PE-3(6): Facility Penetration Testing

PE-3(6) requires you to plan, authorize, and perform facility penetration testing to validate that physical security controls actually prevent or detect real-world attempts to breach a space where systems and data reside. To operationalize it quickly, define scope and rules of engagement, run a controlled test with qualified testers, track findings to remediation, and retain evidence that testing occurred and drove measurable fixes.

Key takeaways:

• Treat PE-3(6) as a repeatable program: scoped test events, documented authorization, and remediation closure.
• Evidence matters as much as the test: rules of engagement, reports, tickets, and closure records.
• Coordinate tightly with safety, legal, facilities, and system security to avoid business disruption and testing that proves nothing.

The pe-3(6): facility penetration testing requirement is about proving your physical security works under adversarial conditions, not just that you have policies and badges. Most organizations have “paper compliance” in physical security: access control lists, cameras, visitor logs, and guards. PE-3(6) pushes you to validate whether those controls hold up when someone actively tries to bypass them using realistic tactics (tailgating, social engineering at reception, bypassing doors, accessing restricted cages, or exploiting weak after-hours processes).

For a CCO, compliance officer, or GRC lead, the fastest path to operationalization is to treat this like a controlled assessment with clear authorization boundaries and clean evidence. You need a test plan that maps to facilities and security objectives, a formally approved rules-of-engagement package, a qualified testing team, a consistent method for recording results, and a remediation workflow that closes gaps with accountable owners. The goal is assessment-ready documentation plus a safer facility.

This page gives requirement-level implementation guidance you can hand to physical security, facilities, and your security program owner, then track in your GRC system through closure.

Regulatory text

Excerpt / reference: “NIST SP 800-53 control PE-3.6.” ¹
Framework context: NIST SP 800-53 Rev. 5 Physical and Environmental Protection (PE) family. ²

Operator interpretation: PE-3(6) expects you to perform facility penetration testing as a validation mechanism for physical access controls. In practice, assessors look for (1) an authorized and scoped penetration test of facilities that matter, (2) results that identify control weaknesses, and (3) evidence that you corrected the weaknesses and improved the control environment.

Because the provided excerpt is limited to the control reference, your implementation should be anchored in a defensible program narrative: you test physical access protections for spaces that host in-scope systems/data, and you can prove the test occurred and drove remediation. ²

Plain-English interpretation (what the requirement really asks)

PE-3(6) means: Run realistic, authorized attempts to breach your facility’s physical protections, then fix what fails. This is not the same as a routine door check, badge audit, or camera functionality test. A facility penetration test evaluates whether a motivated person can:

• Enter controlled areas without authorization,
• Move laterally into more restricted areas,
• Access sensitive rooms, racks, cages, or media storage,
• Exploit weak human processes (reception, shipping/receiving, contractors, cleaning crews),
• Avoid detection by guards, alarms, or monitoring.

The compliance outcome you want: “We test physical controls, document results, and remediate findings.” ²

Who it applies to (entity and operational context)

This requirement commonly applies where you run NIST SP 800-53-aligned programs, including:

• Federal information systems and the facilities supporting them. ²
• Contractor systems handling federal data (for example, systems supporting federal workloads) where NIST 800-53 is a contractual or program requirement. ²

Operationally, it applies to facilities that can impact confidentiality, integrity, or availability of in-scope systems and information, such as:

• Data centers and server rooms (owned or colocation),
• Network closets and telecom rooms,
• Operations floors and restricted offices,
• Media storage and secure disposal locations,
• Shipping/receiving areas if they provide a path into restricted space.

Third-party angle: if a third party operates the facility (colocation provider, managed office building security), you still need assurance. You may satisfy PE-3(6) through contracted testing rights, independent reports, or coordinated testing clauses, but you must be able to show how you validated controls in the spaces that matter to your system boundary. ²

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

Use the sequence below as your minimum viable operating procedure.

