executing-plans
executing-plans
Use when executing an implementation plan in the current session as the implementer yourself — your human partner chose inline execution, or no subagent tool is available
Skills 둘러보기
생산성 및 협업 · SKILL.md
cmmc-assessment-objectives
cmmc-assessment-objectivesVerbatim reference for all 320 NIST 800-171A Rev 2 assessment objectives, plus the Rev 2 → Rev 3 control crosswalk. Use for AO-level lookups (e.g., 3.1.1[c]), evidence planning, and forward-mapping to Rev 3. Pairs with cmmc-expert.
Independent GitHub snapshot · Automated classification · Original documentation governs
Skill 문서
GitHubname: cmmc-assessment-objectives description: "Verbatim reference for all 320 NIST 800-171A Rev 2 assessment objectives, plus the Rev 2 → Rev 3 control crosswalk. Use for AO-level lookups (e.g., 3.1.1[c]), evidence planning, and forward-mapping to Rev 3. Pairs with cmmc-expert." allowed-tools: Read, Glob, Grep, Write
CMMC Assessment Objectives — 800-171A Rev 2 (with Rev 3 Crosswalk)
The scoreable layer underneath every CMMC Level 2 assessment. Where cmmc-expert describes the CMMC program, this skill captures the 320 specific objectives an assessor is actually scoring against, plus the structural Rev 2 → Rev 3 mapping.
How to use this skill (paired with cmmc-expert)
| Question | Skill |
|---|---|
| What does CMMC require, who needs L1 vs L2, how does SPRS scoring work, what's POA&M-eligible? | cmmc-expert |
| What does an assessor look for at the objective level for 3.1.1? What does 3.13.11[a] actually say? | this skill |
| Where does Rev 2 3.5.7 land in Rev 3? Which Rev 2 controls were withdrawn? | this skill |
| What FedRAMP level does a CSP need for CUI? | cmmc-expert |
| What does FIPS-validated cryptography mean in Rev 3 vs. Rev 2? | this skill (note in 3.13.11 crosswalk row) |
Lookup patterns:
- By control: Jump to the family heading (
## 3.X) → find the practice number. - By objective: Each practice lists
[a], [b], [c]...— these are the scoreable units. - By Rev 3 equivalent: Jump to "Rev 2 → Rev 3 Crosswalk" → find the family → row by Rev 2 ID.
- For withdrawn controls: See the "Quick Reference: Withdrawn Rev 2 Controls" table.
Source & Verification Status
Layer 1 — Assessment objectives (Rev 2):
- Source: NIST SP 800-171A (June 2018; published assessment guide for 800-171 Rev 2).
- Status: Withdrawn May 14, 2024; still operative for CMMC Level 2 under current DoD rulemaking.
- DOI for parent 800-171 Rev 2: https://doi.org/10.6028/NIST.SP.800-171r2
- Text below is verbatim from the PDF.
Layer 2 — Rev 2 → Rev 3 crosswalk:
- Source: NIST SP 800-171 Rev 3 (Final, May 2024).
- AC, AT, AU families: PDF-verified.
- CM through SI families: high-confidence training-knowledge mapping; verify against the Rev 3 PDF before relying on it for a Rev 3 assessment deliverable.
Critical constants for Rev 2:
- 14 control families · 110 controls · 320 assessment objectives.
- Numbering scheme:
Chapter.Family.Requirement[Objective]— e.g.,3.1.1[a]= AC, requirement 1, objective a.
Quick Reference: Counts by Family
| Family | Rev 2 Controls | Rev 2 Assessment Objectives |
|---|---|---|
| 3.1 Access Control (AC) | 22 | 70 |
| 3.2 Awareness & Training (AT) | 3 | 9 |
| 3.3 Audit & Accountability (AU) | 9 | 29 |
| 3.4 Configuration Management (CM) | 9 | 44 |
| 3.5 Identification & Authentication (IA) | 11 | 25 |
| 3.6 Incident Response (IR) | 3 | 14 |
| 3.7 Maintenance (MA) | 6 | 10 |
| 3.8 Media Protection (MP) | 9 | 15 |
| 3.9 Personnel Security (PS) | 2 | 4 |
| 3.10 Physical Protection (PE) | 6 | 16 |
| 3.11 Risk Assessment (RA) | 3 | 9 |
| 3.12 Security Assessment (CA) | 4 | 14 |
| 3.13 System & Comms Protection (SC) | 16 | 41 |
| 3.14 System & Info Integrity (SI) | 7 | 20 |
| TOTAL | 110 | 320 |
Assessment Methods Reference (per NIST SP 800-171A)
Three methods — not four. "Determine" is the verb each objective opens with, not a separate method.
| Method | What it means | Depth attributes |
|---|---|---|
| EXAMINE | Reviewing, inspecting, observing, studying, or analyzing assessment objects (specifications, mechanisms, activities). | Basic / Focused / Comprehensive |
| INTERVIEW | Discussions with individuals or groups to facilitate understanding, achieve clarification, or obtain evidence. | Basic / Focused / Comprehensive |
| TEST | Exercising assessment objects under specified conditions to compare actual with expected behavior. | Basic (black box) / Focused (gray box) / Comprehensive (white box) |
Assessment Objects
- Specifications — policies, procedures, plans, SSP, designs, requirements.
- Mechanisms — hardware, software, firmware controls.
- Activities — system operations, exercises, backup operations.
- Individuals — system owners, admins, security personnel, users.
How to read an assessment objective
Each lettered sub-item ([a], [b], ...) is one scoreable assessment objective. For each, the assessor will (per NIST 800-171A):
- Determine if the objective is satisfied.
- Support that determination with E/I/T evidence — typically all three for any non-trivial control.
- Mark it Satisfied or Other Than Satisfied for SPRS / CMMC purposes.
Practice-level rollup: all AOs within a practice must be Satisfied for the practice to be MET in a C3PAO assessment.
320 Assessment Objectives (NIST SP 800-171A Rev 2)
Text below is verbatim from NIST SP 800-171A. Each lettered sub-item is one scoreable assessment objective.
3.1 ACCESS CONTROL (22 controls, 70 objectives)
3.1.1 — Limit system access to authorized users, processes acting on behalf of authorized users, and devices.
- [a] authorized users are identified
- [b] processes acting on behalf of authorized users are identified
- [c] devices (and other systems) authorized to connect to the system are identified
- [d] system access is limited to authorized users
- [e] system access is limited to processes acting on behalf of authorized users
- [f] system access is limited to authorized devices (including other systems)
3.1.2 — Limit system access to the types of transactions and functions that authorized users are permitted to execute.
- [a] the types of transactions and functions that authorized users are permitted to execute are defined
- [b] system access is limited to the defined types of transactions and functions for authorized users
3.1.3 — Control the flow of CUI in accordance with approved authorizations.
- [a] information flow control policies are defined
- [b] methods and enforcement mechanisms for controlling the flow of CUI are defined
- [c] designated sources and destinations for CUI within the system and between interconnected systems are identified
- [d] authorizations for controlling the flow of CUI are defined
- [e] approved authorizations for controlling the flow of CUI are enforced
3.1.4 — Separate the duties of individuals to reduce the risk of malevolent activity without collusion.
- [a] the duties of individuals requiring separation are defined
- [b] responsibilities for duties that require separation are assigned to separate individuals
- [c] access privileges that enable individuals to exercise the duties that require separation are granted to separate individuals
3.1.5 — Employ the principle of least privilege, including for specific security functions and privileged accounts.
- [a] privileged accounts are identified
- [b] access to privileged accounts is authorized in accordance with the principle of least privilege
- [c] security functions are identified
- [d] access to security functions is authorized in accordance with the principle of least privilege
3.1.6 — Use non-privileged accounts or roles when accessing nonsecurity functions.
- [a] nonsecurity functions are identified
- [b] users are required to use non-privileged accounts or roles when accessing nonsecurity functions
3.1.7 — Prevent non-privileged users from executing privileged functions and capture the execution of such functions in audit logs.
- [a] privileged functions are defined
- [b] non-privileged users are defined
- [c] non-privileged users are prevented from executing privileged functions
- [d] the execution of privileged functions is captured in audit logs
3.1.8 — Limit unsuccessful logon attempts.
- [a] the means of limiting unsuccessful logon attempts is defined
- [b] the defined means of limiting unsuccessful logon attempts is implemented
3.1.9 — Provide privacy and security notices consistent with applicable CUI rules.
