Cloud Service Providers (CSPs) who want to do business with the US federal government must secure FedRAMP authorization. However, a lot of our Cloud Service Provider (CSP) clients also chase NIST 800-171 compliance.
Sometimes they do it as a steppingstone to FedRAMP, or because they have clients in the government contracting space who insist on it. Or occasionally they need to tack on 800-171 compliance to an existing authorization, like for NASA or the Department of Defense, to demonstrate the ability to safeguard Controlled Unclassified Information (CUI).
Since NIST 800-171 is a simplified control scheme, focused on applying limited protections to CUI, you’d think it would be pretty easy for a complex, technically sophisticated CSP to knock out right?
In reality, many of our large CSP clients have hit implementation roadblocks that stem from the fact that 800-171 wasn’t really written with cloud architectures in mind. Trying to apply 800-171 to modern clouds can muck up cloudops and introduce operational friction.
Let’s look at some reasons why CSPs struggle with 800-171 and why compliance isn’t as straightforward as some might think, and our advice for tackling those issues.
1. Square Peg, Round Hole
Many 800-171 controls assume on-prem infrastructure, dedicated assets, and clear network perimeters. This doesn’t always map well to the reality of cloud architectures.
- Perimeters get murky in a cloud-native system.
- Users, workloads, and data are fluid across regions and tenants.
- Traditional IT controls don’t always map cleanly to a cloud security model.
CSPs are thus tasked with reinterpreting vague and principle-based security requirements for cloud-native architectures.
Solution: To address this misalignment, we help our clients adopt cloud-native security frameworks like Zero Trust Architecture (ZTA) and Cloud Security Alliance (CSA) best practices, and then map these with audit-proof documentation that aligns with 800-171’s intent. Additionally, implementing well-documented boundary protections and defining clear data flow diagrams can help demonstrate compliance.
2. The Fog of Compliance – Indistinct, Light on Detail
Unlike, say the FedRAMP control set, which provides detailed cloud-specific guidance, 800-171 is light on specifics.
- 800-171 offers broad security principles without clear cloud mappings.
- Assessors often interpret controls differently, leading to inconsistent requirements.
- CSPs must guess at implementation details and hope auditors agree.
This ambiguity leads to wildly different compliance approaches across providers.
Solution: We develop internal control mapping guides, aligning 800-171 requirements to established frameworks like NIST 800-53, FedRAMP, or ISO 27001. We also partner with the top C3PAOs, and get buy-in on our mappings early, so there are no surprises come audit time.
3. Shared Responsibility Confusion
If you use AWS, Azure, or GCP, who’s responsible for what? 800-171 doesn’t say.
- Cloud customers, SaaS providers, and IaaS/PaaS platforms all share security responsibilities.
- Example: Who “encrypts data at rest”? AWS provides the encryption tools, the SaaS provider enables them, and the customer configures them.
- When something goes wrong, auditors may push responsibility up or down the stack depending on how they interpret the control.
Cloud providers often need to do extra documentation and control mapping just to explain what’s covered under shared responsibility.
Solution: While 800-171 does not technically require a FedRAMP-style customer responsibility matrix, we still essentially have to do them to avoid audit confusion. Luckily, we can do them pretty quickly, in a way that both auditors and customers can understand and agree with. Implementing contractual agreements (e.g., SLAs) that define security obligations can also prevent misunderstandings
4. Inheriting Compliance vs. Actually Being Compliant
Just because a CSP uses FedRAMP-approved infrastructure doesn’t mean their solution automatically meets 800-171.
- AWS, Azure, and Google Cloud offer compliant building blocks, but that doesn’t guarantee compliance in how those tools are used.
- Configuration matters. If you don’t enforce strong key management, encryption, or logging settings, you’re not compliant, even if your infrastructure is.
This “compliance gap” between cloud infrastructure and actual implementation is a common pain point.
Solution: We often get hands on for our clients, rapidly deploying an architecture that satisfies all 800-171 requirements for CSPs. With this continuous monitoring ready architecture, our clients are positioned to answer tough customer questions about security posture.
5. Authentication Headaches
NIST 800-171 has strict multi-factor authentication (MFA) and password complexity rules. But CSPs face a few problems:
- Many use third-party identity providers (Okta, Google Authenticator, Microsoft Entra ID) that customers control.
- CSPs can’t always force compliance if users manage their own settings.
- Federated authentication adds another layer of complexity.
When identity and access management (IAM) is split between providers and customers, enforcing compliance is a challenge.
Solution: We help our clients enforce authentication policies through Identity & Access Management (IAM) solutions, integrate conditional access policies, and monitor authentication logs for anomalies. Using Single Sign-On (SSO) with security enforcement can help balance flexibility with compliance. We help our clients set this up in a compliant way that does not fall afoul of compliance rules.
6. Logging & Monitoring in Multi-Tenant Environments
800-171 requires detailed audit logging (AU-3 to AU-12), but SaaS providers face an issue:
- Multi-tenant platforms share infrastructure while keeping logs isolated.
- CSPs must balance granular logging with data privacy & segmentation.
- Some logs might reside in third-party services, adding compliance complexity.
Building a logging system that satisfies 800-171 while maintaining multi-tenancy is a significant engineering effort.
