CMMC Levels 1-3: What You Need to Know

The Cybersecurity Maturity Model Certification (CMMC) is a certification process created by the Department of Defense (DoD) that creates unified standards for cybersecurity implementation for all businesses that are a part of the Defense Industrial Base (DIB) Supply Chain.

The CMMC model outlines cybersecurity best practices into Five Maturity Levels. Each set has its own set of practices and processes ranging from basic cyber hygiene in Level 1 to Level 5’s advanced/progressive capabilities.

In today’s article, we will be discussing Level’s 1-3.

What is CMMC Level 1?

CMMC Level 1 is the foundation of the Cybersecurity Maturity Model Certification and is the lowest level of security controls a DoD contractor can possess to receive a certification. Level 1 is the starting point for DoD contractors and is the bare minimum cybersecurity hygiene required to protect Federal Contract Information.

CMMC Level 1 does not address security process maturity. Consequently, at Level 1, an organization’s Cybersecurity Maturity Processes are limited or inconsistent. Level 1 provides only rudimentary protection against data theft and harmful behavior.

Why It Is Important to Start with Level 1?

The CMMC certification process is a step-by-step procedure, with each level building on the previous one. This means regardless of which CMMC Level a DoD contractor requires; they must first achieve basic cyber hygiene as described in Level 1. If obtaining CMMC compliance were linked to constructing a house, the concrete foundation, plumbing, and electrical wiring would be Level 1. The remaining higher levels would be impossible to achieve until these fundamentals are in place.

By 2026, all DoD contractors must obtain a Cybersecurity Maturity Model Certification (CMMC), making CMMC Level 1’s security foundations an essential for all DoD contractors.

What are the Requirements of CMMC Level 1?

To achieve CMMC Level 1, Defense Contractors must show basic cyber hygiene with all 17 controls of the Federal Acquisition Regulation (FAR) 52.204-21. The following is a breakdown of those 17 controls.

CMMC Level 1 Controls

Access Control (AC)

• AC.1.001:
  • Limit information system access to authorized users, processes acting on behalf of authorized users, or devices (including other information systems).
• AC.1.002:
  • Limit information system access to the types of transactions and functions that authorized users are permitted to execute.
• AC.1.003:
  • Verify and control/limit connections to and use of external information systems.
• AC.1.004:
  • Control information posted or processed on publicly accessible information systems.

Identification and Authentication (IA)

• IA.1.076:
  • Identify information system users, processes acting on behalf of users, or devices.
• IA.1.077:
  • Authenticate (or verify) the identities of those users, processes, or devices, as a prerequisite to allowing access to organizational information systems.

Media Protection (MP)

• MP.1.118:
  • Sanitize or destroy information system media containing Federal Contract Information before disposal or release for reuse.

Physical Protection (PP)

• PP.1.131:
  • Limit physical access to organizational information systems, equipment, and the respective operating environments to authorized individuals.
• PP.1.132:
  • Escort visitors and monitor visitor activity.
• PP.1.133:
  • Maintain audit logs of physical access devices.
• PP.1.134:
  • Control and manage physical access devices.

System and Communications Protection (SC)

• SC.1.175:
  • Monitor, control, and protect organizational communications (i.e., information transmitted or received by organizational information systems) at the external boundaries and key internal boundaries of the information systems.
• SC.1.176:
  • Implement subnetworks for publicly accessible system components that are physically or logically separated from internal networks.

System and Information Integrity (SI)

• SI.1.210:
  • Identify, report, and correct information and information system flaws in a timely manner.
• SI.1.211:
  • Provide protection from malicious code at appropriate locations within organizational information systems.
• SI.1.212:
  • Update malicious code protection mechanisms when new releases are available.
• SI.1.213:
  • Perform periodic scans of the information system and real-time scans of files from external sources as files are downloaded, opened, or executed.

What is CMMC Level 2?

CMMC Level 2 is a small, but significant step forward for DoD contractors. Level 2’s, intermediate cyber hygiene practices provide a natural but essential path for organizations to move from Level 1 to Level 3. Level 2 outlines protections necessary for Controlled Unclassified Information (CUI) in addition to Federal Contract Information (FCI). The extra practices presented in Level 2 create a stronger security posture that can combat more hazardous threats.

The process maturity steps of CMMC is also introduced in Level 2. DoD contractors are expected to conduct and record important cybersecurity functions at CMMC Level 2.

What are the Requirements of CMMC Level 2?