1) Assign ownership and define governance

• Name a control owner (often Physical Security or Facilities Security) and a compliance owner (GRC).
• Establish an approval path for tests: physical security lead, site leader, legal, HR (if social engineering is included), and system security owner.

Deliverable: PE-3(6) control statement with RACI and approval workflow recorded in your GRC system. ²

2) Define scope based on your system boundary

• List facilities and sub-areas that store or process in-scope data/systems.
• Identify “paths to impact” (for example, loading dock → hallway → network closet).
• Decide test types: after-hours entry, receptionist/social engineering, tailgating resistance, badge cloning attempts (only if lawful and authorized), alarm response validation.

Deliverable: Facility penetration testing scope document mapped to in-scope locations. ²

3) Write rules of engagement (RoE) with safety and legal constraints

Your RoE should specify:

• Authorized testers and identification method,
• Allowed techniques and explicit prohibitions (no forced entry, no weapons, no tampering with life safety systems unless explicitly approved),
• Hours, escalation contacts, and emergency stop procedures,
• Evidence handling (photos, logs) and privacy constraints,
• Coordination requirements with guards or building management (covert vs. known test).

Deliverable: Signed RoE and authorization memo. ²

4) Select qualified testers and manage third parties

Options:

• Internal physical security team with documented competence and separation of duties.
• External specialist firm under contract and NDA.
• Hybrid (external execution, internal observation and evidence management).

If a third party performs testing, treat them as a high-trust provider: validate background screening, insurance (if required by your contracts), and handling of sensitive findings. Keep procurement and legal aligned with RoE.

Deliverable: Tester qualifications summary and contract/SOW referencing the RoE. ²

5) Execute the penetration test and capture objective evidence

During execution:

• Record attempt narrative: entry points tried, controls encountered, bypass methods attempted.
• Capture time-stamped evidence: photos (where permitted), badge reader outcomes, guard response, alarm triggers, access logs.
• Document “success criteria” and “detection criteria.” A failed breach attempt may still be a test failure if no one detected it.

Deliverable: Penetration test report with findings, severity rationale, and impacted areas. ²

6) Convert findings into corrective actions with owners and due dates

• Create tickets for each finding (physical fix, process fix, training fix, monitoring fix).
• Assign an accountable owner: facilities, security operations, HR training, building management, or third party provider.
• Define verification: re-test, photo evidence of hardware changes, updated procedures, updated access control configurations.

Deliverable: Remediation plan, ticket list, and closure evidence. ²

7) Re-test and fold lessons learned into your physical security baseline

• Re-test high-risk findings or any finding that could enable unauthorized access to restricted space.
• Update guard post orders, visitor procedures, badging workflows, and monitoring rules based on observed gaps.
• Refresh your risk register entry for physical access threats and document residual risk acceptance where remediation is not feasible.

Deliverable: Re-test memo and updated procedures/training materials. ²

Required evidence and artifacts to retain

Auditors typically want to see artifacts that prove authorization, execution, and remediation. Keep:

• Facility penetration testing policy/standard (or section in physical security standard)
• Test plan and scope map (facilities, areas, entry points)
• Signed authorization and rules of engagement
• Tester qualifications or third-party SOW
• Test report (attempts, results, evidence, findings)
• Supporting logs: badge access logs, visitor logs, camera snapshots (as permitted), incident/guard logs
• Remediation tickets, change records, and closure evidence
• Re-test evidence or management sign-off on residual risk
• Metrics you can defend qualitatively (for example, “repeat finding eliminated after door hardware upgrade”); avoid fabricated percentages

A simple way to stay audit-ready is to map PE-3(6) to a single control record with recurring evidence tasks and an owner. Daydream is useful here because it can track the control, prompt evidence collection on a schedule, and keep RoE, reports, and remediation closures attached to the requirement record. ²

Common exam/audit questions and hangups

Expect these:

1. “Which facilities are in scope, and why?” If you cannot tie scope to the system boundary, the test looks arbitrary.
2. “Who approved the test?” Assessors look for formal authorization, not hallway approvals.
3. “Was the test realistic?” A test that avoids social engineering and only checks a side door may miss the real failure modes.
4. “Show me remediation.” Reports without tickets and closure evidence commonly fail.
5. “How do you handle third-party sites?” “We don’t control it” is not an acceptable end state; you need an assurance mechanism.

