Published Nov 22, 2025 · 10 min read
NIST 800-171 is table stakes for energy operators handling CUI. The fastest path is to operationalize the 14 families with clear owners and evidence. Below is a condensed checklist to drive implementation and audits.
Top Controls to Nail First
- AC-2 / AC-3: Role-based access, JIT elevation, and session timeouts.
- IA-2: MFA everywhere (human and service accounts) with hardware keys for admins.
- AU-2 / AU-12: Centralized logging with immutable storage and 12-month retention.
- SI-4: Continuous monitoring with tuned detections for OT and cloud.
Evidence Pack Template
- Policies: Access control, incident response, configuration management.
- Procedures: On/offboarding, change control, vulnerability management.
- Artifacts: MFA screenshots, SIEM dashboards, backup test logs, vendor SBOMs.
- Records: Quarterly access reviews, monthly patch cycles, annual IR tabletop.
Audit Readiness Tips
Assign a single control owner, map evidence locations, and pre-stage interview answers. Run a mock audit two weeks prior.