In addition to all Level 1 requirements, CMMC Level 2 introduces 55 new practices for a total of 72 controls. The following is a breakdown of those 55 new controls.

CMMC Level 2 Controls

Access Control (AC)

• AC.2.005:
  • Provide privacy and security notices consistent with applicable CUI rules.
• AC.2.006:
  •  Limit use of portable storage devices on external systems.
• AC.2.007:
  • Employ the principle of least privilege, including for specific security functions and privileged accounts.
• AC.2.008:
  • Use non-privileged accounts or roles when accessing nonsecurity functions.
• AC.2.009:
  • Limit unsuccessful logon attempts.
• AC.2.010:
  • Use session lock with pattern-hiding displays to prevent access and viewing of data after a period of inactivity.
• AC.2.011:
  • Authorize wireless access priority to allowing such connections.
• AC.2.013:
  • Monitor and control remote access sessions.
• AC.2.015:
  • Route remote access via managed access control points.
• AC.2.016:
  • Control the flow of CUI in accordance with approved authorization.

Awareness Training (AT)

• AT.2.056:
  • Ensure that managers, system administrators, and users of organizational systems are made aware of the security risks associated with their activities and of the applicable policies, standards, and procedures related to the security of those systems.
• AT.2.057:
  • Ensure that personnel are trained to carry out their assigned information security-related duties and responsibilities.

Audit and Accountability (AU)

• AU.2.041:
  • Ensure the actions of individual system users can be uniquely traced to those users so they can be held accountable for their actions.
• AU.2.042:
  • 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.
• AU.2.043:
  • Provide a system capability that compares and synchronizes internal system clocks with an authoritative source to generate time stamps for audit records.
• AU.2.044:
  • Review audit logs.

Configuration Management (CM)

• CM.2.061:
  • Establish and maintain baseline configurations and inventories of organizational systems (including hardware, software, firmware, and documentation) throughout the respective system development cycle.
• CM.2.062:
  • Employ the principles of least functionality by configurating organizational systems to provide only essential capabilities.
• CM.2.063:
  • Control and monitor user-installed software.
• CM.2.064:
  • Establish and enforce security configuration settings for information technology products employed in organizational systems.
• CM.2.065:
  • Track, review, approve, or disapprove, and log changes to organizational systems.
• CM.2.066:
  • Analyze the security impact of changes prior to implementation.

Identification and Authentication (IA)

• IA.2.078:
  • Enforce a minimum password complexity and change of characters when new passwords are created.
• IA.2.079:
  • Prohibit password reuse for a specified number of generations.
• IA.2.080:
  • Allow temporary password use for system logons with an immediate change to a permanent password.
• IA.2.081:
  • Store and transmit only cryptographically protected passwords.
• IA.2.082:
  • Obscure feedback of authentication information.

Incident Response (IR)

• IR.2.092:
  • Establish an operational incident-handling capability for organizational systems that includes preparation, detection, analysis, containment, recovery, and user response activities.
• IR.2.093:
  • Detect and report events.
• IR.2.094:
  • Analyze and triage events to support event resolution and incident declaration.
• IR.2.096:
  • Develop and implement responses to declared incidents according to pre-defined procedures.
• IR.2.097:
  • Perform root cause analysis on incidents to determine underlying causes.

Maintenance (MA)

• MA.2.111:
  • Perform maintenance on organizational systems.
• MA.2.112:
  • Provide controls on the tools, techniques, mechanisms, and personnel used to conduct system maintenance.
• MA.2.113:
  • Require multifactor authentication to establish nonlocal maintenance sessions via external network connections and terminate such connections when nonlocal maintenance is complete.
• MA.2.114:
  • Supervise maintenance activities of personnel without required access authorization.

Media Protection (MP)

• MP.2.119:
  • Protect (i.e. physically control and securely store) system media containing CUI, both paper and digital.
• MP.2.120:
  • Limit access to CUI on system media to authorized users.
• MP.2.121:
  • Control the use of removable media on system components.

Physical Protection (PE)

• PE.2.135:
  • Protect and monitor the physical facility and support infrastructure for organizational systems.

Personnel Security (PS)

• PS.2.127:
  • Screen carefully all individuals who are provided access to organizational systems containing CUI – this screening process is independent of other such tests.
• PS.2.128:
  • Ensure protection of systems containing CUI during important transitional events relative to personnel, including but not limited to transfers and terminations.

Recovery (RE)

• RE.2.137:
  • Regularly perform and test data back-ups.
• RE.2.138:
  • Protect the confidentiality of backup CUI at storage locations.

