Updated: 
May 9, 2025

NIST 800-172

An overview of NIST 800-172 requirements for protecting controlled unclassified information, including implementation steps, compliance challenges, and how enterprise browser solutions can help organizations meet these enhanced security standards for defense contracts.

About NIST 800-172

NIST Special Publication 800-172 establishes enhanced security requirements for protecting controlled unclassified information (CUI) in nonfederal systems from advanced persistent threats (APTs). These requirements build upon the baseline controls in NIST 800-171, focusing on additional safeguards where the loss, misuse, or unauthorized access could have severe or catastrophic consequences.

The standard addresses protecting the confidentiality of CUI through specialized approaches such as penetration-resistant architecture, damage-limiting operations, and designing for cyber resiliency. NIST 800-172 is particularly important for organizations supporting critical programs or high-value assets in defense, intelligence, and other sectors where sophisticated and well-resourced threat actors pose significant risks.

NIST 800-172 compliance steps

Understand the scope of NIST 800-172, which provides enhanced security requirements for protecting controlled unclassified information (CUI) in nonfederal systems from advanced persistent threats (APTs). This standard builds upon NIST 800-171 and is designed for critical programs and high-value assets.

Conduct a thorough gap analysis comparing your current security posture against the 35 enhanced requirements across 14 security control families in NIST 800-172. Document your current compliance status and identify specific deficiencies that need remediation.

Develop a detailed implementation plan with prioritized actions based on risk level, resource requirements, and operational impacts. Establish realistic timelines and assign clear ownership for each requirement implementation.

Implement access control enhancements by employing dual authorization for critical operations, isolating security functions, and using a privileged access management solution to strictly control administrator accounts and privileges.

Strengthen awareness and training by conducting advanced social engineering exercises, security-specific training for system developers, and threat awareness programs focused on APT tactics and techniques.

Enhance audit and accountability by implementing tamper-resistant logging solutions, automated audit log analysis tools, and cryptographically verifiable audit records to detect sophisticated attackers.

Implement rigorous configuration management through automated tools, secure baseline configurations, and regular security impact analysis for all system changes to prevent unauthorized modifications.

Deploy enhanced identification and authentication mechanisms such as multi-factor authentication for privileged accounts, hardware security tokens, and real-time verification of authenticator function and security status.

Establish comprehensive incident response capabilities including isolation procedures for compromised systems, automated incident handling, and regular adversarial testing to validate response effectiveness.

Implement system and communications protection through dynamic isolation methods, separate physical or logical security domains, and deception environments designed to mislead attackers about system components.

Deploy advanced system and information integrity protections including host-based intrusion detection, firmware integrity verification, and automated capabilities to detect and remediate unauthorized code.

Conduct regular assessments through penetration testing, red team exercises, and vulnerability scanning to verify the effectiveness of implemented security controls against sophisticated threats.

Document all security control implementations, providing evidence of compliance for each NIST 800-172 requirement to support certification and accreditation processes or customer attestations.

Establish a continuous monitoring program that regularly evaluates control effectiveness, emerging threats, and changing operational requirements to maintain a strong security posture over time.

Organizations often struggle to implement NIST 800-172 standards due to their complexity and resource-intensive nature. The enhanced security requirements demand specialized expertise that many organizations lack internally, forcing them to either invest in training or hire expensive security consultants. The financial burden extends beyond personnel to include sophisticated security technologies, monitoring systems, and infrastructure upgrades that can strain already limited IT budgets. Small and mid-sized organizations are particularly disadvantaged, as they must meet the same rigorous standards as larger counterparts without comparable resources.

The technical complexity of implementing controls like tamper-resistant logging, hardware security tokens, and firmware integrity verification presents significant challenges. Many organizations operate legacy systems that cannot easily accommodate these advanced security measures without substantial modification or replacement. The dual authorization requirements and strict isolation protocols often conflict with established business processes, creating friction between security teams and operational staff who prioritize efficiency and accessibility over stringent controls.

The standard's emphasis on sophisticated threat detection and response capabilities requires organizations to develop and maintain advanced security operations centers—an undertaking that demands continuous investment in both technology and human resources. The requirement for regular penetration testing, red team exercises, and adversarial simulations further compounds the operational burden, as these activities require careful planning to avoid disrupting critical business functions.

The consequences of failing to implement NIST 800-172 standards can be severe and far-reaching. Organizations that handle Controlled Unclassified Information risk losing government contracts and partnerships that require compliance. The reputational damage from non-compliance can extend beyond government relationships to affect broader market perception, with potential customers and partners questioning the organization's commitment to security. More critically, inadequate protection against advanced persistent threats leaves organizations vulnerable to sophisticated cyberattacks that could result in data breaches, intellectual property theft, and compromise of critical systems.

The financial impact of a successful attack against poorly protected systems can be devastating, including direct costs from incident response, legal proceedings, and regulatory fines, alongside indirect costs from business disruption and customer attrition. In sectors handling particularly sensitive information, executives may face personal liability for failing to ensure adequate security measures. Beyond organizational consequences, inadequate protection of controlled information could potentially impact national security, especially when the information relates to critical infrastructure, defense capabilities, or sensitive technologies of strategic importance.

Addressing NIST 800-172 requirements with an Enterprise Browser

Organizations contracting with the Department of Defense (DoD) must address NIST 800-172 requirements to ensure that they are "bid compliant" and eligible for contracts.The requirements are based upon the hygiene of the systems and applications interacting with DOD controlled unclassified information (CUI) and a subsequent audit of those controls called Cyber Maturity Model Certification (CMMC). Island Enterprise Browser allows organizations to create application boundaries around DOD CUI data and applications, reducing the size and complexity of the certification.

By creating secure application boundaries and embedding robust controls, Island ensures information stays within authorized systems, reducing audit scope and risk.