PE-3: Physical Access Control

To meet the pe-3: physical access control requirement, you must define which facilities and controlled areas matter to your system, then enforce access so only authorized individuals can enter, based on documented approvals and consistent technical/physical controls. Operationalize PE-3 by tying authorizations to badging and visitor processes, logging entry, and retaining evidence that access is granted, reviewed, and removed.

Key takeaways:

• Scope the “where” first: facilities, data centers, wiring closets, and other controlled areas tied to the system boundary.
• Make authorization enforceable: approvals must map to badges/keys, visitor escorts, and door controls with logs.
• Evidence wins audits: access lists, approvals, logs, reviews, and deprovision records must be retained and reproducible.

PE-3 sits in the Physical and Environmental Protection family and is one of the fastest ways assessors test whether your security program is real or just policy. If your team cannot prove who can physically enter sensitive spaces, how they were approved, and whether access is removed promptly, you will struggle to defend broader controls like media protection, incident response, and system integrity. Physical access is also the easiest path for an attacker to bypass strong logical controls: tailgating, propped doors, shared badges, and unmanaged visitors still show up in real assessments.

This page is written for a Compliance Officer, CCO, or GRC lead who needs to implement PE-3 without turning it into a multi-quarter facilities project. You’ll get requirement-level guidance: what PE-3 expects, who owns which parts, exactly what to build (process + controls + evidence), and the audit questions that create findings. Where organizations get stuck is the “authorization enforcement” gap: approvals live in HR emails, badges live in a separate system, doors are managed by facilities, and logs are inaccessible. The goal is to connect those pieces into a control that operates consistently and leaves defensible evidence.

Regulatory text

NIST excerpt (PE-3): “Enforce physical access authorizations at {{ insert: param, pe-03_odp.01 }} by:” ¹

How to read this as an operator:

• “Enforce” means policy alone is insufficient. You need mechanisms (badges/keys/locks/guards/mantraps) plus procedures (visitor handling, escort rules, periodic reviews) that actually prevent unauthorized entry.
• “Physical access authorizations” means documented approvals that specify who is allowed in which spaces, under what conditions, and for how long (or until revoked).
• “At {{ insert: param, pe-03_odp.01 }}” is an organization-defined parameter. You must define the locations to which PE-3 applies (for example, a primary office, a data center cage, an IDF closet, a records room). Your scoping decision must be written down and consistent with your system boundary.

Reference: NIST SP 800-53 Rev. 5 ²

Plain-English interpretation (what PE-3 requires)

You must maintain a controlled list of who is allowed to enter sensitive facilities/areas, implement physical controls that enforce that list, and keep records that prove access is granted and revoked through an authorized process. If a person is not authorized, they should not be able to badge in, obtain a key, or be waved through without an exception process.

Who it applies to

Entity types (typical):

• Federal information systems implementing NIST SP 800-53 controls ¹
• Contractors handling federal data (including regulated environments where 800-53 is contractually flowed down) ¹

Operational contexts where PE-3 is assessed hard:

• Corporate offices with restricted suites or floors supporting the system
• Data centers (owned, colocation, or cages)
• Telecom rooms, wiring closets, MDF/IDF spaces
• Secure storage areas for backups, laptops, removable media, or sensitive records
• Labs, manufacturing, or areas with specialized equipment tied to the system boundary

Third-party angle: if a third party operates a colocation site, provides guards, or manages badging, PE-3 still lands on you. You must define requirements and obtain evidence through third-party due diligence and ongoing oversight.

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

1) Define the PE-3 scope (your “where”)

1. List in-scope facilities and controlled areas tied to the system boundary (rooms, cages, closets, secure storage).
2. Assign each area a protection level (example: public, controlled, restricted) and specify entry rules per level.
3. Document the organization-defined parameter for PE-3 (the locations). Put this in your SSP/control narrative so assessors don’t guess.

