What a NIST 800-171 Gap Analysis Really Tells You (And What it Doesn’t)

Cybersecurity Federal Compliance Gap Analysis

Many contractors hear the term NIST 800-171 gap analysis but are not sure what it actually means in practice. Some assume it leads directly to certification, while others believe it is simply a checklist exercise.

A NIST 800-171 gap analysis begins with a review of the security controls currently in place and a comparison against the requirements outlined in NIST SP 800-171. This process identifies controls that are missing, partially implemented, or inadequately documented, forming the foundation for remediation planning or compensating controls.

A gap analysis may support future certification efforts, but it is not a certification itself. It is also not a formal audit and does not, on its own, make an organization compliant.

A well-executed gap analysis produces a clear list of compliance gaps that can be directly translated into a Plan of Action & Milestones (POA&M), helping organizations prioritize remediation efforts based on risk. Together, these outputs provide leadership with a realistic understanding of the organization’s current security posture.

Common issues that slow progress toward compliance include insufficient evidence, confusing written policies with actual enforcement, and documentation that is either too vague or overly broad in scope.

A gap analysis is a starting point—not the end. Understanding where an organization currently stands is the first step toward reducing risk and achieving sustainable compliance.