- [a] privacy and security notices required by CUI-specified rules are identified, consistent, and associated with the specific CUI category
- [b] privacy and security notices are displayed
3.1.10 — Use session lock with pattern-hiding displays to prevent access and viewing of data after a period of inactivity.
- [a] the period of inactivity after which the system initiates a session lock is defined
- [b] access to the system and viewing of data is prevented by initiating a session lock after the defined period of inactivity
- [c] previously visible information is concealed via a pattern-hiding display after the defined period of inactivity
3.1.11 — Terminate (automatically) a user session after a defined condition.
- [a] conditions requiring a user session to terminate are defined
- [b] a user session is automatically terminated after any of the defined conditions occur
3.1.12 — Monitor and control remote access sessions.
- [a] remote access sessions are permitted
- [b] the types of permitted remote access are identified
- [c] remote access sessions are controlled
- [d] remote access sessions are monitored
3.1.13 — Employ cryptographic mechanisms to protect the confidentiality of remote access sessions.
- [a] cryptographic mechanisms to protect the confidentiality of remote access sessions are identified
- [b] cryptographic mechanisms to protect the confidentiality of remote access sessions are implemented
3.1.14 — Route remote access via managed access control points.
- [a] managed access control points are identified and implemented
- [b] remote access is routed through managed network access control points
3.1.15 — Authorize remote execution of privileged commands and remote access to security-relevant information.
- [a] privileged commands authorized for remote execution are identified
- [b] security-relevant information authorized to be accessed remotely is identified
- [c] the execution of the identified privileged commands via remote access is authorized
- [d] access to the identified security-relevant information via remote access is authorized
3.1.16 — Authorize wireless access prior to allowing such connections.
- [a] wireless access points are identified
- [b] wireless access is authorized prior to allowing such connections
3.1.17 — Protect wireless access using authentication and encryption.
- [a] wireless access to the system is protected using authentication
- [b] wireless access to the system is protected using encryption
3.1.18 — Control connection of mobile devices.
- [a] mobile devices that process, store, or transmit CUI are identified
- [b] mobile device connections are authorized
- [c] mobile device connections are monitored and logged
3.1.19 — Encrypt CUI on mobile devices and mobile computing platforms.
- [a] mobile devices and mobile computing platforms that process, store, or transmit CUI are identified
- [b] encryption is employed to protect CUI on identified mobile devices and mobile computing platforms
3.1.20 — Verify and control/limit connections to and use of external systems.
- [a] connections to external systems are identified
- [b] the use of external systems is identified
- [c] connections to external systems are verified
- [d] the use of external systems is verified
- [e] connections to external systems are controlled/limited
- [f] the use of external systems is controlled/limited
3.1.21 — Limit use of portable storage devices on external systems.
- [a] the use of portable storage devices containing CUI on external systems is identified and documented
- [b] limits on the use of portable storage devices containing CUI on external systems are defined
- [c] the use of portable storage devices containing CUI on external systems is limited as defined
3.1.22 — Control CUI posted or processed on publicly accessible systems.
- [a] individuals authorized to post or process information on publicly accessible systems are identified
- [b] procedures to ensure CUI is not posted or processed on publicly accessible systems are identified
- [c] a review process is in place prior to posting of any content to publicly accessible systems
- [d] content on publicly accessible systems is reviewed to ensure that it does not include CUI
- [e] mechanisms are in place to remove and address improper posting of CUI
3.2 AWARENESS AND TRAINING (3 controls, 9 objectives)
3.2.1 — Ensure that managers, systems administrators, and users of organizational systems are made aware of the security risks associated with their activities.
- [a] security risks associated with organizational activities involving CUI are identified
- [b] policies, standards, and procedures related to the security of the system are identified
- [c] managers, systems administrators, and users of the system are made aware of the security risks associated with their activities
- [d] managers, systems administrators, and users of the system are made aware of the applicable policies, standards, and procedures related to the security of the system
3.2.2 — Ensure that personnel are trained to carry out their assigned information security-related duties and responsibilities.
- [a] information security-related duties, roles, and responsibilities are defined
- [b] information security-related duties, roles, and responsibilities are assigned to designated personnel
- [c] personnel are adequately trained to carry out their assigned information security-related duties, roles, and responsibilities
3.2.3 — Provide security awareness training on recognizing and reporting potential indicators of insider threat.
- [a] potential indicators associated with insider threats are identified
- [b] security awareness training on recognizing and reporting potential indicators of insider threat is provided to managers and employees
3.3 AUDIT AND ACCOUNTABILITY (9 controls, 29 objectives)
3.3.1 — Create and retain system audit logs and records to the extent needed to enable the monitoring, analysis, investigation, and reporting of unlawful or unauthorized system activity.
- [a] audit logs needed to enable the monitoring, analysis, investigation, and reporting of unlawful or unauthorized system activity are specified
- [b] the content of audit records needed to support monitoring, analysis, investigation, and reporting of unlawful or unauthorized system activity is defined
- [c] audit records are created (generated)
- [d] audit records, once created, contain the defined content
- [e] retention requirements for audit records are defined
- [f] audit records are retained as defined
3.3.2 — Ensure that the actions of individual system users can be uniquely traced to those users so they can be held accountable for their actions.
- [a] the content of the audit records needed to support the ability to uniquely trace users to their actions is defined
- [b] audit records, once created, contain the defined content
3.3.3 — Review and update logged events.
- [a] a process for determining when to review logged events is defined
- [b] event types being logged are reviewed in accordance with the defined review process
- [c] event types being logged are updated based on the review
3.3.4 — Alert in the event of an audit logging process failure.
- [a] personnel or roles to be alerted in the event of an audit logging process failure are identified
- [b] types of audit logging process failures for which alert will be generated are defined
- [c] identified personnel or roles are alerted in the event of an audit logging process failure
3.3.5 — Correlate audit record review, analysis, and reporting processes for investigation and response to indications of unlawful, unauthorized, suspicious, or unusual activity.
- [a] audit record review, analysis, and reporting processes for investigation and response to indications of unlawful, unauthorized, suspicious, or unusual activity are defined
- [b] defined audit record review, analysis, and reporting processes are correlated
3.3.6 — Provide audit record reduction and report generation to support on-demand analysis and reporting.
- [a] an audit record reduction capability that supports on-demand analysis is provided
- [b] a report generation capability that supports on-demand reporting is provided
3.3.7 — Provide a system capability that compares and synchronizes internal system clocks with an authoritative source to generate time stamps for audit records.
- [a] internal system clocks are used to generate time stamps for audit records
- [b] an authoritative source with which to compare and synchronize internal system clocks is specified
- [c] internal system clocks used to generate time stamps for audit records are compared to and synchronized with the specified authoritative time source
3.3.8 — Protect audit information and audit logging tools from unauthorized access, modification, and deletion.
- [a] audit information is protected from unauthorized access
- [b] audit information is protected from unauthorized modification
- [c] audit information is protected from unauthorized deletion
- [d] audit logging tools are protected from unauthorized access
- [e] audit logging tools are protected from unauthorized modification
- [f] audit logging tools are protected from unauthorized deletion
3.3.9 — Limit management of audit logging functionality to a subset of privileged users.
- [a] a subset of privileged users granted access to manage audit logging functionality is defined
- [b] management of audit logging functionality is limited to the defined subset of privileged users
3.4 CONFIGURATION MANAGEMENT (9 controls, 44 objectives)
3.4.1 — Establish and maintain baseline configurations and inventories of organizational systems throughout the respective system development life cycles.
- [a] a baseline configuration is established
- [b] the baseline configuration includes hardware, software, firmware, and documentation
- [c] the baseline configuration is maintained (reviewed and updated) throughout the system development life cycle
- [d] a system inventory is established
- [e] the system inventory includes hardware, software, firmware, and documentation
- [f] the inventory is maintained (reviewed and updated) throughout the system development life cycle
3.4.2 — Establish and enforce security configuration settings for information technology products employed in organizational systems.
- [a] security configuration settings for information technology products employed in the system are established and included in the baseline configuration
- [b] security configuration settings for information technology products employed in the system are enforced
3.4.3 — Track, review, approve or disapprove, and log changes to organizational systems.
- [a] changes to the system are tracked
- [b] changes to the system are reviewed
- [c] changes to the system are approved or disapproved
- [d] changes to the system are logged
3.4.4 — Analyze the security impact of changes prior to implementation.
- [a] the security impact of changes to the system is analyzed prior to implementation
3.4.5 — Define, document, approve, and enforce physical and logical access restrictions associated with changes to organizational systems.
