The material grain size changes significantly during machining of hardened steels, and this must be taken into account for improved modeling of surface integrity effects resulting from machining. Grain size changes induced during orthogonal cutting of hardened AISI 52100 (62 HRC) are modeled using the Finite Element (FE) method; in particular, a user subroutine involving a hardness-based flow stress model is implemented in the FE code and empirical models are utilized for describing the phase transformation conditions to simulate formation of white and dark layers. Furthermore, a procedure utilizing the Zener-Hollomon relationship is implemented in the above-mentioned user subroutine to predict the evolution in material grain size at different cutting speeds (300, 600, 900 SFPM). All simulations were performed for dry cutting conditions using a low CBN-content insert (Kennametal KD050 grade, ANSI TNG-432 geometry). The model is validated by comparing the predicted results with experimental evidence available in the literature.