03.11.01: Risk Assessment

03.11.01: risk assessment requirement work fails for one consistent reason: teams write a risk register that is disconnected from the CUI boundary, the System Security Plan (SSP), and the Plan of Action and Milestones (POA&M). Assessors do not need your risk language to be fancy. They need it to be operational: what could go wrong for CUI, where it could happen in your environment, what control is supposed to prevent it, who owns the fix, and how you know the fix worked.

For a Compliance Officer, CCO, or GRC lead, “operationalizing” 03.11.01 means building a lightweight but defensible loop: define scope, identify threats and weaknesses, rate risk with a consistent method, decide treatment, document decisions, and track remediation to closure. Then keep it current. Changes to your CUI boundary, third parties, identity stack, endpoints, or hosting model should trigger a refresh because they change real exposure.

This page gives requirement-level guidance you can put into a program immediately: who’s in scope, a practical workflow, required artifacts, common audit hangups, and an execution plan you can run with your security and IT owners. (NIST SP 800-171 Rev. 3)

Regulatory text

Regulatory excerpt (as provided): “NIST SP 800-171 Rev. 3 requirement 03.11.01 (Risk Assessment).” (NIST SP 800-171 Rev. 3)

Operator interpretation: you must perform risk assessment activities for the nonfederal system that handles CUI and keep the outputs aligned to how you document and operate security in the SSP and POA&M. A risk assessment that does not drive control implementation or remediation tracking will not stand up in an assessment because it does not demonstrate risk-informed protection of CUI. (NIST SP 800-171 Rev. 3)

What the operator must do:

• Define the CUI environment scope and boundaries you are assessing (your “CUI system” in practice).
• Identify and rate risks to confidentiality, integrity, and availability of CUI within that scope.
• Decide risk treatment (accept, mitigate, transfer, avoid) with accountable approvals.
• Translate mitigation decisions into SSP control statements and POA&M work items, and validate closure before calling the risk addressed. (NIST SP 800-171 Rev. 3)

Plain-English interpretation (what 03.11.01 requires)

03.11.01 expects a living risk assessment process that can answer: “What are the most credible ways CUI could be exposed or disrupted in our environment, and what are we doing about it?” This is not a one-time exercise and not a generic enterprise risk register.

A practical reading for assessors:

• Your risks should be clearly tied to the CUI boundary and the actual system components that touch CUI (identity, endpoints, servers, cloud services, networks, backups, logging, and third parties).
• Your outputs should directly connect to your SSP (documented controls) and POA&M (gaps and remediation plan).
• You should be able to show that you revisit risk when meaningful changes occur and when remediation closes or stalls. (NIST SP 800-171 Rev. 3)

Who it applies to

Entity scope: federal contractors and other nonfederal organizations that handle CUI in nonfederal systems and are implementing NIST SP 800-171 Rev. 3. (NIST SP 800-171 Rev. 3)

Operational scope (what environments are in-bounds):

• Any system, enclave, tenant, or network segment that stores, processes, or transmits CUI.
• Supporting services that provide security-relevant functionality for that environment (identity provider, endpoint management, vulnerability management tooling, logging/SIEM, backup/restore, key management).
• Third parties that directly handle CUI or provide critical security services for the CUI environment (for example: MSPs, SOC providers, cloud hosting, managed directory). Use “third party” language in your risk register and call out when a third party is part of the control design. (NIST SP 800-171 Rev. 3)

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

1) Lock scope to the CUI boundary (don’t start with the risk register)

• Confirm the CUI boundary definition you use for your SSP: systems, data flows, user populations, and interconnections.
• Identify the components that enforce or weaken CUI controls (SSO, MFA, EDR, patching, encryption, logging, admin access paths).
• Output: a scoped inventory list and a simple CUI data flow diagram you can reference in risk statements.

2) Choose a consistent risk method you can repeat

Keep it defensible and understandable:

• Likelihood scale (qualitative is fine if consistent).
• Impact scale aligned to CUI outcomes (confidentiality loss, integrity loss, availability loss).
• A short list of risk drivers you will always consider: external attack paths, insider misuse, misconfiguration, vulnerability exposure, third-party dependency, and weak detection/response.

3) Identify risks as “scenario statements” tied to components

Write risks so an operator can act:

• Scenario: “If [threat event] exploits [weakness] on [component], then [CUI harm].”
• Include: affected asset/system, CUI type/location, existing controls, and observed weakness. Example:
• “If a compromised privileged account accesses the file repository used for CUI, CUI could be exfiltrated because privileged access reviews are not performed consistently.”

4) Map each risk to SSP controls and owners (the assessment-to-operation bridge)

This is where many teams fail. For each risk:

• Identify which SSP controls should address the risk.
• Name the control owner (person/role) and the system owner (service/app owner).
• Identify the implementing components (tooling, configurations, procedures). This alignment is explicitly called out as a risk factor when documentation exists but is not tied to implementable safeguards and owners. (NIST SP 800-171 Rev. 3)

Practical control mapping checklist:

• SSP control statement exists and matches the actual implementation.
• Component list is specific (not “IT systems”).
• Owner is accountable for evidence production and remediation.

5) Decide risk treatment and create POA&M items for gaps

For risks requiring mitigation:

• Create POA&M entries with: risk rating, planned action, target dates, dependencies, and validation steps.
• Track progress; do not mark “complete” until you validate closure with evidence. This is another explicit risk factor: incomplete evidence for SSP/POA&M alignment and closure validation. (NIST SP 800-171 Rev. 3)

6) Define recurring evidence collection (make it easy to prove operation)

You need recurring proof that risk decisions are maintained:

• Meeting minutes for risk review / security governance.
• Approvals for risk acceptance (with expiration or review trigger).
• Evidence of remediation completion (change tickets, screenshots/config exports, scan results, test outputs).
• A change trigger log: what changed, when you reassessed, and what decisions changed.

