NIST 800-53 Compliance Checklist and Security Controls Guide

Ensuring compliance with NIST SP 800-53 is critical for aligning your cybersecurity efforts with federal standards. This popular cybersecurity framework forms the foundation of a robust risk management program, spanning everything from access control and incident response to supply chain security.

The checklist below will help you align your information security program with the primary control pillars of NIST 800-53.

1. Achieve a security control baseline

NIST 800-53 specifies a security controls baseline for achieving the framework’s minimum data security standard. Achieving this minimum security standard sets the foundation for complete compliance with the framework.

A security control baseline is the initial safeguards every information system must meet. NIST defines three different baselines — Low, Moderate, and High — which correspond to the potential impact a security breach could have on your system.

Establishing your baseline is a four-step process:

Classify Your System: First, determine your system’s potential impact level. Use the U.S. federal standard FIPS 199 to assess the impact on confidentiality, integrity, and availability of your system if it were compromised. The highest score you get in any of these areas will determine your system’s overall impact level (e.g., if any score is “Moderate,” your system is considered “Moderate” impact).
Import the Controls: Once you know your system’s impact level, import the corresponding security controls. NIST provides machine-readable spreadsheets or OSCAL catalogs that list the exact controls for Low, Moderate, and High baselines. You can pull these lists into your governance, risk, and compliance (GRC) or preferred project management tool.
Tailor for Relevance: Not every control will apply to your specific system. Remove controls that don’t apply (for example, if you have a cloud-only system, you won’t need controls for physical locks). You’ll also need to define organization-specific parameters, such as your required password length or session time-out settings. NIST 800-53 provides guidance on how to perform proper tailoring.
Document & Approve: Record all your tailoring decisions, any remaining risks after implementing your controls, and who authorized these decisions. This documentation should be kept in a central location, as it serves as an audit trail for your baseline and helps with continuous monitoring.

Differences between NIST 800-53 and NIST 800-171

Many organisations also consider the standard NIST 800-171 for protecting sensitive internal information.

The table below highlights the key differences between NIST 800-53 and NIST 800-171 so you can decide which baseline (or combination) is most suitable for your information security objectives.

Risk tier	Criteria	Examples
Dimension	NIST SP 800-53 Rev 5 (5.1.1)	NIST SP 800-171 Rev 3
Latest release	Patch 5.1.1, 7 Nov 2023 (original Rev 5 Sept 2020)	Final, May 2024
Primary goal	End-to-end security and privacy controls for federal information systems and organisations	Confidentiality controls for CUI in non-federal systems (e.g., contractors, universities)
Control / requirement count	1,189 controls, plus enhancements.	97 security requirements (down from 110 in Rev 2).
Families / domains	20 families, incl. new SCRM and Privacy families.	17 families – adds PL, SA & SR to the original.
Baselines / tiers	Low, Moderate, High impact levels set in SP 800-53B	Single set mapped to 800-53 moderate baseline; no impact tiers
Typical adopters	Federal agencies, cloud service providers pursuing FedRAMP High, critical-infrastructure operators seeking full RMF alignment	DoD/IC contractors, research institutions with CUI, and suppliers aiming for CMMC Level 2
Implementation effort	High: tailoring and inheritance needed to trim 1k+ controls	Moderate: focused set, but new ODP parameters add specificity.
Notable 2023–25 changes	Added one control + three enhancements for identity providers & token management (patch 5.1.1).	Dropped basic/derived split, introduced ODPs, consolidated redundant requirements, and expanded families.
Mapping / cross-walks	Official mappings to CSF, ISO 27001:2022, CUI overlay, etc.	Transition mapping tables back to Rev 2 and 800-53B moderate baseline.

When to choose NIST 800-53

You need broader risk coverage: NIST 800-53 addresses confidentiality, integrity, availability, and privacy, making it ideal for systems with more complex or sensitive risk profiles.
You’re subject to federal compliance requirements: Managing a federal information system or pursuing FedRAMP authorization requires full implementation of the Risk Management Framework (RMF), which is built on NIST 800-53.
You need flexibility to tailor controls: NIST 800-53 allows large enterprises to inherit controls from shared services, disable non-applicable ones, and maintain traceable audit evidence.

When to choose NIST 800-171

You handle CUI under federal contracts: Defence and civilian agencies often require compliance with DFARS 252.204-7012 or CMMC Level 2, which specifically mandate NIST 800-171 Rev 3.
You need a lighter-weight starting point: With only 97 focused requirements, NIST 800-171 is faster to implement and assess, while still mapping to the 800-53 moderate baseline if you plan to expand later.
You want streamlined supply chain coverage: The new Supply Chain Risk (SR) family aligns with 800-53’s SCRM controls, allowing you to manage vendor risk effectively without adopting the full 800-53 catalog.

For support with aligning with NIST 800-171, use this checklist.

