Comparison of NIST SP 800-171 and NIST SP 800-53 for protecting CUI and federal information systems
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NIST Special Publication (SP) 800-171 and NIST SP 800-53 are two important publications from the National Institute of Standards and Technology (NIST) that provide guidance on information security controls. Understanding the differences between the two publications is crucial for ensuring compliance with applicable regulations and best practices in information security. In this article, we will explore the details of each publication, their differences, and the compliance requirements.

NIST SP 800-171

NIST SP 800-171 is designed for non-Federal organizations that process, store, or transmit Controlled Unclassified Information (CUI). Its purpose is to establish minimum security requirements for protecting CUI, which is information that is not classified but still requires safeguarding or dissemination controls. Examples of CUI include financial information, export-controlled information, and certain types of personally identifiable information.

NIST SP 800-171 contains 110 controls across 14 families, covering areas such as access control, awareness and training, configuration management, and incident response. The publication provides guidance on how to assess and implement these controls to protect CUI.

One of the key features of NIST SP 800-171 is that it requires self-assessment by all covered contractors, with a few exceptions. Compliance with NIST SP 800-171 is required for all Department of Defense (DoD) contractors that handle CUI, and for other non-Federal organizations that handle CUI as a result of a contract or agreement. Failure to comply with NIST SP 800-171 can result in contract termination or suspension, among other penalties.

NIST SP 800-171 has been updated recently, with Revision 2 published in June 2020. The new revision includes several changes, such as adding new controls related to Supply Chain Risk Management and requiring Multi-Factor Authentication for privileged accounts.

NIST SP 800-53

NIST SP 800-53 is designed for Federal information systems. Its purpose is to provide a catalog of security and privacy controls for Federal information systems, covering areas such as access control, audit and accountability, contingency planning, and supply chain risk management. The controls are divided into 20 families, containing over 900 individual controls. NIST SP 800-53 is a comprehensive guide to information security controls that provides detailed guidance on how to select, implement, and assess controls.

Assessment is a key difference between NIST SP 800-171 and NIST SP 800-53. While self-assessment is required for compliance with NIST SP 800-171, assessment is required for Federal information systems and organizations to ensure compliance with NIST SP 800-53. The latest version of NIST SP 800-53 is Revision 5, which was released in September 2020 and reflects a more flexible and outcome-based approach to security and privacy control selection, assessment, and implementation.

NIST SP 800-53 is the basis for many Federal information security regulations and guidelines, such as the Federal Information Security Modernization Act (FISMA) and the Federal Risk and Authorization Management Program (FedRAMP). Compliance with NIST SP 800-53 is required for all federal information systems, and non-federal organizations that handle federal information or provide services to federal agencies may also be required to comply.

Comparison

The differences between NIST SP 800-171 and NIST SP 800-53 can be summarized as follows:

  • Scope: NIST SP 800-171 is focused on non-Federal organizations that handle CUI, while NIST SP 800-53 is focused on Federal information systems.
  • Purpose: NIST SP 800-171 establishes minimum security requirements for protecting CUI, while NIST SP 800-53 provides a catalog of security and privacy controls for Federal information systems.
  • Number of controls: NIST SP 800-171 has 110 controls across 14 families, while NIST SP 800-53 has over 900 controls across 20 families.
  • Compliance requirements: NIST SP 800-171 requires self-assessment by covered contractors, while NIST SP 800-53 requires a comprehensive assessment of Federal information systems and organizations.

While both publications have their own specific requirements and purposes, they share some similarities. Both publications are based on the NIST Cybersecurity Framework and emphasize the importance of risk management, continuous monitoring, and incident response. They also provide guidance on how to implement and assess security controls effectively.

Compliance Requirements

Compliance with NIST SP 800-171 and NIST SP 800-53 is essential for organizations that handle CUI or Federal information systems. Failure to comply with these publications can result in penalties, loss of contracts, and reputational damage.

To ensure compliance with NIST SP 800-171, organizations must conduct a self-assessment of their security controls and provide a System Security Plan (SSP) and a Plan of Actions and Milestones (POA&M). The SSP provides an overview of the organization's security posture, while the POA&M identifies any weaknesses or deficiencies and outlines a plan to address them.

To ensure compliance with NIST SP 800-53, Federal information systems and organizations must conduct a comprehensive assessment of their security controls using NIST SP 800-53A, which is a companion document to NIST SP 800-53. NIST SP 800-53A provides guidance on developing effective assessment plans, conducting assessments, and reporting assessment results. It includes a standardized assessment methodology and templates for conducting assessments, which can help ensure consistency and improve the quality of assessment results.

 

Feature NIST SP 800-171 NIST SP 800-53
Scope Designed for non-Federal organizations that process, store, or transmit Controlled Unclassified Information (CUI) Designed for Federal information systems
Purpose Establishes minimum security requirements for protecting CUI Provides a catalog of security and privacy controls for Federal information systems
Controls Contains 110 controls across 14 families Contains over 900 controls across 20 families
Control Families Access Control, Awareness and Training, Audit and Accountability, Configuration Management, Identification and Authentication, Incident Response, Maintenance, Media Protection, Personnel Security, Physical Protection, Risk Assessment, Security Assessment, System and Communications Protection, System and Information Integrity Access Control, Awareness and Training, Audit and Accountability, Configuration Management, Contingency Planning, Identification and Authentication, Incident Response, Maintenance, Media Protection, Physical and Environmental Protection, Planning, Program Management, Personnel Security, Risk Assessment, Security Assessment, System and Services Acquisition, System and Communications Protection, System and Information Integrity, Supply Chain Risk Management
Assessment Self-assessment required for all covered contractors, with a few exceptions Assessment required for Federal information systems and organizations
Compliance Required for all DoD contractors that handle CUI, and for other non-Federal organizations that handle CUI as a result of a contract or agreement Required for Federal information systems and organizations
Revision Latest version is NIST SP 800-171 Rev. 2 (February 2020) Latest version is NIST SP 800-53 Rev. 5 (September 2020)

Conclusion

In conclusion, NIST SP 800-171 and NIST SP 800-53 are two important publications that provide guidance on information security controls. While they have different scopes, purposes, and numbers of controls, they both emphasize the importance of risk management, continuous monitoring, and incident response. Compliance with these publications is essential for organizations that handle CUI or Federal information systems, and failure to comply can result in penalties and reputational damage. Organizations must carefully review and comply with the specific requirements of these publications to ensure the protection of sensitive information and systems.

References:

[1] National Archives and Records Administration. Controlled Unclassified Information. https://www.archives.gov/cui

[2] Department of Defense. Defense Federal Acquisition Regulation Supplement: Network Penetration Reporting and Contracting for Cloud Services. https://www.acq.osd.mil/dpap/policy/policyvault/USA002534-18-DPAP.pdf

[3] National Institute of Standards and Technology. NIST Special Publication 800-53 Rev. 5. https://nvlpubs.nist.gov/nistpubs/SpecialPublications/NIST.SP.800-53r5.pdf

[4] National Institute of Standards and Technology. NIST Special Publication 800-53A Rev. 5. https://nvlpubs.nist.gov/nistpubs/SpecialPublications/NIST.SP.800-53Ar5.pdf

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Author Profile

Carl B. Johnson, President of Cleared Systems, is a highly experienced and a ITAR, CMMC 2.0, Microsoft GCC High, and Microsoft DLP/AIP consultant. With over twenty years of experience in information assurance, cybersecurity, policy development, risk management, and regulatory compliance, he brings a wealth of knowledge and expertise to his clients.

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