PE-5(3): Marking Output Devices

PE-5(3) requires you to clearly mark output devices (such as printers, copiers, plotters, fax/MFP devices, and other system-connected output endpoints) so staff can reliably identify which devices are authorized for sensitive output and which are not. Operationalize it by defining marking standards, tagging devices, enforcing printing routes, and retaining repeatable evidence of deployment and upkeep. (NIST SP 800-53 Rev. 5)

Key takeaways:

• Maintain an inventory of output devices and apply consistent, durable markings tied to authorization and data handling rules.
• Pair physical markings with technical controls (print queues, access control, secure release) so markings reflect reality.
• Keep assessor-ready evidence: standards, inventory, photos, work orders, and periodic verification results.

The pe-5(3): marking output devices requirement is a physical and operational control that prevents a simple failure mode: people sending sensitive output to the wrong device or retrieving output from an untrusted location. In many environments, the “printer problem” is not theoretical. Shared devices move, queues get renamed, loaners show up, and staff print by habit. Without unambiguous markings, you end up with ambiguous handling rules.

This requirement is straightforward to implement, but it fails audits for one predictable reason: teams treat “marking” as a one-time label exercise instead of an operating process with ownership, standard definitions, and verification. You want a standard that answers: which devices are approved for which types of information, how users can tell, and how you keep labels accurate as devices change.

This page gives you requirement-level guidance you can execute quickly: applicability, step-by-step implementation, evidence to retain, common auditor questions, and a practical execution plan. It also flags where teams stumble, especially in mixed fleets that include third-party managed print services, remote offices, and hybrid work. (NIST SP 800-53 Rev. 5)

Regulatory text

Control reference: PE-5(3) “Marking Output Devices.” (NIST SP 800-53 Rev. 5 OSCAL JSON)

Provided excerpt: “NIST SP 800-53 control PE-5.3.” (NIST SP 800-53 Rev. 5 OSCAL JSON)

Operator meaning (what you must do): Implement a method to mark output devices so personnel can quickly determine device status and handling expectations before producing or collecting output. Treat markings as a controlled standard: defined criteria, assigned ownership, applied consistently, and validated periodically so the marking matches current authorization. (NIST SP 800-53 Rev. 5)

Plain-English interpretation

You need a visible, durable indicator on each output device that tells a user whether the device is:

• approved for sensitive printing (and at what level), or
• restricted to non-sensitive printing, or
• out of service / not authorized / quarantined.

Marking is about reducing human error at the point of use. If a user must guess whether a hallway printer is cleared for regulated data, you have already lost. The marking should be obvious, standardized, and tied to a real control decision (authorization, location, and configuration). (NIST SP 800-53 Rev. 5)

Who it applies to

Entity scope

• Federal information systems and programs aligning to NIST SP 800-53. (NIST SP 800-53 Rev. 5)
• Contractors operating systems that handle federal data and are assessed against NIST SP 800-53 controls. (NIST SP 800-53 Rev. 5)

Operational scope (where it shows up in practice)

• Corporate offices with shared printers and MFPs (copy/scan/print).
• Controlled spaces (badge-access floors, restricted labs, SCIF-adjacent spaces where applicable to your program).
• High-volume operations (mail rooms, claims processing, call centers).
• Third-party managed print fleets, including leased devices and field service support.
• Remote/branch sites where device sprawl and “temporary” printers are common.

If the system can generate output and people can physically retrieve it, PE-5(3) is in scope. (NIST SP 800-53 Rev. 5)

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

Step 1: Assign ownership and define the control boundary

1. Name a control owner (often Facilities + IT Asset Management + Security).
2. Define which devices count as “output devices” for your environment: printers, copiers/MFPs, plotters, label printers, production printers, and any specialized output endpoints connected to the system.
3. Decide whether “virtual printers” (PDF drivers) are out of scope for physical marking but still need logical labeling in print dialogs. Keep that decision documented. (NIST SP 800-53 Rev. 5)

Deliverable: PE-5(3) procedure with ownership, scope, and definitions.