2. Implement Control Enhancements

Control enhancements further expand upon the functionality and efficacy of a given control to provide additional assurance of effectiveness.

Control Enhancements are included below the list of baseline controls in each control family (refer to this control catalog spreadsheet by NIST). They can be identified as an abbreviated name of a baseline control, followed by a number in parentheses, representing the sequential number of the enhanced control (e.g., AC-2(5)).

Each enhancement is optional for organizations not handling national-security data, but implementing them can be beneficial. For example, implementing controls enhancements in the Access Control family provides additional account management security, such as inactivity logout and privileged user accounts, reducing the risk of data breaches resulting from account compromise.

Here are three suggestions for simplifying the process of control enhancements implementation.

(i) Leverage free NIST resources

(ii) Automated security platforms

Governance, Risk, and Compliance (GRC) and general cyber risk management solutions can automatically discover whether a vendor’s security controls meet both the base controls and any enhanced controls you’ve deemed applicable, saving security teams from the time-consuming effort of manually reviewing vendor security information.

Using such tools also ensures vendor control expectations are commensurate with risk exposure levels, supporting the efficient allocation of Vendor Risk Management resources.

Platforms like UpGuard accelerate control gap discovery by automatically analysing evidence from multiple sources — from audit reports and attestations to questionnaire responses — to discover security control gaps and present findings in a professional risk assessment in minutes.

3. Delegate responsibilities and record evidence of implementation

Designate an individual or team to take ownership of every relevant NIST 800-53 control, capturing evidence that each control operates as expected. This will elevate your compliance tracking from a simple box-ticking process to an auditable day-to-day practice.

Follow the steps below to give every requirement a named owner, an execution plan, and an auditable trail.

(i) Map owners with a RACI matrix tied to the control catalogue

Build a RACI (Responsible, Accountable, Consulted, Informed) table that lists each 800-53 control alongside the individuals or teams who create, approve, execute, and review it. NIST’s role-based RMF quick-start guide will help you understand how to assign roles across each phase of the risk management process.
Review the RACI matrix quarterly or when new systems or control enhancements are introduced to keep accountability current.

RACI matrix example. Source: usemotion.com

(ii) Convert control tasks into project-management items

Break down each NIST control into actionable tasks and track them using a project management tool, like Jira. Create dedicated issue types for compliance tasks. Add custom fields like the control ID (e.g., AC-2), deadlines, and responsible owners. Set up automated reminders to ensure nothing is missed.

(iii) Utilize compliance dashboards and GRC platforms for status logging

Beyond task management, you need a centralized system to log the overall status of each control and store evidence of its implementation. Compliance dashboards, often integrated within Governance, Risk, and Compliance (GRC) platforms, are ideal. These platforms enable:

Real-time control status: Visualize the compliance status of all controls at a glance (e.g., compliant, partially compliant, non-compliant) and all necessary regulations, such as NIS2.
Evidence repository: Upload and link documentation, screenshots, policy documents, audit logs, and configuration files directly to the relevant controls. This creates an auditable trail.
Version control for documentation: Ensure all policies and procedures are the latest approved versions.
Reporting and analytics: Generate reports on compliance progress, identify areas of weakness, and demonstrate due diligence to auditors.

(iv) Establish a regular review and update cycle

Schedule recurring reviews of delegated responsibilities, control statuses, and collected evidence. This could be monthly for critical controls and quarterly for the entire framework. Document these reviews, including any actions taken, such as responsibility changes or modifications to your control strategy.

By systematically delegating tasks and diligently recording all implementation details and evidence, your organization can build a strong, defensible, and continuously improving NIST 800-53 compliance program.

4. Integrate with existing security policies and operations

Achieving NIST 800-53 compliance doesn’t necessarily mean starting from scratch. Most organizations already have a foundational set of security policies, procedures, and operational practices supporting NIST 800-53.

By understanding these overlaps, you can avoid redundant efforts and build a more cohesive compliance program.

Here’s a list of common supportive frameworks:

ISO/IEC 27001: Both NIST 800-53 and ISO 27001 emphasize a risk-based approach, require comprehensive documentation, and cover similar control areas such as access control, incident management, and physical security. If you are already ISO 27001 certified, many of your existing policies, risk assessments, and implemented controls can be directly mapped to fulfill NIST 800-53 requirements, significantly reducing the effort needed for compliance.
PCI DSS (Payment Card Industry Data Security Standard): While more prescriptive in certain areas (e.g., encryption of cardholder data, network segmentation), it also shares numerous commonalities with NIST 800-53, particularly in areas like vulnerability management, strong access control, and incident response..
HIPAA (Health Insurance Portability and Accountability Act): Similar to NIST 800-53, HIPAA mandates robust administrative, physical, and technical safeguards. Controls related to access logging, data integrity, secure disposal of information, and incident reporting under HIPAA will directly support corresponding NIST 800-53 requirements.
CIS Controls (Center for Internet Security Controls): The CIS Controls provide a strong operational foundation that aligns well with the objectives of NIST 800-53, offering practical steps contributing to compliance.