- [a] physical access restrictions associated with changes to the system are defined
- [b] physical access restrictions associated with changes to the system are documented
- [c] physical access restrictions associated with changes to the system are approved
- [d] physical access restrictions associated with changes to the system are enforced
- [e] logical access restrictions associated with changes to the system are defined
- [f] logical access restrictions associated with changes to the system are documented
- [g] logical access restrictions associated with changes to the system are approved
- [h] logical access restrictions associated with changes to the system are enforced
3.4.6 — Employ the principle of least functionality by configuring organizational systems to provide only essential capabilities.
- [a] essential system capabilities are defined based on the principle of least functionality
- [b] the system is configured to provide only the defined essential capabilities
3.4.7 — Restrict, disable, or prevent the use of nonessential programs, functions, ports, protocols, and services.
- [a] essential programs are defined
- [b] the use of nonessential programs is defined
- [c] the use of nonessential programs is restricted, disabled, or prevented as defined
- [d] essential functions are defined
- [e] the use of nonessential functions is defined
- [f] the use of nonessential functions is restricted, disabled, or prevented as defined
- [g] essential ports are defined
- [h] the use of nonessential ports is defined
- [i] the use of nonessential ports is restricted, disabled, or prevented as defined
- [j] essential protocols are defined
- [k] the use of nonessential protocols is defined
- [l] the use of nonessential protocols is restricted, disabled, or prevented as defined
- [m] essential services are defined
- [n] the use of nonessential services is defined
- [o] the use of nonessential services is restricted, disabled, or prevented as defined
3.4.8 — Apply deny-by-exception (blacklisting) policy to prevent the use of unauthorized software or deny-all, permit-by-exception (whitelisting) policy to allow the execution of authorized software.
- [a] a policy specifying whether whitelisting or blacklisting is to be implemented is specified
- [b] the software allowed to execute under whitelisting or denied use under blacklisting is specified
- [c] whitelisting to allow the execution of authorized software or blacklisting to prevent the use of unauthorized software is implemented as specified
3.4.9 — Control and monitor user-installed software.
- [a] a policy for controlling the installation of software by users is established
- [b] installation of software by users is controlled based on the established policy
- [c] installation of software by users is monitored
3.5 IDENTIFICATION AND AUTHENTICATION (11 controls, 25 objectives)
3.5.1 — Identify system users, processes acting on behalf of users, and devices.
- [a] system users are identified
- [b] processes acting on behalf of users are identified
- [c] devices accessing the system are identified
3.5.2 — Authenticate (or verify) the identities of users, processes, or devices, as a prerequisite to allowing access to organizational systems.
- [a] the identity of each user is authenticated or verified as a prerequisite to system access
- [b] the identity of each process acting on behalf of a user is authenticated or verified as a prerequisite to system access
- [c] the identity of each device accessing or connecting to the system is authenticated or verified as a prerequisite to system access
3.5.3 — Use multifactor authentication for local and network access to privileged accounts and for network access to non-privileged accounts.
- [a] privileged accounts are identified
- [b] multifactor authentication is implemented for local access to privileged accounts
- [c] multifactor authentication is implemented for network access to privileged accounts
- [d] multifactor authentication is implemented for network access to non-privileged accounts
3.5.4 — Employ replay-resistant authentication mechanisms for network access to privileged and non-privileged accounts.
- [a] replay-resistant authentication mechanisms are implemented for network account access to privileged and non-privileged accounts
3.5.5 — Prevent reuse of identifiers for a defined period.
- [a] a period within which identifiers cannot be reused is defined
- [b] reuse of identifiers is prevented within the defined period
3.5.6 — Disable identifiers after a defined period of inactivity.
- [a] a period of inactivity after which an identifier is disabled is defined
- [b] identifiers are disabled after the defined period of inactivity
3.5.7 — Enforce a minimum password complexity and change of characters when new passwords are created.
- [a] password complexity requirements are defined
- [b] password change of character requirements are defined
- [c] minimum password complexity requirements as defined are enforced when new passwords are created
- [d] minimum password change of character requirements as defined are enforced when new passwords are created
3.5.8 — Prohibit password reuse for a specified number of generations.
- [a] the number of generations during which a password cannot be reused is specified
- [b] reuse of passwords is prohibited during the specified number of generations
3.5.9 — Allow temporary password use for system logons with an immediate change to a permanent password.
- [a] an immediate change to a permanent password is required when a temporary password is used for system logon
3.5.10 — Store and transmit only cryptographically-protected passwords.
- [a] passwords are cryptographically protected in storage
- [b] passwords are cryptographically protected in transit
3.5.11 — Obscure feedback of authentication information.
- [a] authentication information is obscured during the authentication process
3.6 INCIDENT RESPONSE (3 controls, 14 objectives)
3.6.1 — Establish an operational incident-handling capability for organizational systems that includes preparation, detection, analysis, containment, recovery, and user response activities.
- [a] an operational incident-handling capability is established
- [b] the operational incident-handling capability includes preparation
- [c] the operational incident-handling capability includes detection
- [d] the operational incident-handling capability includes analysis
- [e] the operational incident-handling capability includes containment
- [f] the operational incident-handling capability includes recovery
- [g] the operational incident-handling capability includes user response activities
3.6.2 — Track, document, and report incidents to designated officials and/or authorities both internal and external to the organization.
- [a] incidents are tracked
- [b] incidents are documented
- [c] authorities to whom incidents are to be reported are identified
- [d] organizational officials to whom incidents are to be reported are identified
- [e] identified authorities are notified of incidents
- [f] identified organizational officials are notified of incidents
3.6.3 — Test the organizational incident response capability.
- [a] the incident response capability is tested
3.7 MAINTENANCE (6 controls, 10 objectives)
3.7.1 — Perform maintenance on organizational systems.
- [a] system maintenance is performed
3.7.2 — Provide controls on the tools, techniques, mechanisms, and personnel used to conduct system maintenance.
- [a] tools used to conduct system maintenance are controlled
- [b] techniques used to conduct system maintenance are controlled
- [c] mechanisms used to conduct system maintenance are controlled
- [d] personnel used to conduct system maintenance are controlled
3.7.3 — Ensure equipment removed for off-site maintenance is sanitized of any CUI.
- [a] equipment to be removed from organizational spaces for off-site maintenance is sanitized of any CUI
3.7.4 — Check media containing diagnostic and test programs for malicious code before the media are used in organizational systems.
- [a] media containing diagnostic and test programs are checked for malicious code before being used in organizational systems that process, store, or transmit CUI
3.7.5 — Require multifactor authentication to establish nonlocal maintenance sessions via external network connections and terminate such connections when nonlocal maintenance is complete.
- [a] multifactor authentication is used to establish nonlocal maintenance sessions via external network connections
- [b] nonlocal maintenance sessions established via external network connections are terminated when nonlocal maintenance is complete
3.7.6 — Supervise the maintenance activities of maintenance personnel without required access authorization.
- [a] maintenance personnel without required access authorization are supervised during maintenance activities
3.8 MEDIA PROTECTION (9 controls, 15 objectives)
3.8.1 — Protect (i.e., physically control and securely store) system media containing CUI, both paper and digital.
- [a] paper media containing CUI is physically controlled
- [b] digital media containing CUI is physically controlled
- [c] paper media containing CUI is securely stored
- [d] digital media containing CUI is securely stored
3.8.2 — Limit access to CUI on system media to authorized users.
- [a] access to CUI on system media is limited to authorized users
3.8.3 — Sanitize or destroy system media containing CUI before disposal or release for reuse.
- [a] system media containing CUI is sanitized or destroyed before disposal
- [b] system media containing CUI is sanitized before it is released for reuse
3.8.4 — Mark media with necessary CUI markings and distribution limitations.
- [a] media containing CUI is marked with applicable CUI markings
- [b] media containing CUI is marked with distribution limitations
3.8.5 — Control access to media containing CUI and maintain accountability for media during transport outside of controlled areas.
- [a] access to media containing CUI is controlled
- [b] accountability for media containing CUI is maintained during transport outside of controlled areas
3.8.6 — Implement cryptographic mechanisms to protect the confidentiality of CUI stored on digital media during transport unless otherwise protected by alternative physical safeguards.
- [a] the confidentiality of CUI stored on digital media is protected during transport using cryptographic mechanisms or alternative physical safeguards
3.8.7 — Control the use of removable media on system components.
- [a] the use of removable media on system components is controlled
3.8.8 — Prohibit the use of portable storage devices when such devices have no identifiable owner.