Step 2: Create a marking standard that maps to data handling

Your standard should specify:

• Marking categories (simple and enforceable). Example categories you can adapt:
  • “Approved for Sensitive Output” (allowed for specified data types)
  • “Public/Non-sensitive Only”
  • “Secure Release Required” (if you require badge/PIN release)
  • “Out of Service / Not Authorized”
• What the label must include: device identifier, queue name, site/location code, service desk contact, and any required handling instructions (“Collect immediately,” “Do not leave unattended,” etc.).
• Label durability and placement: where to place labels so they survive cleaning and are visible at point of use.
• Change control triggers: relocation, queue rename, network reconfiguration, servicing, replacement, or authorization change must update markings.

Make sure markings are understandable by non-technical staff. If a label requires knowledge of internal acronyms, it will fail in operations. (NIST SP 800-53 Rev. 5)

Deliverable: “Output Device Marking Standard” (one-page plus appendix for label templates).

Step 3: Build a complete device inventory and tie it to authorization

1. Inventory all output devices in scope (include serial number, asset tag, model, physical location, print queue name, IP/MAC if relevant, and owner).
2. For each device, record its authorization status (which marking category applies and why).
3. If a third party manages devices, require them to provide an updated device list and location changes as part of the contract or operating procedure.

This is where many programs fail: they label what they remember, not what exists. Your inventory is the backbone of evidence. (NIST SP 800-53 Rev. 5)

Deliverable: Output device register (exportable, versioned, and reviewable).

Step 4: Implement the physical marking (and make it consistent)

1. Produce labels that match your standard (color, wording, iconography if you use it).
2. Apply labels to every device in the inventory.
3. Photograph a representative sample per site and per label category, and store photos with timestamps and device identifiers.

Include a process for loaners and replacements. Field service swaps are a common gap: the “new” device arrives without the label and runs for months. (NIST SP 800-53 Rev. 5)

Deliverable: Work orders or tickets showing labeling completed; photo evidence.

Step 5: Align technical controls so the marking matches reality

Physical markings become misleading if the configuration allows behavior that contradicts the label. Align at least these items:

• Print queue access control (who can print where).
• Secure print / pull-print configuration (if required by your handling rules).
• Default printer mappings (avoid defaulting sensitive users to non-approved devices).
• Device location controls (approved devices should be in approved spaces).

You do not need to over-engineer this enhancement, but you do need to prevent “Approved for Sensitive Output” labels from being placed on devices that accept jobs from anyone to an open tray in a public hallway. (NIST SP 800-53 Rev. 5)

Deliverable: Configuration baselines or screenshots for representative device classes and queues.

Step 6: Verify and keep it current (the part auditors probe)

1. Establish a recurring verification cadence (site walk-throughs or remote attestation with photos if sites are distributed).
2. Reconcile inventory to what’s on the floor: devices added, removed, moved, or relabeled.
3. Track exceptions and fixes in a ticketing system.

Daydream fit (natural place to use it): Many teams can do the labeling, but struggle to keep evidence coherent across sites and third parties. Use Daydream to map PE-5(3) to a single control owner, store the marking standard and templates, attach recurring evidence (inventories, tickets, photos), and generate assessor-ready exports without chasing inboxes. (NIST SP 800-53 Rev. 5)

Required evidence and artifacts to retain

Keep artifacts that prove both design (you defined the standard) and operation (it’s deployed and maintained):

Evidence artifact	What it proves	Good enough for auditors
Output Device Marking Standard + label templates	Defined, consistent marking criteria	Version-controlled doc with approval/owner
Output device inventory/register	Full scope and authorization status	Export with last-updated date and location fields
Deployment records (tickets/work orders)	Markings were applied	Samples across sites and device types
Photo evidence tied to device IDs	Labels exist and are legible	Representative sample; include “restricted” categories
Verification/inspection logs	Ongoing upkeep	Findings + remediation tracking
Third-party procedures/SLAs (if applicable)	External fleets follow the same rules	Contract language or operating procedure references

Assessors rarely accept “we label printers” without a standard and proof of upkeep. (NIST SP 800-53 Rev. 5)

Common exam/audit questions and hangups

Expect these questions, and prepare evidence that answers them quickly:

1. “What counts as an output device here?”
   Have your scoped inventory and definition ready.