The strategic integration of these frameworks means that an investment in one often yields benefits across others. For example:

A robust access control policy (e.g., multi-factor authentication, principle of least privilege) implemented for ISO 27001 will simultaneously contribute to NIST AC controls, PCI DSS requirement 8, and HIPAA access safeguards.
Regular vulnerability scanning and penetration testing conducted to meet PCI DSS requirements will also provide valuable data and evidence for NIST CA and RA controls.
A comprehensive incident response plan developed for HIPAA will align closely with NIST IR controls.

5. Centralize neutral security controls

Keeping “neutral” controls, those used by every system and department, in one place prevents duplication, speeds audits, and gives leadership a single pane of glass for risk. NIST explicitly encourages agencies to designate common controls so that multiple systems can inherit a single, well-maintained safeguard instead of reinventing it in silos

Why centralization matters

One source of truth. A shared control library removes conflicting versions of policies and procedures.
Less audit fatigue. By unifying control evidence visibility, control owners can reduce security alerts and response fatigue by up to 50%, as eBay found after moving to a centralized ServiceNow GRC dashboard.
Rapid gap detection. Central dashboards easily highlight missing details or overdue review, helping security teams avoid last-minute information scrambling before an audit or risk assessment.

Track NIST 800-53 compliance with UpGuard.

UpGuard gives security teams a fast and scalable workflow for tracking vendor alignment with popular frameworks and standards, including NIST 800-53.

Key features include:

Purpose-built NIST 800-53 questionnaire: A pre-built and customizable vendor questionnaire mapping to NIST 800-53 and related frameworks, such as ISO 27001, CIS Controls, HIPAA, and PCI DSS.
AI-Powered security profiles: Processes security control evidence from multiple sources, such as audit reports, certifications and secuity questionnaires, flagging security gaps in minutes.
AI-driven risk assessments: Generate a detailed risk assessment summarizing key control gap findings — complete with control-by-control commentary — in under 60 seconds.
Centralized vendor security repository: All completed questionnaires and collected security evidence are stored in a centralized location, allowing complete visibility across all teams to reduce audit fatigue and streamline future reassessments.

Watch this video to learn how UpGuard leverages AI-powered automation to streamline vendor control gap discovery and improve overall TPRM efficiency.

Get a free demo of UpGuard >

FAQs about NIST 800-53 compliance

What is the difference between NIST 800-53 and 800-171?

NIST 800-53 is a comprehensive security and privacy control catalog designed for federal information systems. NIST 800-171 is specifically for non-federal entities that handle, store, or transmit Controlled Unclassified Information (CUI).

How often should you assess NIST compliance?

NIST encourages continuous monitoring based on system risk. For formal assessments, the frequency often depends on your organization’s risk management strategy and contractual obligations. A common approach is conducting annual full assessments, supplemented by ongoing monitoring and more frequent assessments (e.g., quarterly or semi-annually) for high-impact systems.

Can NIST compliance be automated?

Yes, significant portions of NIST compliance can and should be automated. While automation cannot replace human oversight entirely, such as policy creation and high-level risk management decisions, it can drastically streamline compliance activities.

Automation tools can assist with:

Continuous monitoring of vendor security controls to detect gaps and misconfigurations.
Automated evidence collection to simplify audit preparation and vendor risk assessments.
Real-time dashboards for tracking your compliance posture based on internal and external risk factors.
Generating compliance reports mapping to specific NIST controls.

Is NIST 800-53 mandatory for my organization?

NIST SP 800-53 is mandatory for all U.S. federal information systems. This requirement also extends to any contractors, cloud vendors, and other service providers that manage federal data or operate systems on behalf of a federal agency.

What is the difference between a “control” and a “control enhancement” in NIST 800-53?

A control is a fundamental safeguard or countermeasure for an information system. A control enhancement provides additional, specific functionality to a baseline control, offering a way to increase its security and assurance.

What were the key changes in NIST 800-53 Revision 5 (Rev. 5)?

NIST SP 800-53 Rev. 5 introduced several significant updates from its predecessor (Rev. 4). The most notable changes include:

Integration of privacy: Privacy controls are no longer in a separate appendix but are fully integrated into the control catalog, making privacy a core consideration from the start.
New control families: Two new families were introduced: Personally Identifiable Information (PII) Processing and Transparency (PT), and Supply Chain Risk Management (SR).
Focus on outcomes: The language of the controls was updated to be more outcome-based, focusing on the desired result rather than prescribing a specific implementation. This gives organizations more flexibility.
Removal of “federal”: The word “Federal” was removed from the title to encourage broader adoption by the private sector and other organizations.
Separation of baselines: The control baselines (Low, Moderate, High) were moved to a separate document (NIST SP 800-53B), making the main publication an accurate catalog of controls.