- [a] the use of portable storage devices is prohibited when such devices have no identifiable owner
3.8.9 — Protect the confidentiality of backup CUI at storage locations.
- [a] the confidentiality of backup CUI is protected at storage locations
3.9 PERSONNEL SECURITY (2 controls, 4 objectives)
3.9.1 — Screen individuals prior to authorizing access to organizational systems containing CUI.
- [a] individuals are screened prior to authorizing access to organizational systems containing CUI
3.9.2 — Ensure that organizational systems containing CUI are protected during and after personnel actions such as terminations and transfers.
- [a] a policy and/or process for terminating system access and any credentials coincident with personnel actions is established
- [b] system access and credentials are terminated consistent with personnel actions such as termination or transfer
- [c] the system is protected during and after personnel transfer actions
3.10 PHYSICAL PROTECTION (6 controls, 16 objectives)
3.10.1 — Limit physical access to organizational systems, equipment, and the respective operating environments to authorized individuals.
- [a] authorized individuals allowed physical access are identified
- [b] physical access to organizational systems is limited to authorized individuals
- [c] physical access to equipment is limited to authorized individuals
- [d] physical access to operating environments is limited to authorized individuals
3.10.2 — Protect and monitor the physical facility and support infrastructure for organizational systems.
- [a] the physical facility where organizational systems reside is protected
- [b] the support infrastructure for organizational systems is protected
- [c] the physical facility where organizational systems reside is monitored
- [d] the support infrastructure for organizational systems is monitored
3.10.3 — Escort visitors and monitor visitor activity.
- [a] visitors are escorted
- [b] visitor activity is monitored
3.10.4 — Maintain audit logs of physical access.
- [a] audit logs of physical access are maintained
3.10.5 — Control and manage physical access devices.
- [a] physical access devices are identified
- [b] physical access devices are controlled
- [c] physical access devices are managed
3.10.6 — Enforce safeguarding measures for CUI at alternate work sites.
- [a] safeguarding measures for CUI are defined for alternate work sites
- [b] safeguarding measures for CUI are enforced for alternate work sites
3.11 RISK ASSESSMENT (3 controls, 9 objectives)
3.11.1 — Periodically assess the risk to organizational operations, organizational assets, and individuals, resulting from the operation of organizational systems and the associated processing, storage, or transmission of CUI.
- [a] the frequency to assess risk to organizational operations, organizational assets, and individuals is defined
- [b] risk to organizational operations, organizational assets, and individuals resulting from the operation of an organizational system that processes, stores, or transmits CUI is assessed with the defined frequency
3.11.2 — Scan for vulnerabilities in organizational systems and applications periodically and when new vulnerabilities affecting those systems and applications are identified.
- [a] the frequency to scan for vulnerabilities in organizational systems and applications is defined
- [b] vulnerability scans are performed on organizational systems with the defined frequency
- [c] vulnerability scans are performed on applications with the defined frequency
- [d] vulnerability scans are performed on organizational systems when new vulnerabilities are identified
- [e] vulnerability scans are performed on applications when new vulnerabilities are identified
3.11.3 — Remediate vulnerabilities in accordance with risk assessments.
- [a] vulnerabilities are identified
- [b] vulnerabilities are remediated in accordance with risk assessments
3.12 SECURITY ASSESSMENT (4 controls, 14 objectives)
3.12.1 — Periodically assess the security controls in organizational systems to determine if the controls are effective in their application.
- [a] the frequency of security control assessments is defined
- [b] security controls are assessed with the defined frequency to determine if the controls are effective in their application
3.12.2 — Develop and implement plans of action designed to correct deficiencies and reduce or eliminate vulnerabilities in organizational systems.
- [a] deficiencies and vulnerabilities to be addressed by the plan of action are identified
- [b] a plan of action is developed to correct identified deficiencies and reduce or eliminate identified vulnerabilities
- [c] the plan of action is implemented to correct identified deficiencies and reduce or eliminate identified vulnerabilities
3.12.3 — Monitor security controls on an ongoing basis to ensure the continued effectiveness of the controls.
- [a] security controls are monitored on an ongoing basis to ensure the continued effectiveness of those controls
3.12.4 — Develop, document, and periodically update system security plans that describe system boundaries, system environments of operation, how security requirements are implemented, and the relationships with or connections to other systems.
- [a] a system security plan is developed
- [b] the system boundary is described and documented in the system security plan
- [c] the system environment of operation is described and documented in the system security plan
- [d] the security requirements identified and approved by the designated authority as non-applicable are identified
- [e] the method of security requirement implementation is described and documented in the system security plan
- [f] the relationship with or connection to other systems is described and documented in the system security plan
- [g] the frequency to update the system security plan is defined
- [h] system security plan is updated with the defined frequency
3.13 SYSTEM AND COMMUNICATIONS PROTECTION (16 controls, 41 objectives)
3.13.1 — Monitor, control, and protect communications at the external boundaries and key internal boundaries of organizational systems.
- [a] the external system boundary is defined
- [b] key internal system boundaries are defined
- [c] communications are monitored at the external system boundary
- [d] communications are monitored at key internal boundaries
- [e] communications are controlled at the external system boundary
- [f] communications are controlled at key internal boundaries
- [g] communications are protected at the external system boundary
- [h] communications are protected at key internal boundaries
3.13.2 — Employ architectural designs, software development techniques, and systems engineering principles that promote effective information security within organizational systems.
- [a] architectural designs that promote effective information security are identified
- [b] software development techniques that promote effective information security are identified
- [c] systems engineering principles that promote effective information security are identified
- [d] identified architectural designs that promote effective information security are employed
- [e] identified software development techniques that promote effective information security are employed
- [f] identified systems engineering principles that promote effective information security are employed
3.13.3 — Separate user functionality from system management functionality.
- [a] user functionality is identified
- [b] system management functionality is identified
- [c] user functionality is separated from system management functionality
3.13.4 — Prevent unauthorized and unintended information transfer via shared system resources.
- [a] unauthorized and unintended information transfer via shared system resources is prevented
3.13.5 — Implement subnetworks for publicly accessible system components that are physically or logically separated from internal networks.
- [a] publicly accessible system components are identified
- [b] subnetworks for publicly accessible system components are physically or logically separated from internal networks
3.13.6 — Deny network communications traffic by default and allow network communications traffic by exception (i.e., deny all, permit by exception).
- [a] network communications traffic is denied by default
- [b] network communications traffic is allowed by exception
3.13.7 — Prevent remote devices from simultaneously establishing non-remote connections with organizational systems and communicating via some other connection to resources in external networks (i.e., split tunneling).
- [a] remote devices are prevented from simultaneously establishing non-remote connections with the system and communicating via some other connection to resources in external networks (split tunneling)
3.13.8 — Implement cryptographic mechanisms to prevent unauthorized disclosure of CUI during transmission unless otherwise protected by alternative physical safeguards.
- [a] cryptographic mechanisms intended to prevent unauthorized disclosure of CUI are identified
- [b] alternative physical safeguards intended to prevent unauthorized disclosure of CUI are identified
- [c] either cryptographic mechanisms or alternative physical safeguards are implemented to prevent unauthorized disclosure of CUI during transmission
3.13.9 — Terminate network connections associated with communications sessions at the end of the sessions or after a defined period of inactivity.
- [a] a period of inactivity to terminate network connections associated with communications sessions is defined
- [b] network connections associated with communications sessions are terminated at the end of the sessions
- [c] network connections associated with communications sessions are terminated after the defined period of inactivity
3.13.10 — Establish and manage cryptographic keys for cryptography employed in organizational systems.
- [a] cryptographic keys are established whenever cryptography is employed
- [b] cryptographic keys are managed whenever cryptography is employed
3.13.11 — Employ FIPS-validated cryptography when used to protect the confidentiality of CUI.
- [a] FIPS-validated cryptography is employed to protect the confidentiality of CUI
3.13.12 — Prohibit remote activation of collaborative computing devices and provide indication of devices in use to users present at the device.
- [a] collaborative computing devices are identified
- [b] collaborative computing devices provide indication to users of devices in use
- [c] remote activation of collaborative computing devices is prohibited
3.13.13 — Control and monitor the use of mobile code.
- [a] use of mobile code is controlled
- [b] use of mobile code is monitored
3.13.14 — Control and monitor the use of Voice over Internet Protocol (VoIP) technologies.