Where Daydream fits naturally: Daydream helps you keep the requirement-to-SSP mapping, evidence requests, and POA&M closure validation in one workflow, so your risk assessment outputs remain connected to accountable owners and repeatable evidence. That reduces the common “nice deck, no operating proof” failure mode.

Required evidence and artifacts to retain

Keep artifacts in an assessor-ready package, grouped by the CUI environment:

• Risk assessment methodology (scales, definitions, process owner, review triggers).
• Scoped asset/system inventory for the CUI boundary.
• Risk register with scenario-based entries, ratings, treatment, and owners.
• SSP mappings: for each major risk, link to relevant SSP control statements and implementation components. (NIST SP 800-171 Rev. 3)
• POA&M entries for gaps, with status and closure validation evidence. (NIST SP 800-171 Rev. 3)
• Risk acceptance memos (signed approvals, rationale, compensating controls, review cadence).
• Remediation validation: test results, configuration baselines, vulnerability scan outputs, access review records, logging verification, and ticket closure notes.

Common exam/audit questions and hangups

Expect assessors to press on these points:

• “Show me the boundary. What systems are in your risk assessment scope?”
• “Pick a top risk. Which SSP controls address it, and where is that implemented?”
• “Which risks are accepted? Who approved them? When is the acceptance reviewed?”
• “Show remediation closure. How did you validate the fix worked?”
• “How do you keep the risk assessment current when the environment changes?” (NIST SP 800-171 Rev. 3)

Hangups that cause findings:

• Risk register is enterprise-wide and not CUI-specific.
• Risks are written as vague topics (“phishing”) with no component tie-in.
• POA&M exists but is not clearly derived from risk and not validated on closure. (NIST SP 800-171 Rev. 3)

Frequent implementation mistakes (and how to avoid them)

1. Mistake: treating the SSP as static paperwork.
   Fix: require every “high” or “priority” risk to reference specific SSP control statements and implementation components. (NIST SP 800-171 Rev. 3)

2. Mistake: a POA&M that is just a task list.
   Fix: include risk rating, treatment intent, and closure validation steps before work starts; then collect the evidence at closure. (NIST SP 800-171 Rev. 3)

3. Mistake: no owner for risk decisions.
   Fix: assign a single accountable owner per risk (role + name) and require approvals for acceptance.

4. Mistake: no reassessment triggers.
   Fix: define triggers such as major boundary changes, onboarding a CUI-handling third party, identity platform changes, or incidents that touch CUI.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so you should not expect this page to list case citations.

Operationally, weak 03.11.01 execution increases your likelihood of failing assessments because the assessor can’t see how you identify and manage CUI exposure over time. The largest practical risk is not the existence of a risk; it is the inability to demonstrate controlled remediation and current alignment between risk decisions, the SSP, and the POA&M. (NIST SP 800-171 Rev. 3)

Practical execution plan (30/60/90-day)

Use this as an operational cadence, not a promise about effort.

First 30 days: establish scope, method, and minimum viable risk register

• Confirm CUI boundary inputs used by the SSP.
• Publish a one-page risk assessment method (scales, triggers, owners).
• Run a focused workshop with IT/security owners to identify top risks tied to CUI components.
• Create initial SSP mappings and open POA&M items for obvious gaps. (NIST SP 800-171 Rev. 3)

By 60 days: make it auditable

• Add evidence expectations to each key control owner (what logs/reports/approvals are required).
• Formalize risk acceptance approvals and a review trigger workflow.
• Validate that POA&M items have measurable closure criteria and evidence storage locations. (NIST SP 800-171 Rev. 3)

By 90 days: make it durable

• Run a second pass risk review after remediations and boundary changes.
• Sample test closure on completed POA&M items (prove “done” means validated).
• Create a standing governance routine: review top risks, aging POA&M items, and accepted risk renewals. (NIST SP 800-171 Rev. 3)

Frequently Asked Questions

Do we need a formal risk methodology (like NIST 800-30) to satisfy 03.11.01?

NIST SP 800-171 Rev. 3 expects a repeatable approach, but it does not require a specific branded method in the text excerpt provided. Use a consistent likelihood/impact method and show that results drive SSP control mapping and POA&M remediation. (NIST SP 800-171 Rev. 3)

Should our risk assessment cover the whole enterprise or only the CUI environment?

Scope it to the systems that handle CUI and the supporting services that secure them. You can maintain an enterprise risk program, but 03.11.01 evidence should clearly tie to your CUI boundary and CUI control operation. (NIST SP 800-171 Rev. 3)

What’s the minimum evidence an assessor will accept?

Keep a documented method, a CUI-scoped risk register, and proof that risks map to SSP controls and produce POA&M items with validated closure evidence. Missing SSP/POA&M alignment and closure validation is a known risk factor. (NIST SP 800-171 Rev. 3)

How do we document “risk acceptance” properly?

Record the risk scenario, rationale for acceptance, compensating controls, and the approving authority. Also document when you will revisit the acceptance or what change triggers a review. (NIST SP 800-171 Rev. 3)

How should third parties show up in the risk assessment?

Treat third parties that handle CUI or provide security-relevant services as in-scope risk drivers. Document dependency risks (access, logging, incident notification, configuration control) and link mitigations to SSP controls and POA&M tasks where gaps exist. (NIST SP 800-171 Rev. 3)

Can we treat POA&M as the risk register?

No. The POA&M tracks remediation work. Your risk assessment should identify and rate risk scenarios, decide treatment, then open POA&M items to implement mitigations and validate closure. (NIST SP 800-171 Rev. 3)