DWS Blog | 11.25.2025 Ep 19

November 25, 2025

Episode 19

NIST SP 800-53: More Controls, or a Shift in Security?

Author: Paul Neville

The evolution of cybersecurity standards is a necessary response to a rapidly changing digital world. While technological advancement has made our systems more capable, it has also introduced new threat vectors and complexities. In response, the National Institute of Standards and Technology's (NIST) Special Publication (SP) 800-53 has undergone its most significant update in over a decade with Revision 5 (Rev. 5). This revision is more than just a compliance update; it’s a change in the approach to cybersecurity and privacy. In the following sections, we will move past the initial shock of the increased control count to analyze how Rev. 5 shifts its scope, and establishes a new framework built upon outcome-based security principles.

About the Author:

My name is Paul Neville, I have 15 years of experience in securing complex information systems, hold a Master of Science in Cybersecurity and Information Assurance, and maintain several industry certifications, including: CISSP, CySA+, Network+, and Pentest+. My career began in the U.S. Navy as an Information Systems Technician, where I started out in system administration and network engineering. This better prepared me for later roles as an Information System Security Manager (ISSM) in highly regulated government environments utilizing NIST SP 800-53 as the primary compliance framework. I recently began working at Dark Wolf in May, where my primary role has me performing cybersecurity posture assessments on behalf of the Defense Innovation Unit (DIU) Proving Grounds initiative to identify any compliance gaps of small commercial companies in relation to multiple NIST frameworks.

More Controls and Addressing Modern Realities:

The most immediate change in NIST SP 800-53 Rev. 5 is the sheer number of security and privacy safeguards. The revision adds 2 new control families, 66 new security controls, 202 new control enhancements, and modifies 131 parameters of existing controls, bringing the total combined count to 1,007. This expansion wasn't done to pad the list and make compliance efforts more arduous; it was about addressing the modern reality of a rapidly evolving threat landscape.

The first “new” control family: “Personally Identifiable Information Processing and Transparency” or PT - formally integrates privacy into the security control catalog. Previously, privacy was treated somewhat as an afterthought, being relegated to Appendix J in Rev. 4. In Rev. 5, NIST has elevated privacy and individual rights by creating new controls, and integrating privacy considerations across all other control families. This update introduces provisions to ensure the processing of Personally Identifiable Information (PII) is justified, limited, communicated openly, and based on the individual's consent.

The other new addition is the Supply Chain Risk Management (SR) control family. Through this, NIST aims to address the vulnerabilities inherent in modern digital ecosystems, acknowledging that systems are composed of hardware, software, and services provided by numerous external entities. The SR controls take a full-lifecycle approach to implement acquisition strategies, perform continuous supplier assessments, and verify component authenticity. Put simply, the addition of this family means that organizations cannot simply outsource accountability for the security risk introduced by their supply chain. To those of you managing systems with Cisco devices who may remember checking dozens (if not thousands) of serial numbers to determine device authenticity, this newest addition should be met with thankfulness.

Story Time and Some Practical Examples:

In my time as a prior ISSM, I performed the transition from Rev. 4 to 5 on a “very large” network with about 8,000 active users, and an even messier supply chain to solve. These two new control families gave me multiple problems to solve. The first being PT, I found myself suddenly trying to answer a lot of difficult questions to determine where PII was being stored for these 8,000 users. Why was it there? What do we do with it? How long do we keep it? What was a Privacy Impact Assessment (PIA), and how do I perform one?

The second problem to deal with was SR, as it is with many systems, ours was a chaotic mix of technologies ranging from the latest-greatest next-gen firewall, to a switch that reached End of Life (EOL) back in 2004 somehow keeping the whole network afloat. As with PT, I was expected to answer these new controls. I knew what equipment I was responsible for, but where was it procured? Did we actually have plans to replace EOL equipment at some point? Or was it simply another CA-5 line-item in a Plan of Action and Milestones (POA&M) forever doomed to be put off in an ever growing list of problems? Attempting to answer these questions quickly shifted me away from the all too common “check-box” security mindset I might have been using up until that point.

The point is, through asking these new questions, I was quickly led down a rabbit hole of interlinked security concepts to properly find the answers. Phrasing that practically, Rev. 5 made me think for the first time in about a decade on how to actually do my job, rather than trying to check a box for the sake of an Authorization to Operate (ATO). This was primarily due to the way the security controls have been written, with Rev. 5 shifting toward implementing the outcome of a control, versus the impact.

Outcome Versus Impact:

Arguably the most influential change in Revision 5 is the evolution of the control language itself. Earlier versions relied on impact-based control narratives, which were often prescriptive, identifying who was responsible for what action within a system and often limiting security control implementation flexibility.