Deliverable: “Physical Access Scope & Area Register” (owned by Security/GRC with Facilities input).

2) Establish authorization rules (your “who/why/how long”)

1. Define eligible roles (employee, contractor, visitor) and what each can access.
2. Set approval authorities by area (Facilities, Security, System Owner).
3. Define time bounds (permanent vs. time-limited), and the trigger events for removal (termination, transfer, contract end).
4. Define exceptions (emergency entry, after-hours maintenance) with compensating controls and required logging.

Deliverable: “Physical Access Authorization Standard” plus an access request/approval workflow.

3) Implement enforcement mechanisms (make approval real)

Choose controls appropriate to the area, then connect them to the authorization workflow:

• Badge access system tied to identity records; badges map to approved access groups.
• Keys/locks with controlled issuance and return tracking.
• Visitor management with check-in/out, ID verification as required by your policy, and escort requirements for restricted areas.
• Guards/reception for areas where technical controls are weak (older buildings, shared spaces).
• Anti-tailgating measures where risk warrants (turnstiles, mantraps, cameras, or staffed entry).

Operator test: pick a recently terminated user and confirm they cannot enter any in-scope area. That test often reveals broken handoffs between HR, IT, and Facilities.

4) Centralize and retain logs (without boiling the ocean)

1. Decide which logs are authoritative per area (badge system events, visitor system records, key cabinet logs, guard logs).
2. Ensure logs can be exported for an audit period and filtered by person/date/door.
3. Define ownership for log production during an assessment (usually Facilities/Security Operations with GRC oversight).
4. Record retention should be written and followed; align to your broader record retention program.

5) Run recurring reviews (prove it stays correct)

1. Perform periodic access reviews for each controlled area: validate current authorized users against HR roster, contractor list, and current job needs.
2. Review visitor trends and exceptions (after-hours entry, forced door events, repeated escort violations).
3. Test revocation by sampling separations and verifying badge/key deactivation and key returns.

Tip: put PE-3 on a calendar with named owners. The most common PE-3 gap is not design, it’s missed review cycles and missing evidence.

6) Map the control to an owner, procedure, and evidence

Assessors want traceability: who runs the control, what they do, and what artifacts prove it happened. A simple control “bill of materials” prevents scrambling during audits. This aligns with the recommended operational control: map PE-3 to a control owner, implementation procedure, and recurring evidence artifacts ¹.

Required evidence and artifacts to retain

Keep artifacts that show design and operation. Minimum set:

• Scope & area register (in-scope locations; protection level; owner)
• Physical access policy/standard (authorization rules, escort rules, exceptions)
• Access request and approval records (tickets/workflow exports)
• Current access rosters per controlled area/access group (badge system exports)
• Deprovision evidence (badge deactivation logs, key return forms, removal tickets)
• Visitor logs (check-in/out, escort acknowledgments if used)
• Access review evidence (review date, reviewer, findings, remediation tickets)
• Incident/exception logs (forced doors, propped doors, after-hours exceptions) and corrective actions

Make evidence reproducible: store exports with timestamps and the query/filter used.

Common exam/audit questions and hangups

Expect these:

• “Show me the list of in-scope facilities/areas for this system boundary.”
• “Who approved access for these five people, and where is the approval?”
• “Demonstrate that a terminated user cannot enter.”
• “How do you control and track keys (including master keys)?”
• “How do visitors enter restricted areas, and who escorts them?”
• “How often do you review physical access lists, and what did you find last cycle?”

Hangups that trigger findings:

• No written scoping for the PE-3 locations (the parameter is undefined)
• Badge system exists, but approvals are informal and not traceable
• Access reviews happen ad hoc, with no evidence
• Contractors retain access after contract end
• Colocation access is treated as “the provider’s problem,” with no oversight artifacts

Frequent implementation mistakes (and how to avoid them)

1. Mistake: treating all buildings the same.
   Fix: classify areas and apply stronger enforcement only where it matters; document the rationale.