Solution: We implement log aggregation with role-based access control (RBAC), using dedicated logging services (e.g., AWS CloudTrail, Azure Monitor) to ensure compliance. Data segmentation techniques like encryption at rest and tenant-specific log stores can also prevent privacy violations.
7. Encryption Everywhere (But How?)
800-171 mandates FIPS 140-2/3 validated encryption, but CSPs face hurdles:
- Many cloud-native services (like AWS Lambda or Azure Cosmos DB) don’t always document their encryption module validation.
- SaaS providers often use third-party encryption services—but are those compliant?
- Managing encryption across distributed, auto-scaling architectures isn’t as simple as flipping a switch.
CSPs sometimes have to build custom encryption layers just to satisfy compliance.
Solution: We implement a layered solution to meet FIPS 140-2/3 compliance while maintaining flexibility in cloud-native architectures. We:
- Use cloud-native encryption services with FIPS 140-2/3 validated modules (e.g., AWS KMS, Azure Key Vault).
- Implement customer-controlled key management (BYOK or HYOK) to maintain control over encryption keys.
- Use end-to-end encryption for data in transit and at rest, ensuring FIPS-validated encryption algorithms are enforced.
- Document encryption mappings and validation status for third-party services, ensuring compliance with auditors.
- Automate encryption policy enforcement across all storage and database solutions to maintain continuous compliance.
8. Patch Management in the Cloud Doesn’t Work Like On-Prem
800-171 assumes traditional patch management, but in cloud-native environments:
- Containers are recycled instead of patched.
- Serverless functions (like AWS Lambda) don’t have a traditional OS.
- Many applications rely on third-party libraries with unpredictable update cycles.
How do you “patch” an environment that doesn’t use traditional patching? CSPs must reframe the conversation around automated image updates, container refresh cycles, and dependency management.
Solutions. Our clients need to shift from traditional patch management to automated, cloud-native security approaches, including:
- Automated Image Updates – Regularly rebuild and redeploy container images with patched versions rather than applying updates to live instances.
- Immutable Infrastructure – Adopt infrastructure-as-code (IaC) practices where patched instances replace outdated ones instead of being modified in place.
- Serverless Security Controls – Use runtime security tools to detect and block vulnerabilities in serverless functions, as traditional patching doesn’t apply.
- Software Bill of Materials (SBOM) – Maintain an SBOM to track dependencies and ensure third-party libraries are updated and monitored for vulnerabilities.
- Continuous Vulnerability Scanning – Implement automated scanning tools (e.g., AWS Inspector, Azure Defender) to detect and remediate vulnerabilities in real-time.
By adopting these cloud-native security strategies, CSPs can maintain secure and compliant environments without relying on outdated patch management models.
9. Incident Response & Containment in Cloud-Native Models
800-171 expects clear incident response procedures, but cloud-native architectures complicate containment:
- Serverless functions don’t have persistent instances to quarantine.
- Kubernetes workloads scale dynamically, making containment tricky.
- Cloud environments are highly automated—a misconfigured response can delete critical data or expose new security gaps.
CSPs must design cloud-specific incident response workflows that meet compliance without breaking the system.
Solution: To meet compliance while maintaining operational integrity, we help our clients develop cloud-native incident response strategies that focus on automated yet controlled containment. Implementing real-time monitoring and anomaly detection allows for early identification of threats before they escalate. CSPs should leverage microsegmentation and identity-based access controls to prevent lateral movement within dynamic cloud environments. Additionally, response automation should be carefully designed to ensure that containment actions, such as isolating workloads or revoking access, do not inadvertently cause outages or delete essential resources. Well-documented incident playbooks tailored for serverless and containerized environments will help teams respond effectively while maintaining compliance with 800-171 requirements.
10. Customer-Controlled Configurations Create Compliance Gaps
SaaS providers let customers configure security settings, but what happens when they:
- Use weak passwords despite CSP recommendations?
- Disable logging for cost reasons?
- Leave APIs open to the public?
CSPs must decide whether to enforce compliance at all costs or give customers the flexibility to (accidentally) make themselves non-compliant.
Solution: SaaS providers must strike a balance between enforcing security best practices and allowing customer flexibility without compromising compliance. Implementing default secure configurations—such as enforcing strong password policies, enabling logging by default, and restricting API access—can help maintain compliance while allowing customers to adjust settings within secure parameters. Providing security guardrails rather than rigid enforcement ensures customers don’t inadvertently make themselves non-compliant. Additionally, continuous monitoring and automated policy enforcement can detect risky configurations in real-time, allowing CSPs to proactively alert customers or take corrective action where necessary. This approach ensures security without stifling usability.
Conclusion: Navigating 800-171 in the Cloud
Implementing NIST 800-171 in the cloud is not as straightforward as it initially appears. It requires:
- Reinterpreting traditional controls for cloud-native environments.
- Clear mappings of shared responsibility (Who owns what?).
- Cloud-specific security architecture that meets compliance without breaking functionality.
Ultimately, CSPs need to bridge the gap between traditional compliance frameworks and modern cloud realities—or risk being stuck in a never-ending game of compliance whack-a-mole.