For a practical example, let's analyze IA-4(1), “Prohibit Account Identifiers As Public Identifiers” in both versions:

Rev. 4 - IA-4(1):

The organization prohibits the use of information system account identifiers that are the same as public identifiers for individual electronic male accounts.

Rev. 5 - IA-4(1):

Prohibited the use of system count identifiers that are the same as public identifiers for individual accounts.

At their core, the controls share the same objective, but two specific changes in Rev. 5 are a subtle, yet significant indicator of the broader philosophical shift:

Removal of "The organization": This removes the prescriptive entity, ensuring the controls’ intent regardless of whether the responsibility for management lies with the organization itself, or a third-party service provider.

Removal of "electronic mail accounts": This broadens the scope from a specific technology (email) to any public identifier.

This distinction provides for a less linear approach to fulfilling a security controls’ intent as organizations are no longer penalized for using creative or advanced solutions. This flexibility allows Rev. 5 to remain more relevant across diverse and rapidly evolving technological solutions. This shifts away from a restrictive approach to effectively managing risk, as long as the intended security outcome is achieved, organizations can find their own unique way to fulfill it, whether through automation, cloud-native tools, or something entirely different. While this doesn’t eliminate an Authorizing Official’s (AO) fear of the word “cloud”, it does mean organizations can now find worth in the newest revision.

A Shift in Scope - From FISMA to Organization:

In earlier iterations, NIST SP 800-53 was more narrowly focused on systems subject to the Federal Information Security Management Act (FISMA) requirements. Its primary audience was U.S. federal agencies and the contractors directly supporting them. In reality, this document generally functioned as a compliance checklist tailored to the specifics of federal information systems subject to a more traditional 3-year ATO cycle.

Rev. 5 transitions away from this narrow, system-centric view. For over two decades, every version of this publication included "Federal" in its title; with Rev. 5, this is intentionally omitted in favor of "Security and Privacy Controls for Information Systems and Organizations." By making this shift, NIST has positioned Rev. 5 as a practical guide for any organization seeking to manage enterprise-level risk and establish a security and privacy program. What this means in practical terms is that Governance, Risk, and Compliance (GRC) isn’t just an acronym for government, or contractor types to know anymore.

Blurring Line Between Public and Private Security:

The Department of War (DOW) and other federal agencies are actively embracing private commercial solutions, particularly cloud services and modern software tools, to maintain a technological advantage. This means that the changes introduced with Rev. 5 are not just abstract policy or verbiage updates, they are a direct response to the increasing adoption of the federal sector on commercial technology.

This evolution is already taking place, one such example being through the Federal Risk and Authorization Management Program (FedRAMP) authorization process. FedRAMP has adopted Rev. 5 as its authoritative guidance to determine product suitability, while providing a standardized approach to security assessment, authorization, and continuous monitoring for cloud products and services used by federal agencies. For any Cloud Service Provider (CSP) to gain an ATO and compete for business in DOW spaces, they must demonstrate compliance with the Rev. 5 baseline.

In practice this presents two major impacts to consider:

Baseline Security: FedRAMP’s use of Rev. 5 allows for a small, private company and their product to meet the same security outcomes as a large federal agency when handling data.

Market Growth: FedRAMP has already authorized 471 products, with 80 currently in the authorization process, and another 68 ready to begin assessment. This would be expected to accelerate based upon FedRAMP’s roadmap as part of the 20x initiative.

Practicality, Automation, and a Look at What’s to Come:

OSCAL, another initiative started by NIST in 2021, is planned to be leveraged for the automated validation, assessment, and authorization of FedRAMP packages. Put simply, FedRAMP is already leading the charge in terms of using automation to accelerate the ATO process and bring more commercial company products into DOW spaces. With OSCAL being adopted as part of these efforts, we should expect the number of authorized products to grow exponentially. This reality should motivate companies attempting to break into a rapidly expanding market, and maybe help legacy contractors realize they won’t always be the top dog if they’re unwilling to step out of their comfort zones. - This blog-post would derail quickly if I expanded beyond that, so check out Carl Markowski’s upcoming blog series titled “Cracking the Code of OSCAL's Technical Architecture” to follow his journey as he seeks to master this complex language and document every challenge.

In closing, these updates to NIST SP 800-53, alongside the shift towards automation combine to create the perfect recipe for commercial companies: clear incentives, and a competitive advantage to break into government contracting. Meaning that strong security is no longer a check-box obligation for contractors to meet, but a high-value path to enter DOW and government spaces by adopting these outcome-based security baselines as their goal.

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Episode 19

DARK WOLF SOLUTIONS