NIST 800-171 3.13.10 (SC.L2-3.13.10): Key Management

Establish and manage cryptographic keys for cryptography employed in organizational systems.

NIST SP 800-171 Rev. 2, requirement 3.13.10

CMMC Level 2 practice SC.L2-3.13.10Published 2026-11-11

What 3.13.10 means in practice

Wherever cryptography is used, its keys are created, stored, distributed, rotated and destroyed under control: who can use them, where they are kept and how long they live. A key vault or hardware security module, and a written key management procedure, are the usual evidence.

SPRS points and the CMMC POA&M

CMMC Level 2 practice: SC.L2-3.13.10
SPRS points: 1 point. When it is not met, the DoD Assessment Methodology subtracts 1 from the score of 110.
CMMC POA&M: Allowed. It is worth 1 point, and 32 CFR 170.21(a)(2)(ii) admits requirements worth 1 point. Conditional status also needs a score of at least 88, and the item must be closed within 180 days.

Sources: NIST SP 800-171 DoD Assessment Methodology, version 1.2.1 (June 24, 2020), Annex A; 32 CFR 170.21, Plan of Action and Milestones requirements.

What an assessor checks for 3.13.10

NIST SP 800-171A gives 2 determination statements for 3.13.10, each found satisfied or other than satisfied. Determine if:

3.13.10[a] cryptographic keys are established whenever cryptography is employed.
3.13.10[b] cryptographic keys are managed whenever cryptography is employed.

NIST SP 800-171A (June 2018), assessment objectives for 3.13.10

Evidence that shows 3.13.10 is met

The key management procedure, covering creation, rotation and destruction.
Key vault configuration: access permissions, deletion protection and rotation policies.
Records of key rotation and certificate renewal.

How PolicyCortex gathers the evidence

PolicyCortex reads this evidence with the collectors below, read only, and grades 3.13.10 from it. Each line says what the product checks.

Azure Key Vault: Key vaults; Azure: Role assignments. Reads each Azure Key Vault and the role assignments that reach it, and checks that soft delete and purge protection are on and that access to keys follows least privilege through Azure RBAC.
Azure Policy: Compliance state. Reads Azure Policy's verdicts on Key Vault keys and secrets: rotation policies configured and expiration dates set.

Related pages

Calculator: SPRS score calculator: mark 3.13.10 and the other 109 requirements and see the score.
Sample package: Sample package: an SSP, a POA&M and an evidence chain the product generated from demonstration data.
Family: All 16 System and Communications Protection requirements (3.13).
Previous: 3.13.9: Connection Termination
Next: 3.13.11: FIPS Cryptography
All requirements: All 110 NIST SP 800-171 requirements, by family.

Related records

Guides and articles describe the work. The evidence that work produces is described in three proof pages, the architecture page, and the two pages on authorization.

proof.state: Proof of State. What the environment was, as of a date someone else picks: point-in-time records, content hashed and chained.
proof.change: Proof of Change. Who or what altered the environment, under what authority, with before and after state hashes.
proof.agency: Proof of Agency. What a machine was permitted to do before it acted, what it did, and what would have stopped it.
architecture: Architecture. How the chain is built and where the evidence is stored in each delivery mode.
authorization: Continuous ATO. How an authorizing official's decision is recorded with its package, and how the authorized system is checked against it every hour.
baseline: NIST SP 800-53. The Low, Moderate and High baselines as evidence, with the SSP, SAR and POA&M generated from one record.