PE-3(1): System Access

PE-3(1): System Access requires you to enforce system-level physical access authorizations on top of your facility’s physical security controls. Practically, that means you must define which people are allowed to physically reach the specific system (rooms, racks, consoles, media), implement controls that enforce those authorizations, and keep reviewable evidence that access matches approvals. ¹

Key takeaways:

• Facility access approval is not enough; you need explicit authorization for physical access to the system boundary. ¹
• Operationalize with an authorization list, enforce it at doors/racks/consoles, and review access routinely.
• Audit readiness depends on evidence: approvals, access logs, and periodic recertifications tied to the system.

PE-3(1): system access requirement shows up in audits because teams often stop at “badge access to the building” and assume the system is covered. NIST’s intent is narrower and more actionable: a person can be authorized to enter a facility, but still must not be authorized to physically access the specific information system, its components, or the areas that provide practical access to it. ¹

For a Compliance Officer, CCO, or GRC lead, the fastest path to operationalizing this control is to (1) define your “system physical boundary,” (2) define roles and conditions for who may access that boundary, (3) implement enforcement points aligned to that boundary (doors, cages, racks, consoles, smart hands procedures), and (4) retain evidence that approvals and enforcement match reality.

This page gives requirement-level guidance you can hand to facilities/security operations, IT, and data center/colocation stakeholders. It is written for federal information systems and contractor systems handling federal data, but it maps cleanly to common expectations in ISO 27001 physical security and SOC 2 logical/physical access narratives. ²

Regulatory text

Requirement (quoted): “Enforce physical access authorizations to the system in addition to the physical access controls for the facility at {{ insert: param, pe-03.01_odp }}.” ¹

Operator meaning: you must do two separate things and prove both:

1. Facility physical access controls exist (building security, perimeter, guards, badge readers, visitor management).
2. System physical access authorizations are explicitly enforced so only approved individuals can physically access the system itself (or the rooms/racks/consoles/media that equate to system access), even if they can enter the broader facility. ¹

A good mental model for exams: “Show me the list of people authorized to touch the system, and show me how the environment blocks everyone else.”

Plain-English interpretation (what PE-3(1) is really asking)

PE-3(1) is a separation-of-access requirement:

• Facility access answers: “Who can get into the building or data center?”
• System physical access authorization answers: “Who can reach this system (its servers, network devices, consoles, cabling, removable media, or the secure space that provides access to them)?” ¹

In practice, physical access to the system includes any of the following, depending on your architecture:

• Access to a data hall, cage, or secure room where the system resides
• Access to racks containing system components
• Ability to connect to consoles (KVM, crash cart, serial console) in the space
• Ability to handle system media (backup tapes, removable drives) stored with the system
• Ability to request “remote hands” to perform system-impacting actions without your approval

Who it applies to (entity and operational context)

Applies to:

• Federal information systems operated by agencies.
• Contractor systems handling federal data (including many regulated government contractors and service providers). ²

Operational contexts where this becomes real work:

• Colocation and data centers: the facility operator grants site access; you must still ensure only your approved personnel can access your cage/racks and that “smart hands” follow your authorization rules.
• Shared corporate offices: a general office badge may allow entry to a floor; PE-3(1) expects an additional boundary around server rooms, network closets, or lab environments that contain the system.
• Hybrid environments: even if most workloads are cloud-hosted, you may still have on-prem components (VPN appliances, HSMs, network gear) where system physical access authorizations matter.

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

Use the sequence below to operationalize quickly and create audit-ready evidence.

Step 1: Define the “system physical boundary”

Document where “physical access to the system” begins. Write it as enforceable scope, not prose:

• Locations (building, floor, room, cage, rack identifiers)
• Assets (rack IDs, device classes, media storage cabinets)
• Access methods that equate to physical access (console ports, crash cart storage, key cabinets)

Artifact: “System Physical Boundary Statement” owned by Security/Facilities with GRC review.