- [a] use of Voice over Internet Protocol (VoIP) technologies is controlled
- [b] use of Voice over Internet Protocol (VoIP) technologies is monitored
3.13.15 — Protect the authenticity of communications sessions.
- [a] the authenticity of communications sessions is protected
3.13.16 — Protect the confidentiality of CUI at rest.
- [a] the confidentiality of CUI at rest is protected
3.14 SYSTEM AND INFORMATION INTEGRITY (7 controls, 20 objectives)
3.14.1 — Identify, report, and correct system flaws in a timely manner.
- [a] the time within which to identify system flaws is specified
- [b] system flaws are identified within the specified time frame
- [c] the time within which to report system flaws is specified
- [d] system flaws are reported within the specified time frame
- [e] the time within which to correct system flaws is specified
- [f] system flaws are corrected within the specified time frame
3.14.2 — Provide protection from malicious code at designated locations within organizational systems.
- [a] designated locations for malicious code protection are identified
- [b] protection from malicious code at designated locations is provided
3.14.3 — Monitor system security alerts and advisories and take action in response.
- [a] response actions to system security alerts and advisories are identified
- [b] system security alerts and advisories are monitored
- [c] actions in response to system security alerts and advisories are taken
3.14.4 — Update malicious code protection mechanisms when new releases are available.
- [a] malicious code protection mechanisms are updated when new releases are available
3.14.5 — Perform periodic scans of organizational systems and real-time scans of files from external sources as files are downloaded, opened, or executed.
- [a] the frequency for malicious code scans is defined
- [b] malicious code scans are performed with the defined frequency
- [c] real-time malicious code scans of files from external sources as files are downloaded, opened, or executed are performed
3.14.6 — Monitor organizational systems, including inbound and outbound communications traffic, to detect attacks and indicators of potential attacks.
- [a] the system is monitored to detect attacks and indicators of potential attacks
- [b] inbound communications traffic is monitored to detect attacks and indicators of potential attacks
- [c] outbound communications traffic is monitored to detect attacks and indicators of potential attacks
3.14.7 — Identify unauthorized use of organizational systems.
- [a] authorized use of the system is defined
- [b] unauthorized use of the system is identified
Rev 2 → Rev 3 Control Crosswalk
CMMC 2.0 is Rev 2 only. Rev 3 (Final, May 2024) is the forward horizon. DoD has not adopted Rev 3 for CMMC. Use this section for transition planning and to understand Rev 3 finding language — not as a substitute for Rev 2 assessment evidence.
Verification status: ✅ PDF-verified | 🔵 Training-knowledge (high confidence; verify against the Rev 3 PDF for deliverables)
Summary
| Metric | Rev 2 | Rev 3 |
|---|---|---|
| Control families | 14 | 17 (adds PL, SA, SR) |
| Total requirements | 110 | ~97 (net — many consolidations) |
| Numbering | 3.X.Y | 03.X.Y (leading zeros) |
| Basic / Derived distinction | Yes | Eliminated |
| ODPs (Organization-Defined Parameters) | None | Introduced |
| Family rename | Security Assessment (CA) | "Security Assessment and Monitoring" |
3.1 → 03.01 ACCESS CONTROL ✅
| Rev 2 | Rev 2 title | Rev 3 | Status | Notes |
|---|---|---|---|---|
| 3.1.1 | Limit system access to authorized users/processes/devices | 03.01.01 | Account Management | Massively expanded — 8 parts (a–h) covering full account lifecycle |
| 3.1.2 | Limit access to permitted transactions/functions | 03.01.02 | Access Enforcement | Similar scope, refined |
| 3.1.3 | Control flow of CUI | 03.01.03 | Information Flow Enforcement | Similar scope |
| 3.1.4 | Separate duties | 03.01.04 | Separation of Duties | Slightly narrowed |
| 3.1.5 | Least privilege | 03.01.05 | Least Privilege | Split — privilege rules moved to 03.01.06/07 |
| 3.1.6 | Non-privileged accounts for non-security functions | 03.01.06 | Least Privilege – Privileged Accounts | Carved out from Rev 2 3.1.5 |
| 3.1.7 | Prevent non-privileged execution of privileged functions | 03.01.07 | Least Privilege – Privileged Functions | Carved out |
| 3.1.8 | Limit unsuccessful logon attempts | 03.01.08 | Unsuccessful Logon Attempts | Added ODPs for count and time; selection for response |
| 3.1.9 | Privacy/security notices | 03.01.09 | System Use Notification | Similar |
| 3.1.10 | Session lock | 03.01.10 | Device Lock | Added ODP for inactivity period |
| 3.1.11 | Terminate user session after defined condition | 03.01.11 | Session Termination | Added ODP for triggers |
| 3.1.12 | Monitor and control remote access | 03.01.12 | Remote Access | Consolidated with 3.1.14 and 3.1.15 |
| 3.1.13 | Crypto for remote access confidentiality | 03.01.13 | WITHDRAWN | Addressed by 03.13.08 |
| 3.1.14 | Route remote access via managed access points | 03.01.14 | WITHDRAWN | Into 03.01.12 |
| 3.1.15 | Authorize remote execution of privileged commands | 03.01.15 | WITHDRAWN | Into 03.01.12 |
| 3.1.16 | Authorize wireless access | 03.01.16 | Wireless Access | Consolidated with 3.1.17 |
| 3.1.17 | Protect wireless via authn/encryption | 03.01.17 | WITHDRAWN | Into 03.01.16 |
| 3.1.18 | Control connection of mobile devices | 03.01.18 | Access Control for Mobile Devices | Consolidated with 3.1.19 |
| 3.1.19 | Encrypt CUI on mobile devices | 03.01.19 | WITHDRAWN | Into 03.01.18 |
| 3.1.20 | Verify/control external system connections | 03.01.20 | Use of External Systems | Consolidated with 3.1.21; ODP added |
| 3.1.21 | Limit portable storage on external systems | 03.01.21 | WITHDRAWN | Into 03.01.20 |
| 3.1.22 | Control CUI on publicly accessible systems | 03.01.22 | Publicly Accessible Content | Streamlined |
AC summary: 22 Rev 2 → 13 active Rev 3 (+ 9 withdrawn slots).
3.2 → 03.02 AWARENESS AND TRAINING ✅
| Rev 2 | Rev 2 title | Rev 3 | Status | Notes |
|---|---|---|---|---|
| 3.2.1 | Make users aware of security risks | 03.02.01 | Literacy Training and Awareness | Incorporates 3.2.3; ODPs for frequency/triggers; adds social-engineering topics |
| 3.2.2 | Train personnel for assigned security duties | 03.02.02 | Role-Based Training | Similar; ODPs for frequency/triggers |
| 3.2.3 | Insider threat awareness training | 03.02.03 | WITHDRAWN | Into 03.02.01 |
AT summary: 3 Rev 2 → 2 active Rev 3 (+ 1 withdrawn).
3.3 → 03.03 AUDIT AND ACCOUNTABILITY ✅
| Rev 2 | Rev 2 title | Rev 3 | Status | Notes |
|---|---|---|---|---|
| 3.3.1 | Create and retain audit logs | 03.03.01 + 03.03.03 | Split | Event types/review → 03.03.01; record generation/retention → 03.03.03 |
| 3.3.2 | Trace actions to individual users | 03.03.02 | Audit Record Content | Expanded — 6 required content elements |
| 3.3.3 | Review and update logged events | 03.03.01 | Merged | Into 03.03.01 |
| 3.3.4 | Alert on audit logging process failure | 03.03.04 | Response to Audit Logging Process Failures | ODPs for time period and additional response actions |
| 3.3.5 | Correlate audit record review/analysis | 03.03.05 | Audit Record Review, Analysis, and Reporting | ODP for review frequency |
| 3.3.6 | Record reduction and report generation | 03.03.06 | Audit Record Reduction and Report Generation | Adds requirement to preserve original content and time ordering |
| 3.3.7 | Synchronize internal clocks with authoritative source | 03.03.07 | Time Stamps | Scope changed — focus on UTC-based format and granularity; explicit NTP-sync requirement softened |
| 3.3.8 | Protect audit information and tools | 03.03.08 | Protection of Audit Information | Consolidated with 3.3.9 |
| 3.3.9 | Limit management of audit logging to privileged users | 03.03.09 | WITHDRAWN | Into 03.03.08 |
AU summary: 9 Rev 2 → 8 active Rev 3 (+ 1 withdrawn). Practitioner note on 3.3.7: Rev 3 no longer requires explicit NTP sync with an authoritative source — but for CMMC purposes (Rev 2), NTP sync is still required.
