By Mitch Rice
Did you know that small and mid-sized businesses comprising the government supply chain were hit by more than 70 percent of cyberattacks in 2024?
Thus, today, the security of sensitive data is not something optional; it’s a necessity. That said, if your organization has some responsibility to handle Controlled Unclassified Information (CUI) with U.S. federal agencies, you’re under a contractual obligation to comply with NIST Special Publication 800-171.
Whether you’re a defense contractor, IT vendor, or manufacturer, not complying is not just going to mean losing business or paying legal penalties; it is going to expose critical data to dangerous actors.
But the good news?
There’s no need to be overwhelmed by compliance, as we are here to help you.
This is a step-by-step guide to the NIST 800-171 framework for you to follow, which would help you protect your systems, meet federal regulations, and be ready for new cyber threats that can occur in 2025 and beyond.
What Is NIST 800-171?
NIST 800-171 sets forward a collection of security controls aimed at protecting Controlled Unclassified Information (CUI) in non-federal information systems and organizations. Proper information handling was the aim behind its development, as sensitive government data should continue to remain secure in the hands of contractors and third-party organizations.
NIST 800-171 was originally mandated by the Defense Federal Acquisition Regulation Supplement (DFARS) and has turned into a standard for every organization doing business with federal or government agencies.
Nevertheless, staying compliant is a challenging task as there are numerous technicalities involved. Hence, you need professionally created editable NIST 800-171 compliance policies for your organization. These editable policy templates save you a significant amount of time and labor costs.
Why Is Compliance Important?
Failure to comply with NIST 800-171 can result in:
- Loss of government contracts
- Legal liability for data breaches
- Reputational damage
- Disqualification from future bidding opportunities
In addition, compliance is usually a prerequisite for other frameworks, such as CMMC (Cybersecurity Maturity Model Certification), making compliance a foundational requirement for future security endeavors.
So, in order to start your NIST 800-171 compliance journey, proceed with the below-mentioned steps.
Step 1: Understand 14 Control Families
The NIST 800-171 framework consists of 14 families of security requirements. Each family covers a specific area of cybersecurity, including:
- 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
Understanding these categories is a foundation for a compliance assessment of your organization’s current state.
Step 2: Conduct a Gap Analysis
Perform a gap analysis comparing your cybersecurity control to NIST 800 171 requirements. This process will help you:
- Identify missing or inadequate controls
- Prioritize remediation efforts
- Understand the scope of necessary improvements
This step is often done by many organizations via automated tools or consultants so that the assessment is comprehensive and accurate.
Step 3: Develop a System Security Plan (SSP)
A System Security Plan (SSP) is a key requirement of NIST 800-171 compliance. This document outlines:
- Your current security controls
- How each control is implemented
- Any deficiencies or areas for improvement
- Planned mitigation strategies
The SSP should be detailed, kept up to date regularly, and aligned with the real IT environment. This should be understood as your cybersecurity playbook.
Step 4: Create a Plan of Action and Milestones (POA&M)
Once you have cleared your gap analysis, you will find non-compliance areas and will need a POA&M (Plan of Action and Milestones). This document lays out:
- Specific steps needed to address each deficiency
- Responsible personnel
- Target completion dates
Having a POA&M demonstrates to agencies that your organization is intentionally working towards full compliance.
Step 5: Implement Necessary Security Controls
After you have received your SSP and POA&M, start pushing or improving your security controls. Some common updates include:
- Enforcing multi-factor authentication (MFA)
- Encrypting sensitive data at rest and in transit
- Enhancing access controls and audit logs
- Providing regular security awareness training
- Improving incident response protocols
System upgrades, process changes, and training employees to match the necessary standards may be involved in this stage.
Step 6: Monitor and Maintain Compliance
NIST 800-171 compliance is not a simple check to be completed once. It is critical for ongoing monitoring and maintenance to continue ongoing protection.
Best practices include:
- Regular vulnerability scans and risk assessments
- Updating the SSP and POA&M as systems evolve
- Continuous training and education
- Periodic internal audits
Establishing a compliance culture in your organization allows you to stay compliant, as threats and technologies are always changing.
Step 7: Be Audit-Ready
Government agencies or primes may conduct audits or request documentation to verify compliance. To be audit-ready, make sure:
- Your SSP and POA&M are current and accurate
- All implemented controls can be demonstrated
- Logs and audit trails are preserved
- Staff are prepared to answer compliance-related questions
Being prepared minimizes the risk of failed audits and contract disruptions.
Step 8: Prepare for CMMC
The Cybersecurity Maturity Model Certification (CMMC) is gradually replacing self-attestation with third-party audits. NIST 800-171 forms the foundation of CMMC Level 2, which is required for organizations handling CUI.
By fully implementing NIST 800-171, you position your organization to meet future CMMC requirements with minimal friction.
Final Thoughts
Achieving NIST 800-171 compliance is a crucial step for organizations that work with the federal government. It not only protects sensitive data but also ensures your business remains competitive and contract-eligible.
The process may seem complex, but by breaking it into clear, manageable steps—understanding control families, conducting a gap analysis, creating your SSP and POA&M, and implementing controls—you can navigate the path to compliance efficiently and effectively.
Cybersecurity is no longer optional. Start today, stay vigilant, and set your organization up for long-term success.
Data and information are provided for informational purposes only, and are not intended for investment or other purposes.
