- List the genuinely dangerous duty pairs first: change-making versus change approval, administrative action versus log review, payment initiation versus release.
- Where headcount makes separation impossible, document the conflict and the compensating review — a second set of eyes on the audit trail beats pretending.
- Reflect the separations in group memberships and role assignments, not only in a policy paragraph.
03.01.04OFFICIAL TITLEPENDING NIST SME REVIEW
03.01.04 — Separation of Duties
03.01 Access Control · NIST SP 800-171 Rev. 3
Independent summary of the official requirement
Requires identifying the duties of individuals that require separation and defining system access authorizations to support that separation (aligned to SP 800-53 AC-5). Both the analysis and the access assignments that reflect it are in scope.
Rev. 3 requirement text is multi-part and parameterized with organization-defined values, so this site summarizes rather than reproduces it. The summary is independent — read the official publication for the binding wording.
NIST SP 800-171 Rev. 3 — Protecting CUI in Nonfederal Systems ↗NIST SP 800-171A Rev. 3 — Assessing Security Requirements for CUI ↗Independent interpretation
What this requirement is after
One person should not be able to both make a risky change and approve it, or administer the security tooling and also erase its logs. In a ten-person shop full separation is impossible — the honest implementation names the conflicts you actually carry, separates the ones you can, and puts compensating review on the ones you cannot.
Across revisions
Substantively carried forward from 3.1.4; Rev. 3 makes the identification step explicit — name the duties requiring separation, then define the access authorizations that support it.
Mapped practices
Brilliant at the Basics practices that support this requirement
No practice maps to this requirement — deliberately.
The campaign’s twenty practices are a priority list, not a control catalog, and none of them works this requirement’s substance directly. It still applies to you if it is in your contract’s scope: address it through your own implementation and the related artifacts below, and treat the absence of a mapping here as honesty, not permission to skip it.
Doing the work
Implementation considerations and evidence
- The documented duties-requiring-separation analysis, including accepted conflicts and their compensations
- Role or group assignments demonstrating the separations in the systems that matter
Artifacts
Templates and worksheets with a mapped relationship
No artifact in the library names this requirement yet. The library index groups everything by category and practice.
The other revision
Where this came from in Rev. 2
Provenance
Sources and review status
| Primary sources | NIST SP 800-171 Rev. 3 — Protecting CUI in Nonfederal Systems · NIST SP 800-171A Rev. 3 — Assessing Security Requirements for CUI |
|---|---|
| Review status | Pending NIST SME review |
| Content version | 1.0 |
| Updated |