3.4 → 03.04 CONFIGURATION MANAGEMENT 🔵
| Rev 2 | Rev 2 title | Rev 3 | Status | Notes |
|---|---|---|---|---|
| 3.4.1 | Baseline configurations and inventories | 03.04.01 | Baseline Configuration | Simplified — inventory handled separately |
| 3.4.2 | Establish/enforce security configuration settings | 03.04.02 | Configuration Settings | ODP added for settings |
| 3.4.3 | Track/review/approve/log changes | 03.04.03 | Configuration Change Control | Incorporates 3.4.4 (security impact analysis) |
| 3.4.4 | Analyze security impact of changes | 03.04.03 | Merged | Into 03.04.03 |
| 3.4.5 | Physical/logical access restrictions for changes | 03.04.04 | Access Restrictions for Change | Streamlined |
| 3.4.6 | Least functionality | 03.04.05 | Least Functionality | ODP for essential capabilities |
| 3.4.7 | Restrict nonessential programs/functions/ports/protocols/services | 03.04.06 | Nonessential Programs, Functions, Ports, Protocols, and Services | 15 Rev 2 sub-objectives collapsed into a single ODP-driven control |
| 3.4.8 | Deny-by-exception or allow-by-exception software policy | 03.04.07 | Authorized Software | Reframed; ODP for allowed/denied software |
| 3.4.9 | Control and monitor user-installed software | 03.04.08 | User-Installed Software | Retained |
CM summary: 9 Rev 2 → 8 active Rev 3.
3.5 → 03.05 IDENTIFICATION AND AUTHENTICATION 🔵
| Rev 2 | Rev 2 title | Rev 3 | Status | Notes |
|---|---|---|---|---|
| 3.5.1 | Identify users/processes/devices | 03.05.01 | Identification | Similar |
| 3.5.2 | Authenticate identities | 03.05.02 | Authenticator Management | Expanded — full authenticator lifecycle |
| 3.5.3 | MFA for privileged/non-privileged accounts | 03.05.03 | Multi-Factor Authentication | Incorporates 3.5.4; ODP for when MFA is required |
| 3.5.4 | Replay-resistant authentication mechanisms | 03.05.04 | WITHDRAWN | Into 03.05.03 |
| 3.5.5 | Prevent reuse of identifiers | 03.05.05 | Identifier Management | Incorporates 3.5.6 |
| 3.5.6 | Disable identifiers after inactivity | 03.05.06 | WITHDRAWN | Into 03.05.05 |
| 3.5.7 | Password complexity / change of characters | 03.05.07 | Password Management | Consolidates 3.5.7 through 3.5.11 |
| 3.5.8 | Prohibit password reuse | 03.05.08 | WITHDRAWN | Into 03.05.07 |
| 3.5.9 | Temporary password with immediate change | 03.05.09 | WITHDRAWN | Into 03.05.07 |
| 3.5.10 | Cryptographically-protected passwords | 03.05.10 | WITHDRAWN | Into 03.05.07 |
| 3.5.11 | Obscure feedback of authentication info | 03.05.11 | WITHDRAWN | Into 03.05.07 |
IA summary: 11 Rev 2 → 5 active Rev 3 (+ 6 withdrawn). Biggest family consolidation in Rev 3.
3.6 → 03.06 INCIDENT RESPONSE 🔵
| Rev 2 | Rev 2 title | Rev 3 | Status | Notes |
|---|---|---|---|---|
| 3.6.1 | Operational incident-handling capability | 03.06.01 | Incident Handling | IR phases retained |
| 3.6.2 | Track, document, report incidents | 03.06.02 | Incident Monitoring, Reporting, Response Planning | Adds formal IR plan requirement |
| 3.6.3 | Test incident response capability | 03.06.03 | Incident Response Testing | ODP for testing frequency |
IR summary: 3 → 3, no withdrawals.
3.7 → 03.07 MAINTENANCE 🔵
| Rev 2 | Rev 2 title | Rev 3 | Status | Notes |
|---|---|---|---|---|
| 3.7.1 | Perform maintenance | 03.07.01 | Controlled Maintenance | Incorporates 3.7.2 |
| 3.7.2 | Controls on maintenance tools/techniques/personnel | 03.07.02 | WITHDRAWN | Into 03.07.01 |
| 3.7.3 | Sanitize off-site maintenance equipment | 03.07.02 | Maintenance Tools | Renumbered; sanitization retained |
| 3.7.4 | Check diagnostic/test media for malicious code | 03.07.03 | (Nonlocal Maintenance / Media Check) | ODP added |
| 3.7.5 | MFA for nonlocal maintenance via external connections | 03.07.04 | Nonlocal Maintenance | MFA retained; ODP for authentication mechanisms |
| 3.7.6 | Supervise unauthorized maintenance personnel | 03.07.05 | Maintenance Personnel | Similar |
MA summary: 6 → 5 active (+ 1 withdrawn).
3.8 → 03.08 MEDIA PROTECTION 🔵
| Rev 2 | Rev 2 title | Rev 3 | Status | Notes |
|---|---|---|---|---|
| 3.8.1 | Protect media containing CUI | 03.08.01 | Media Protection | Incorporates 3.8.2 |
| 3.8.2 | Limit access to CUI on media | 03.08.02 | WITHDRAWN | Into 03.08.01 |
| 3.8.3 | Sanitize/destroy media before disposal/reuse | 03.08.02 | Media Sanitization | Renumbered; ODP for sanitization methods |
| 3.8.4 | Mark media with CUI markings and distribution limits | 03.08.03 | Media Marking | Similar |
| 3.8.5 | Control access to media and accountability during transport | 03.08.04 | Media Transport | ODP for protection during transport |
| 3.8.6 | Crypto for CUI on digital media during transport | 03.08.05 | WITHDRAWN | Addressed by 03.13.08 |
| 3.8.7 | Control use of removable media | 03.08.05 | Media Use | Renumbered; ODP for restrictions |
| 3.8.8 | Prohibit portable storage without identifiable owner | 03.08.06 | WITHDRAWN | Into 03.08.05 |
| 3.8.9 | Protect confidentiality of backup CUI | 03.08.06 | Media Downgrading | Reframed |
MP summary: 9 → 6 active (+ 3 withdrawn). Key change: transport-encryption requirement moves to SC family (03.13.08).
3.9 → 03.09 PERSONNEL SECURITY 🔵
| Rev 2 | Rev 2 title | Rev 3 | Status | Notes |
|---|---|---|---|---|
| 3.9.1 | Screen individuals before authorizing access | 03.09.01 | Personnel Screening | ODP for screening criteria |
| 3.9.2 | Protect systems during/after personnel actions | 03.09.02 | Personnel Termination and Transfer | Explicit about both termination and transfer |
PS summary: 2 → 2, no withdrawals.
3.10 → 03.10 PHYSICAL PROTECTION 🔵
| Rev 2 | Rev 2 title | Rev 3 | Status | Notes |
|---|---|---|---|---|
| 3.10.1 | Limit physical access to authorized individuals | 03.10.01 | Physical Access Authorizations | Authorization process now explicit |
| 3.10.2 | Protect and monitor physical facility/infrastructure | 03.10.02 | Physical Access Control | Monitoring split into separate concern |
| 3.10.3 | Escort visitors / monitor activity | 03.10.03 | Visitor Control | ODP for visitor log retention |
| 3.10.4 | Maintain audit logs of physical access | 03.10.04 | (Within broader physical access controls — verify) | Reorganized |
| 3.10.5 | Control and manage physical access devices | 03.10.05 | Physical Access Devices | ODP for inventory frequency |
| 3.10.6 | Safeguarding measures for CUI at alternate work sites | 03.10.06 | Alternate Work Sites | Adds compromise detection requirement |
PE summary: 6 → 6, no withdrawals (reorganized within family).
3.11 → 03.11 RISK ASSESSMENT 🔵
| Rev 2 | Rev 2 title | Rev 3 | Status | Notes |
|---|---|---|---|---|
| 3.11.1 | Periodically assess risk | 03.11.01 | Risk Assessment | ODP for frequency; documents results |
| 3.11.2 | Scan for vulnerabilities | 03.11.02 | Vulnerability Monitoring and Scanning | Expanded; ODPs for scan frequency, tools, techniques; remediation tracking added |
| 3.11.3 | Remediate vulnerabilities | 03.11.03 | Vulnerability Remediation | ODP for remediation timeframes by severity |
RA summary: 3 → 3, no withdrawals.
