re-validation)

Output: 03.10.01 Control Implementation Statement with named owners.

3) Map 03.10.01 to internal policies, standards, and procedures

Create a crosswalk that points to the exact documents and sections that govern the behavior:

• Information security policy
• System security plan (SSP) for the CUI boundary
• Standards (secure configuration, IAM, logging, vulnerability management, etc. as relevant to the actual 03.10.01 text)
• Operating procedures (runbooks, ticket workflows)

Output: Control-to-policy crosswalk entry.

4) Implement the control in systems (or verify it’s already implemented)

Work with system owners to connect the control statement to real implementations:

• Identify the systems of record that produce evidence (SIEM, EDR, IAM, CMDB, ticketing, MDM, vulnerability scanner, backup console, etc.).
• Confirm the control is enabled and correctly scoped to the CUI boundary.
• Document any compensating controls where the exact implementation differs, and ensure they are testable.

Output: Implementation notes + references to system configurations and admin consoles.

5) Establish recurring evidence collection

Define:

• Evidence types (reports, exports, screenshots, tickets)
• Evidence owner(s)
• Storage location and naming convention
• Review/approval step (second set of eyes)

Daydream fits here as the system of work: you can tie 03.10.01 directly to evidence requests and keep a clean timeline of what was collected, by whom, and when.

Output: Evidence plan and a populated evidence folder.

6) Test like an auditor would

Build a simple test script:

• What the assessor asks
• What you show
• Pass/fail criteria aligned to the requirement statement from NIST SP 800-171 Rev. 3 ¹

Output: Test procedure + last-run test results.

Required evidence and artifacts to retain

Keep artifacts that prove design, implementation, and operation:

Core artifacts

• Authoritative 03.10.01 requirement text excerpt saved internally ¹
• 03.10.01 control implementation statement (owner, scope, method, tools)
• Scope definition for CUI boundary (SSP extract or system list) ¹
• Control-to-policy crosswalk

Operational evidence (examples; pick what matches your actual 03.10.01 text)

• System configuration exports or screenshots showing the setting is enabled
• Access control lists / role assignments where relevant
• SIEM/EDR reports where relevant
• Ticket samples demonstrating the process runs in practice (approvals, exceptions, remediation)
• Change records showing re-validation after material changes

Third-party artifacts (if applicable)

• Contracts/SOW language requiring cooperation and evidence support for controls affecting CUI systems
• Third-party access lists and review approvals
• Attestations or service reports where they are your evidence source (store what you actually received)

Common exam/audit questions and hangups

What assessors ask

• “Show me the exact 03.10.01 requirement text you implemented.” ¹
• “Which systems are in scope for CUI, and how do you ensure the control applies to all of them?”
• “Who is responsible for operating and reviewing this control?”
• “Show evidence from the last operating cycle.”
• “What happens when there’s an exception, and who approves it?”

Common hangups

• Requirement text is missing from the control library, so teams argue about intent during the exam.
• Evidence is “somewhere in a tool” but not exported and retained with context.
• Scope drift: new systems or third parties touch CUI, but the control mapping isn’t updated.

Frequent implementation mistakes and how to avoid them

1. Tracking 03.10.01 as a checkbox.
   Fix: require a control statement plus evidence list before you mark it implemented.

2. No authoritative requirement text retained.
   Fix: store the 03.10.01 text excerpt from the NIST SP 800-171 Rev. 3 PDF in the control record. ¹

3. Evidence without scope.
   Fix: every artifact should indicate it covers the CUI boundary (system name, tenant, OU/group, tag, or report filter).

4. One-person process.
   Fix: assign an operator and a reviewer. Separation avoids silent failure.

5. Third-party blind spot.
   Fix: if a third party administers or hosts in-scope components, contractually require cooperation for evidence and validate their access paths.

Enforcement context and risk implications

No public enforcement cases were provided in your source catalog for this requirement, so this page does not list enforcement examples.

Operationally, the risk is still real: if you handle CUI, failing to produce credible evidence for a NIST SP 800-171 requirement creates assessment exposure and may delay contract eligibility, renewals, or customer approvals. Keep your posture defensible by treating evidence as a first-class deliverable, not a scramble item. ¹

Practical 30/60/90-day execution plan

First 30 days: Stabilize the requirement record

• Retrieve and store the authoritative 03.10.01 text from NIST SP 800-171 Rev. 3. ¹
• Identify the in-scope CUI boundary systems and owners.
• Draft the control implementation statement and get sign-off from the technical owner and compliance.
• Build the evidence inventory (what tools, what reports, who exports).

Next 60 days: Implement and prove operation

• Validate implementation across all in-scope systems (spot-check plus targeted deep checks on highest-risk systems).
• Collect the first full evidence set and run the test script.
• Close gaps with remediation tickets; document exceptions with approvals and expirations.

Next 90 days: Make it repeatable

• Integrate evidence collection into your recurring compliance calendar.
• Tie control checks to change management (new systems, new third parties, tenant migrations, identity changes).
• Run an internal mini-assessment: can a non-author of the control produce evidence on demand?
• In Daydream, keep 03.10.01 as the single hub for mapping, tasks, and evidence so the record stays current as staff and tools change.

Frequently Asked Questions

What does “03.10.01: ad requirement” mean if my tracker doesn’t show the full text?

It means your tracking system has the identifier but not the full requirement statement. Pull the authoritative 03.10.01 text from NIST SP 800-171 Rev. 3 and store it in your control record so implementation and testing anchor to the same source. ¹

How do I prove compliance if the control is mostly “configured in tools”?

Export the configuration state (or capture admin-console screenshots) and pair it with a short narrative that ties the setting to the CUI boundary. Add operational proof such as reports or tickets that demonstrate the control ran in practice.

What’s the minimum evidence set an assessor expects?

Enough to show design, implementation, and operation: the requirement text on file, your control statement, scope mapping to CUI systems, and current artifacts from the tools or workflows that implement the control. ¹

How should I handle exceptions for 03.10.01?

Use a documented exception workflow with business justification, compensating controls, approver, and an expiration condition. Store the exception record alongside the 03.10.01 evidence so it’s available during assessment.

Does this requirement extend to third parties?

If a third party can access or administer in-scope CUI systems, your ability to meet 03.10.01 can depend on them. Flow down relevant obligations in contracts and ensure you can obtain evidence about their access paths or operational activities that affect the control.

Where should this live: SSP, policies, or GRC tool?

Put the authoritative requirement text and your control narrative in your control library (often a GRC tool), reference the SSP for scope and system context, and keep the operational evidence in a controlled repository linked back to the requirement record. ¹

Footnotes

1. NIST SP 800-171 Rev. 3