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CMMC Model — Official DoD FAQ

Will CMMC Update to Use NIST SP 800-171 Revision 3?

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Official DoD Answer
Source Source: DoD CIO CMMC FAQs v5 (B-Q3)

Yes, the Department will incorporate Revision 3 with future rulemaking. In the interim, the Department has issued a class deviation to DFARS clause 252.204-7012 to maintain Revision 2 as the standard against which defense industrial base companies will be assessed until Revision 3 has been incorporated into the 32 CFR CMMC Program rule through rulemaking.

In-Depth Analysis

Rev 2 vs Rev 3: What You Need to Know

NIST released SP 800-171 Revision 3 in May 2024 with significant changes, but CMMC assessments will continue using Revision 2 until the DoD completes formal rulemaking to adopt Rev 3.

What Changed in Revision 3

  • Reorganized from 14 families to aligned with NIST SP 800-53 structure
  • Added new requirements for supply chain risk management
  • Enhanced requirements for incident response and system integrity
  • Organization-Defined Parameters (ODPs) allow more flexibility

What This Means for You

For now: Prepare for and be assessed against NIST SP 800-171 Revision 2. This is the current standard per the class deviation memo.

Looking ahead: Begin familiarizing yourself with Rev 3 changes, but do not implement them at the expense of Rev 2 compliance. When the DoD formally adopts Rev 3, there will be a transition period.

The DoD has issued a class deviation memo specifically to prevent confusion — Revision 2 remains the assessment standard until further notice. This gives contractors clarity while the rulemaking process for Rev 3 incorporation proceeds.

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