2. Mistake: approvals in email, enforcement in a badge console, no linkage.
   Fix: require a ticket/workflow ID before granting badge access; store it in the badge system notes field or the ticket.

3. Mistake: visitor process is theater.
   Fix: define “restricted area visitor rules” and train reception/guards; run spot checks.

4. Mistake: keys are unmanaged because “Facilities handles it.”
   Fix: put key issuance/return and periodic reconciliation into the PE-3 control procedure; sample-test it.

5. Mistake: third-party sites aren’t covered.
   Fix: require colocation/managed facility evidence (access roster, visit approval process, logs) as part of third-party oversight.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so this page focuses on assessment readiness and operational risk rather than enforcement outcomes.

Risk-wise, PE-3 failures create direct exposure:

• Unauthorized physical entry can bypass logical controls, enabling device tampering, network access, and data theft.
• Weak visitor and contractor controls often become “unknown access paths” during incident investigations because logs are incomplete or unavailable.
• If you cannot produce evidence, assessors will treat the control as not implemented, even if doors are locked.

Practical 30/60/90-day execution plan

First 30 days (stabilize and scope)

• Name a PE-3 control owner and backups (Security or Facilities with GRC accountability).
• Build the in-scope area register and document the PE-3 locations parameter in your control narrative.
• Document the authorization workflow (request, approval, provisioning, removal) for badges and keys.
• Identify log sources and confirm you can export badge and visitor records on demand.

Days 31–60 (enforce and instrument)

• Require ticketed approvals for all access grants; stop “walk-up badge changes.”
• Normalize access groups (by area/role), then align badge permissions to those groups.
• Implement or tighten visitor/escort procedures for restricted areas; train reception/guards.
• Start a lightweight evidence pack: monthly exports, a deprovision sample, and one exception review.

Days 61–90 (prove operation and close gaps)

• Run the first formal access review per controlled area; document findings and remediation tickets.
• Test termination/contract-end revocation end-to-end with sampling.
• Document third-party facility oversight expectations and request evidence from providers.
• Move evidence collection to a repeatable cadence in your GRC system.

Where Daydream fits naturally: use Daydream to map PE-3 to a single accountable owner, link the procedure, and schedule recurring evidence requests (badge roster exports, access reviews, visitor logs) so audit prep is a pull, not a scramble.

Frequently Asked Questions

What counts as “physical access authorizations” for PE-3?

A physical access authorization is a documented approval that grants a specific person access to a defined facility or controlled area. It must be enforceable through badges/keys/guards and traceable to an approver.

Do we have to include every office location in PE-3 scope?

No. You need to define the locations tied to your system boundary and document them as the organization-defined parameter for PE-3 ¹. Many teams scope to restricted areas first, then expand based on risk.

Our building is shared with other tenants. Can we still meet PE-3?

Yes, but you must clearly distinguish tenant-controlled spaces from common areas and show how you enforce access to your controlled areas. If common area controls matter to your risk model, capture them as dependencies and obtain supporting evidence from property management where possible.

Does PE-3 require badge logs to be in a SIEM?

PE-3 requires enforcement and evidence; it does not prescribe a specific tooling architecture in the provided excerpt ¹. If you can reliably export and retain logs with integrity and produce them during an assessment, you can meet typical audit needs without SIEM ingestion.

How do we handle third-party technicians who need periodic access (HVAC, ISP, copier, colocation staff)?

Put them on time-bounded access, require visit approvals, and enforce escort rules for restricted areas. Keep their access list separate so it can be reviewed and removed without relying on HR events.

What’s the fastest way to fail a PE-3 audit?

Being unable to show who is authorized for a restricted area and who approved it, then failing to demonstrate timely removal for a departed worker or contractor. Evidence gaps are treated as control failures in practice.

Footnotes

1. NIST SP 800-53 Rev. 5 OSCAL JSON

2. NIST SP 800-53 Rev. 5