Step 2: Build a system physical access authorization matrix

Create a short matrix that says who can have access, under what conditions, and who approves. Keep it role-based, with named approvers:

• Roles: Data Center Tech, Network Engineer, SRE On-call, Facilities Security, Third-party Smart Hands
• Conditions: business need, background screening (if required by your program), escort required, time-bound access, ticket required
• Approvers: System Owner (or delegate), Physical Security Lead, HR for employment status validation

Artifact: “PE-3(1) System Access Authorization Matrix” and a current “Authorized Personnel List” (APL).

Step 3: Implement enforcement points that match the boundary

Pick controls that actually prevent unauthorized access, not controls that only detect. Common enforcement points:

• Door badge access for server rooms / data halls
• Mantraps or keyed locks for restricted rooms (if used in your environment)
• Rack locks or cages with separate access lists
• Key management for mechanical keys (issuance, return, periodic inventory)
• Console access governance: where crash carts are stored, who can retrieve them, how access is logged
• Colocation: ensure the provider enforces cage access lists and logs entry; ensure “remote hands” require your ticket/approval

Design rule examiners like: each enforcement point has (a) a defined list of authorized people, (b) a way to block others, and (c) logs you can retrieve.

Artifacts: access control system configuration export (where possible), provider portal screenshots showing authorized user list, rack/cage assignment docs.

Step 4: Put an approval + provisioning workflow in place

Make approvals and provisioning traceable:

• Request intake: ticketing system record with role, justification, boundary, start/end date if temporary
• Approval: System Owner (or delegate) and Physical Security sign-off
• Provisioning: badge group assignment / key issuance / colocation authorization update
• Deprovisioning triggers: termination, transfer, role change, end of contract, end of on-call rotation (if time-bound)

Artifacts: sample tickets, approval records, onboarding/offboarding runbooks, termination checklist entries.

Step 5: Establish routine reviews and reconciliations

Your control fails in audits when access lists drift. Set a cadence that matches your risk tolerance and operational churn:

• Periodic recertification of the Authorized Personnel List against HR roster and contractor list
• Reconciliation of badge group membership vs approvals
• Review of exceptions: escorted entries, after-hours access, “remote hands” work performed

Artifacts: review logs, sign-off evidence, reconciliation reports, exception register.

Step 6: Prepare the “audit packet”

Package evidence so you can answer in one sitting:

• Current authorization matrix + APL
• Last recertification evidence
• Access logs for a sample period
• A sample of access requests and approvals
• Colocation or third-party evidence (visitor logs, entry logs, remote hands tickets)

Daydream tip (practical, not theoretical): track PE-3(1) as a requirement with a named control owner, a written procedure, and a recurring evidence checklist so the audit packet builds itself over time rather than being assembled under pressure.

Required evidence and artifacts to retain

Keep evidence that proves authorization, enforcement, and operation over time.

Evidence type	What it should show	Examples
Authorization definition	Who can access, and approvals required	Authorization matrix; policy excerpt; RACI
Current authorized population	Exactly who is authorized today	Authorized Personnel List with roles and dates
Provisioning/deprovisioning records	Access changes follow approval	Tickets, approvals, badge group changes, key issuance forms
Enforcement configuration	Controls align to system boundary	Badge group mappings; cage/rack access list; key cabinet logs
Activity logs	Access events are logged and reviewable	Door logs; visitor logs; colocation entry logs; remote hands completion records
Reviews and reconciliations	You detect and fix drift	Recertification sign-offs; reconciliation outputs; exception register

Common exam/audit questions and hangups

Expect these, and pre-build your answers:

1. “Where is the system boundary?” Auditors will press until you name rooms, racks, and components.
2. “Show me who is authorized.” They want a list, not a policy.
3. “How do you enforce that list?” “Guards are present” is usually weaker than badge group controls tied to specific doors/cages.
4. “How do you remove access?” They will test a termination sample.
5. “What about third parties?” Colocation staff, cleaners, facilities contractors, and “remote hands” need explicit handling because they can reach the system.