Frequent implementation mistakes (and how to avoid them)

• Mistake: Treating a walkthrough as penetration testing. Fix: require adversarial attempts with defined success criteria and documented outcomes.
• Mistake: No written authorization. Fix: make a signed RoE mandatory; store it with the report.
• Mistake: Over-scoping without operational buy-in. Fix: start with the highest impact areas (server rooms, network closets) and expand once governance works.
• Mistake: Findings die in email. Fix: force every finding into a ticketing system with an owner and closure evidence.
• Mistake: Testing breaks trust with building security or HR. Fix: coordinate guard leadership and HR upfront, define boundaries for social engineering, and document safety controls.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so this section is omitted by design.

Operational risk is still clear: weak physical access controls can enable device theft, tampering, unauthorized console access, or placement of rogue equipment. PE-3(6) gives you a structured way to demonstrate that “restricted” means restricted in practice. ²

Practical 30/60/90-day execution plan

Use these phases as an execution path; adjust based on facility complexity and stakeholder availability.

First 30 days (stand up governance and scope)

• Assign control owner and compliance owner; document RACI.
• Define in-scope facilities and restricted areas tied to your system boundary.
• Draft and approve a rules-of-engagement template.
• Decide internal vs third-party testers; begin contracting if needed.
• Create an evidence checklist in your GRC system (Daydream or equivalent) and pre-create a “PE-3(6) evidence” repository folder structure. ²

Days 31–60 (execute the first test and produce defensible artifacts)

• Run the first penetration test against one or two high-impact areas.
• Produce a formal report and log package.
• Open remediation tickets with owners and expected verification method.
• Brief leadership on findings and remediation commitments (keep it operational, not sensational).

Days 61–90 (close findings, re-test, and operationalize repeatability)

• Verify remediation and perform re-tests where needed.
• Update procedures: visitor management, contractor escort, after-hours access, shipping/receiving handling.
• Add the next facilities/areas into the testing schedule.
• Finalize your “assessment packet” for PE-3(6): control narrative, RoE, report, ticket closures, and re-test evidence. ²

Frequently Asked Questions

Does PE-3(6) require testing every facility we have?

The control reference does not prescribe a fixed frequency or facility count in the provided text. Scope it to facilities that support in-scope systems and data, and document why each included site matters. ²

Can we satisfy PE-3(6) with a third party’s SOC report or building security attestation?

Often you still need evidence that physical controls were validated through a penetration-style exercise for your risk. If a third party provides credible testing results for the relevant areas, retain those reports and document how they map to your scope and boundary. ²

Do we need to include social engineering (reception, guards) in the test?

The provided excerpt does not mandate specific tactics. Include human-process testing when it reflects your realistic threat paths, then document explicit boundaries in the rules of engagement. ²

Who should own PE-3(6): Facilities, Physical Security, or Security Compliance?

Put day-to-day ownership with the team that controls physical safeguards (physical security or facilities security) and keep GRC accountable for evidence quality and audit readiness. Write the RACI so remediation ownership is unambiguous. ²

What’s the minimum evidence an auditor will accept?

Aim for a signed authorization/RoE, a test report with objective evidence, and remediation records that show closure or formal risk acceptance. Missing remediation proof is a common failure point. ²

How do we prevent a penetration test from disrupting operations?

Control disruption through tight RoE boundaries, defined testing windows, safety prohibitions, and a stop procedure. Coordinate with site leadership and security operations so alarms and guard responses are handled safely and documented. ²

Footnotes

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

2. NIST SP 800-53 Rev. 5