3.12 → 03.12 SECURITY ASSESSMENT AND MONITORING 🔵
(Renamed from "Security Assessment" in Rev 2.)
| Rev 2 | Rev 2 title | Rev 3 | Status | Notes |
|---|---|---|---|---|
| 3.12.1 | Assess effectiveness of security controls | 03.12.01 | Security Assessments | ODP for frequency; more explicit scope |
| 3.12.2 | POA&M development and implementation | 03.12.02 | Plan of Action and Milestones | ODP for POA&M update frequency |
| 3.12.3 | Monitor security controls on ongoing basis | 03.12.03 | Continuous Monitoring | Expanded — monitoring strategy/program/frequency now explicit |
| 3.12.4 | SSP development, documentation, periodic update | Moved | → 03.15.02 (Planning family) | SSP requirement relocated to new PL family |
CA summary: 4 → 3 active in the CA family; SSP requirement migrated to the new PL family.
3.13 → 03.13 SYSTEM AND COMMUNICATIONS PROTECTION 🔵
| Rev 2 | Rev 2 title | Rev 3 | Status | Notes |
|---|---|---|---|---|
| 3.13.1 | Monitor/control/protect communications at boundaries | 03.13.01 | Boundary Protection | ODP for external/key internal boundaries |
| 3.13.2 | Architectural designs, software dev techniques, systems eng | 03.13.02 | Security Engineering Principles | Similar |
| 3.13.3 | Separate user and system management functionality | 03.13.03 | Security Function Isolation | Similar |
| 3.13.4 | Prevent unauthorized info transfer via shared resources | 03.13.04 | (Reframed) | May be combined/reframed in Rev 3 |
| 3.13.5 | Subnetworks for publicly accessible components | 03.13.05 | Boundary Protection – Publicly Accessible Systems | Similar |
| 3.13.6 | Deny network communications by default | 03.13.06 | Deny by Default | Similar |
| 3.13.7 | Prevent split tunneling | 03.13.07 | Boundary Protection – Split Tunneling | Similar |
| 3.13.8 | Crypto to prevent unauthorized disclosure during transmission | 03.13.08 | Cryptographic Protection | Consolidation target — 3.1.13 and 3.8.6 point here |
| 3.13.9 | Terminate network connections after inactivity | 03.13.09 | Network Disconnect | ODP for inactivity period |
| 3.13.10 | Establish/manage cryptographic keys | 03.13.10 | Cryptographic Key Management | Similar |
| 3.13.11 | Employ FIPS-validated cryptography for CUI | 03.13.11 | Cryptographic Protection – FIPS | Changed — Rev 3 uses ODP "organization-defined types of cryptography." For CMMC purposes, FIPS 140-2/140-3 validation is still the operational expectation. Do not advise clients that Rev 3 weakens this. |
| 3.13.12 | Prohibit remote activation of collaborative computing devices | 03.13.12 | Collaborative Computing Devices and Applications | ODP for authorized exceptions |
| 3.13.13 | Control and monitor mobile code | 03.13.13 | Mobile Code | ODP for mobile code technologies |
| 3.13.14 | Control and monitor VoIP | 03.13.14 | Voice Over IP Technologies | ODP for VoIP technologies |
| 3.13.15 | Protect authenticity of communications sessions | 03.13.15 | Communications Authenticity | Similar |
| 3.13.16 | Protect confidentiality of CUI at rest | 03.13.16 | CUI at Rest | ODP for types of cryptography |
SC summary: 16 → 16, no withdrawals.
3.14 → 03.14 SYSTEM AND INFORMATION INTEGRITY 🔵
| Rev 2 | Rev 2 title | Rev 3 | Status | Notes |
|---|---|---|---|---|
| 3.14.1 | Identify, report, correct system flaws | 03.14.01 | Flaw Remediation | ODP for remediation timeframes by severity |
| 3.14.2 | Malicious code protection at designated locations | 03.14.02 | Malicious Code Protection | ODP for mechanisms and locations |
| 3.14.3 | Monitor security alerts/advisories and take action | 03.14.03 | Security Alerts, Advisories, and Directives | Requires internal dissemination |
| 3.14.4 | Update malicious code protection on new releases | 03.14.04 | WITHDRAWN | Into 03.14.02 |
| 3.14.5 | Periodic and real-time scans | 03.14.04 | Malicious Code Protection – Scans | Renumbered |
| 3.14.6 | Monitor inbound/outbound traffic for attacks | 03.14.05 | System Monitoring | Expanded; ODP for monitoring activities |
| 3.14.7 | Identify unauthorized use of systems | 03.14.06 | System Monitoring – Unauthorized Use | Possibly incorporated into 03.14.05 |
SI summary: 7 → 6 active (+ 1 withdrawn).
New Families in Rev 3 (No Rev 2 Equivalent)
03.15 PLANNING (PL) — NEW 🔵
Picks up planning requirements that were implicit or in other Rev 2 families.
| Rev 3 | Title | Origin |
|---|---|---|
| 03.15.01 | Policy and Procedures | New — formerly NFO (XX-1 type) controls that were excluded from Rev 2 |
| 03.15.02 | System Security Plan | From Rev 2 3.12.4 — relocated from CA family |
| 03.15.03 | Rules of Behavior | New — system use rules for users |
| 03.15.04 | (Additional planning requirements) | New additions from 800-53B moderate baseline |
Practitioner note: SSP migration from 3.12.4 → 03.15.02 means Rev 3 assessors will look at the SSP as a planning artifact, not a security assessment artifact. SSP content requirements are retained and expanded.
03.16 SYSTEM AND SERVICES ACQUISITION (SA) — NEW 🔵
Requirements for secure acquisition of systems, components, and services.
| Rev 3 | Title | Notes |
|---|---|---|
| 03.16.01 | Security Engineering Principles for Development | Software/system development security |
| 03.16.02 | Unsupported System Components | EOL/unsupported software management |
| 03.16.03 | External System Services | Contracts/agreements with cloud/MSP providers — related to Rev 2 3.1.20 |
| 03.16.04 | (Additional SA requirements) | Acquisition documentation, security requirements in contracts |
Practitioner note: 03.16.03 is particularly relevant for clients using cloud providers — it requires verifying that service providers implement required controls. Formalizes what was implied in Rev 2 3.1.20.
03.17 SUPPLY CHAIN RISK MANAGEMENT (SR) — NEW 🔵
| Rev 3 | Title | Notes |
|---|---|---|
| 03.17.01 | Supply Chain Risk Management Plan | Develop and maintain SCRM plan |
| 03.17.02 | Acquisition Strategies, Tools, and Methods | Address supply chain risks during acquisition |
| 03.17.03 | Supplier Reviews | Assess suppliers/vendors providing system components |
Practitioner note: Entirely new for nonfederal contractors. CMMC 2.0 (Rev 2-based) has no SR family. When/if CMMC adopts Rev 3, SCRM becomes a new assessment domain — notable for clients with complex vendor ecosystems.
Quick Reference: Withdrawn Rev 2 Controls
| Rev 2 Control | Disposition in Rev 3 |
|---|---|
| 3.1.13 | 03.01.13 WITHDRAWN — addressed by 03.13.08 |
| 3.1.14 | 03.01.14 WITHDRAWN — into 03.01.12 |
| 3.1.15 | 03.01.15 WITHDRAWN — into 03.01.12 |
| 3.1.17 | 03.01.17 WITHDRAWN — into 03.01.16 |
| 3.1.19 | 03.01.19 WITHDRAWN — into 03.01.18 |
| 3.1.21 | 03.01.21 WITHDRAWN — into 03.01.20 |
| 3.2.3 | 03.02.03 WITHDRAWN — into 03.02.01 |
| 3.3.3 | Merged into 03.03.01 (no "withdrawn" slot) |
| 3.3.9 | 03.03.09 WITHDRAWN — into 03.03.08 |
| 3.4.4 | Merged into 03.04.03 (no "withdrawn" slot) |
| 3.5.4 | 03.05.04 WITHDRAWN — into 03.05.03 |
| 3.5.6 | 03.05.06 WITHDRAWN — into 03.05.05 |
| 3.5.8 | 03.05.08 WITHDRAWN — into 03.05.07 |
| 3.5.9 | 03.05.09 WITHDRAWN — into 03.05.07 |
| 3.5.10 | 03.05.10 WITHDRAWN — into 03.05.07 |
| 3.5.11 | 03.05.11 WITHDRAWN — into 03.05.07 |
| 3.7.2 | 03.07.02 WITHDRAWN — into 03.07.01 |
| 3.8.2 | 03.08.02 WITHDRAWN — into 03.08.01 |
| 3.8.6 | 03.08.06 WITHDRAWN — addressed by 03.13.08 |
| 3.8.8 | 03.08.08 WITHDRAWN — into 03.08.07 |
| 3.12.4 | Relocated to 03.15.02 (PL family) |
| 3.14.4 | 03.14.04 WITHDRAWN — into 03.14.02 |
ODPs — Organization-Defined Parameters (Rev 3 concept)
Rev 3 introduces ODPs — values that the organization (or contracting federal agency) must define. Once defined, they become assessable scope. Common categories:
- Time periods — inactivity timeouts, audit-failure response windows, scan frequency.