Frequent implementation mistakes (and how to avoid them)

• Mistake: treating building badges as system authorization.
  Fix: create a distinct authorization group for the system boundary (server room/cage/racks) and require System Owner approval.

• Mistake: no written boundary definition.
  Fix: document the boundary in one page with identifiers (rooms/racks). Update it when you move gear.

• Mistake: “remote hands” can do anything with an email request.
  Fix: require a ticket number and named approver; keep completed-work evidence tied to the approval.

• Mistake: access list drift.
  Fix: schedule recurring recertification and reconcile badge group membership against the APL.

• Mistake: evidence lives in five systems and can’t be produced fast.
  Fix: maintain an evidence index for PE-3(1) and store exports/screenshots in a controlled repository each review cycle.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so treat risk as assessment-driven: PE-3(1) failures typically show up as audit findings because physical access is a direct path to system compromise (device tampering, rogue hardware insertion, media theft) and because physical access lists often drift without strong offboarding and periodic review. ²

Practical 30/60/90-day execution plan

Use phases (not dated promises) to move fast without guessing durations.

First 30 days (Immediate stabilization)

• Assign a control owner (physical security or facilities security, with the System Owner as approver).
• Define the system physical boundary and list the enforcement points (doors, cages, racks, consoles, media cabinets).
• Create the authorization matrix and produce the first Authorized Personnel List snapshot.
• Identify all third parties with potential physical access pathways (colocation provider staff, cleaning, building security, managed services).

Days 31–60 (Enforcement and workflow hardening)

• Implement or tighten enforcement: badge group changes, door permissions, cage/rack authorization updates.
• Stand up the approval workflow in your ticketing system and require it for any access changes.
• Establish deprovisioning triggers and map them to HR/offboarding.
• Run a first reconciliation of authorized list vs actual badge group membership; remediate exceptions.

Days 61–90 (Evidence maturity and audit packet)

• Perform a formal recertification with System Owner sign-off.
• Collect access logs and review exceptions; document findings and remediation.
• Finalize the PE-3(1) audit packet (evidence index + stored artifacts).
• If you use Daydream, map PE-3(1) to the control owner, procedure, and recurring evidence artifacts so collection becomes a recurring operational rhythm rather than a scramble.

Frequently Asked Questions

Does PE-3(1) require separate badging for the system area?

It requires separate authorization and enforcement for system access beyond the facility controls. Separate badging is a common way to enforce it, but a cage/rack control or controlled key management can also meet the intent if it blocks unauthorized individuals. ¹

If we’re fully cloud-hosted, does PE-3(1) still apply?

If your system has no customer-controlled physical components, your focus shifts to the cloud provider’s physical security and your contractual assurance. Many organizations still have some physical scope (network gear, endpoints used for administration, removable media), so confirm your system boundary before scoping it out. ²

How do we handle colocation “remote hands” under PE-3(1)?

Treat remote hands as physical access to the system. Require a ticket, named approval, scope of work, and completion evidence (provider work record) that you can tie back to the authorization.

What’s the minimum evidence an auditor will accept?

Expect to provide a boundary definition, an authorized personnel list, proof of enforcement (door/cage authorization), and proof of operation (access logs plus periodic recertification evidence). If one element is missing, the control often fails on “operating effectiveness.”

Can visitors ever access the system area?

Yes, but define strict conditions (escort required, time-bound access, visitor logs, and pre-approval). Treat “escorted access” as an exception path that still requires authorization and produces evidence.

Who should own this control: Facilities, Security, or IT?

Put day-to-day operation with the team that administers physical access systems (often Physical Security/Facilities Security) and require System Owner approval for authorization decisions. GRC should define evidence requirements and run periodic reviews.

Footnotes

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

2. NIST SP 800-53 Rev. 5