2. “How do users know which printers are approved for sensitive output?”
   Show your marking standard, label examples, and photos in situ.

3. “How do you keep markings accurate after moves or replacements?”
   Show change control triggers and tickets from real device changes.

4. “Do third parties follow the same requirements?”
   Provide contract clauses, SOPs, and samples from third-party managed sites.

5. “How do you verify this control is operating?”
   Provide inspection logs and remediation tracking.

Frequent implementation mistakes (and how to avoid them)

• Mistake: Labels that don’t map to a real authorization decision.
  Fix: Tie each marking category to documented handling rules and location constraints.

• Mistake: Inventory drift (untracked devices).
  Fix: Reconcile device discovery sources (asset management, print server lists, procurement, and site walk-throughs).

• Mistake: “Secure printer” labels on devices without secure release.
  Fix: Require configuration validation before applying that category.

• Mistake: Third-party managed print is treated as “their problem.”
  Fix: Put marking requirements into operational procedures and ticket workflows the third party must follow.

• Mistake: No evidence beyond a policy statement.
  Fix: Retain tickets and photos as routine artifacts, not a scramble before assessment.

Enforcement context and risk implications

No public enforcement cases were provided in your source catalog for this requirement, so this page does not cite enforcement outcomes. What matters operationally is exposure: misrouted or abandoned printed output can become a reportable incident depending on the data type and applicable obligations. PE-5(3) reduces the likelihood of that class of failure by making authorization visible and auditable. (NIST SP 800-53 Rev. 5)

Practical 30/60/90-day execution plan

First 30 days (foundation)

• Assign control owner(s) and confirm in-scope device types and sites.
• Draft the Output Device Marking Standard and label templates.
• Pull initial device lists from asset management and print infrastructure; identify gaps.
• Decide how you will store evidence (central repository with consistent naming).

Day 31–60 (deployment)

• Complete physical walk-throughs (or equivalent remote attestation) to validate inventory.
• Apply labels to prioritized locations first (high foot traffic, shared devices, sensitive teams).
• Update print queue names and access controls where they contradict the marking categories.
• Start capturing tickets and photos in a consistent evidence format.

Day 61–90 (operationalize)

• Run your first formal verification cycle; document findings and remediation.
• Add third-party requirements to operating procedures and service workflows.
• Train service desk and facilities on triggers: moves, swaps, decommissions, new installs.
• Set recurring reviews and evidence collection so assessment prep is a byproduct, not a project.

Frequently Asked Questions

Does PE-5(3) mean I must label every printer with classification levels (e.g., “CUI,” “Confidential”)?

The control calls for marking output devices, but your categories should match your organization’s handling rules. Many programs use simpler “approved/not approved” markings and keep detailed data type mappings in the standard. (NIST SP 800-53 Rev. 5)

Are MFP scan-to-email and scan-to-network-folder functions covered by “output devices” marking?

If the device produces output (printed pages) it is squarely in scope. If you also treat scan functions as sensitive workflows, align markings and instructions so users understand allowed uses at the device. (NIST SP 800-53 Rev. 5)

How do we handle printers in remote or home offices?

Treat them as in scope if they are used for system-related output and you allow sensitive printing there. If you prohibit sensitive printing at home, make the rule explicit and prevent routing to home devices where possible, then document the decision. (NIST SP 800-53 Rev. 5)

What’s the minimum evidence an assessor will accept?

A documented marking standard, an inventory tied to authorization status, and operational proof such as tickets and photos from multiple sites. Add verification logs to show the control stays current as devices change. (NIST SP 800-53 Rev. 5)

Our print fleet is managed by a third party. Can we inherit this control?

You can rely on a third party for execution, but you still need accountability and evidence. Require the third party to follow your marking standard, provide updated inventories, and produce service tickets and photos as deliverables. (NIST SP 800-53 Rev. 5)

How do we avoid labels becoming stale after moves and replacements?

Put labeling into the move/add/change workflow: no device goes live without the correct marking, and any relocation triggers re-validation. Use tickets as your system of record and reconcile inventory during periodic verification. (NIST SP 800-53 Rev. 5)