- Roles/personnel — who is authorized for privileged accounts, who responds to logon-attempt thresholds.
- Technical parameters — number of invalid logon attempts allowed, configuration settings, types of cryptography.
- Security requirements — those imposed on external systems, prohibited services/ports/protocols.
Pre-adoption planning for clients:
- Stand up an ODP register (separate document or SSP appendix).
- Get management approval for each value.
- Implement controls using those defined values.
- Be ready to be assessed against the values you stated — they become binding.
If the contracting agency specifies ODP values via contract or policy, those govern. Otherwise the contractor defines its own.
Rev 2 vs. Rev 3 — Which Applies Right Now
As of 2026-05-17:
- CMMC 2.0 assessments → Rev 2 only. All 110 Rev 2 controls and 320 assessment objectives apply.
- DFARS 252.204-7012 requires Rev 2 compliance. No DoD contract language has adopted Rev 3.
- SPRS scoring uses the 110-point Rev 2 framework.
- C3PAO assessments assess against Rev 2 practices (CMMC Level 2 = 110 practices).
Forward planning:
- DoD has not announced a CMMC adoption timeline for Rev 3.
- When adopted, control count drops from 110 to ~97, but the addition of PL/SA/SR families likely increases total requirement counts.
- ODP values become assessable scope.
- Clients implementing MFA via platform tools (Entra ID, Okta) benefit from IA consolidation (one implementation, one control).
Reverse-Mapping (Rev 3 finding → Rev 2 impact)
When a Rev 3 finding references a specific control, map back to Rev 2 to understand CMMC impact:
| If Rev 3 finds an issue with... | Check Rev 2 controls... |
|---|---|
| 03.01.01 Account Management | 3.1.1, 3.1.2 |
| 03.01.12 Remote Access | 3.1.12, 3.1.14, 3.1.15 |
| 03.01.16 Wireless Access | 3.1.16, 3.1.17 |
| 03.01.18 Mobile Device AC | 3.1.18, 3.1.19 |
| 03.01.20 External Systems | 3.1.20, 3.1.21 |
| 03.02.01 Literacy Training | 3.2.1, 3.2.3 |
| 03.03.01 Event Logging | 3.3.1 (partial), 3.3.3 |
| 03.03.08 Audit Protection | 3.3.8, 3.3.9 |
| 03.05.03 MFA | 3.5.3, 3.5.4 |
| 03.05.07 Password Management | 3.5.7, 3.5.8, 3.5.9, 3.5.10, 3.5.11 |
| 03.13.08 Cryptographic Protection | 3.1.13, 3.8.6, 3.13.8 |
| 03.15.02 System Security Plan | 3.12.4 |
Key Risk: Clients Who Know Rev 3 But Aren't Rev 2 Ready
Some clients have implemented Rev 3-style controls and believe they're covered. Rev 2 has specific requirements that Rev 3 softened with ODPs — for current CMMC assessments, the Rev 2 language governs:
- 3.3.7 (clock sync) — Rev 2 requires NTP sync with an authoritative source; Rev 3 softened. NTP sync is required for CMMC.
- 3.4.8 (allow/deny software) — Rev 2 requires an explicit policy choice and implementation. "We'll define an ODP later" does not satisfy Rev 2.
- 3.5.3 (MFA) — Rev 2 requires MFA for network access to non-privileged accounts. No ODP wiggle room in Rev 2.
- 3.13.11 (FIPS crypto) — Rev 2 says "FIPS-validated", flat. Rev 3 uses an ODP. For CMMC, FIPS 140-2/140-3 validation is mandatory.
High-Complexity Controls (Assessment Effort Indicators)
Controls with 5+ assessment objectives drive the bulk of assessment effort and evidence burden:
| Control | Objectives | Key evidence focus |
|---|---|---|
| 3.4.7 | 15 | Port/protocol/service documentation (most objectives of any control) |
| 3.13.1 | 8 | Network boundary definition + monitoring/control/protection |
| 3.4.5 | 8 | Change control access restrictions (physical AND logical) |
| 3.12.4 | 8 | SSP completeness (boundary, environment, connections, update freq) |
| 3.6.1 | 7 | IRP covering all IR phases |
| 3.6.2 | 6 | Incident reporting chain (internal + external) |
| 3.1.1 | 6 | User/device/process inventory + access restrictions |
| 3.1.20 | 6 | External system agreements + connection controls |
| 3.3.1 | 6 | Audit log configuration + retention policy |
| 3.3.8 | 6 | Log protection controls |
| 3.4.1 | 6 | Baseline config + asset inventory |
| 3.13.2 | 6 | Secure architecture documentation |
| 3.14.1 | 6 | Flaw ID/report/correct with defined timeframes |
| 3.1.3 | 5 | Data flow diagrams + flow enforcement |
| 3.1.22 | 5 | Public web content review process |
Common POA&M Objective-Split Patterns
When clients have partial implementations, these objectives are typically split across a POA&M (some Satisfied, some Other Than Satisfied — assuming the practice is POA&M-eligible per cmmc-expert §11):
- 3.4.7: Often
[a]–[f]Satisfied (programs/functions);[g]–[o](ports/protocols/services) on POA&M. - 3.3.1: Often
[a]–[d]Satisfied (log creation/content);[e]–[f](retention) on POA&M. - 3.5.3: Often
[b]–[c]Satisfied (MFA on privileged);[d](network MFA for non-privileged) on POA&M. - 3.12.4: Often
[a]–[c]Satisfied (SSP exists);[d]–[h](specific elements) on POA&M. - 3.1.12: Often
[a]–[b]Satisfied (types defined);[c]–[d](active monitoring) on POA&M.
For POA&M eligibility rules, point weights, and the 180-day window, see cmmc-expert §10–§11.
Authoritative Sources
- NIST SP 800-171A (June 2018) — assessment procedures for 800-171 Rev 2 (this skill's primary source).
- NIST SP 800-171 Rev 2 — https://doi.org/10.6028/NIST.SP.800-171r2
- NIST SP 800-171 Rev 3 (Final, May 2024) — forward horizon; source of the crosswalk.
- NIST SP 800-171A Rev 3 — assessment procedures for Rev 3 (consult directly for Rev 3 AO-level language).
- NIST SP 800-53B — parent moderate baseline that informed Rev 3 expansions.
- 32 CFR Part 170 — CMMC program rule.
- DFARS 252.204-7012 / -7019 / -7020 / -7021 / -7025 — contract clauses.
- CMMC Assessment Guide — Level 2 (current version on dodcio.defense.gov).
- CMMC Scoping Guide — Level 2.
- CMMC Scoring Methodology.
Primary locations: dodcio.defense.gov/CMMC/, cyber.mil, cyberab.org, sprs.csd.disa.mil.
Capabilities
This skill supports:
- Looking up the verbatim text of any Rev 2 assessment objective by ID (e.g.,
3.1.1[c],3.13.11[a]) - Counting and listing AOs per family for assessment planning
- Determining what evidence types support a given AO (via Examine/Interview/Test method mapping)
- Mapping any Rev 2 control to its Rev 3 equivalent (or noting that it was withdrawn / merged)
- Identifying which Rev 2 controls are gone in Rev 3 and where their content lives now
- Distinguishing Rev 3 ODP-driven language from Rev 2 hard requirements
- Reverse-mapping a Rev 3 finding to its Rev 2 impact on a current CMMC assessment
- Identifying high-complexity controls for assessment scoping
- Spotting common objective-split POA&M patterns
For program-level CMMC topics — SPRS scoring, POA&M rules, scoping, ESP/CSP, C3PAO lifecycle, annual affirmation, False Claims Act risk — use the cmmc-expert skill instead.