Risk Management (RM)

• RM.2.141:
  • Periodically assess the risk to organizational operations (including missions, functions, image, or reputation), organizational assets, and individuals, resulting from operation of organizational systems and the associated processing, storage, or transmission of CUI.
• RM.2.142:
  • Scan for vulnerabilities in organizational systems and applications periodically and when new vulnerabilities affecting those systems and applications are identified.
• RM.2.143:
  • Remediate vulnerabilities in accordance with risk assessments.

Security Assessment (CA)

• CA.2.157:
  • Develop and regularly update security plans describing in detail the parameters of systems protected and relevant logistics, including:
    • Boundaries of information systems
    • Systems’ environments of operation
    • Security implementations and requirements
    • Relationships and connections between systems
  • CA.2.158:
    • Assess controls across systems periodically, determining efficacy.
  • CA.2.159:
    • Develop and deploy plans to correct and improve any weaknesses, deficiencies, vulnerabilities, or other system security issues identified.

Systems and Communications Protection (SC)

• SC.2.178:
  • Prohibit remote activation of collaborative computing devices and provide indication of devices in use to users present at the device.
• SC.2.179:
  • Use encrypted sessions for the management of network devices.

System and Information Integrity (SI)

• SI.2.214:
  • Monitor system security alerts and advisories and take action in response.
• SI.2.216:
  • Monitor organizational systems, including inbound and outbound communications traffic, to detect attacks and indicators of potential attacks.
• SI.2.217:
  • Identify unauthorized use of organizational systems.

What is CMMC Level 3?

CMMC Level 3 is referred to as “excellent cyber hygiene.” It incorporates all the requirements from Levels 1 and 2, as well as new ones related to planning, sourcing, and reviewing your security policies and procedures.

Level 3 of the Cybersecurity Maturity Model Certification (CMMC) improves on Level 2 by including Federal Acquisition Regulation (FAR) practices and NIST SP 800-171 Rev 1 controls. It also includes 20 other key cyber hygiene measures. The need to plan and manage cybersecurity activities are emphasized at this level.

While CMMC Level 3 shows strong cyber hygiene, it falls short of higher levels. Even if a business is CMMC Level 3 certified, advanced persistent threats (APTs) might be difficult to defend.

How Does Level 3 Compare to Level 2?

The most notable distinction between CMMC Level 2 and Level 3 is the maturity process of both levels, also known as continuous security management.

Defense contractors are obligated to establish policies, methods, and a plan to apply the required security features at Level 2. Level 3 goes a step further by requiring a thorough assessment of existing rules and practices, as well as dedicated resources to accomplish the specified goal and objectives.

These added safeguards help to ensure that security solutions are properly integrated and completely functional. Obtaining level 3 accreditation signifies that your organization has adopted and is actively monitoring the required solutions.

What are the Requirements of CMMC Level 3?

In comparison to Levels 1 and 2, CMMC Level 3 accreditation adds 58 new controls for a total of 130 processes. Let’s have a look at what each of these controls are.

CMMC Level 3 Controls

Access Control (AC)

• AC.3.012:
  • Protect wireless access using authentication and encryption.
• AC.3.014:
  • Employ cryptographic mechanisms to protect the confidentiality of remote access sessions.
• AC.3.017:
  • Separate the duties of individuals to reduce the risk of malevolent activity without collusion.
• AC.3.018:
  • Prevent non-privileged users from executing privileged functions and capture the execution of such functions in audit logs.
• AC.3.019:
  • Terminate (automatically) user sessions after a defined condition.
• AC.3.020:
  • Control connection of mobile devices.
• AC.3.021:
  • Authorize remote execution of privileged commands and remote access to security-relevant information.
• AC.3.022:
  • Encrypt CUI on mobile devices and mobile computing platforms.

Asset Management (AM)

• AM.3.036:
  • Define procedures for the handling of CUI data.

Awareness and Training Practices (AT)

• AT.3.058:
  • Provide security awareness training on recognizing and reporting potential indicators of insider threats.

Audit and Accountability Practices (AU)

• AU.3.045:
  • Review and update logged events.
• AU.3.046:
  • Alert in the event of an audit logging process failure.
• AU.3.048:
  • Collect audit information (e.g. logs) into one or more central repositories.
• AU.3.049:
  • Protect audit information and audit logging tools from unauthorized access, modification, and deletion.
• AU.3.050:
  • Limit management of audit logging functionality to a subset of privileged users.
• AU.3.051:
  • Correlate audit record review, analysis, and reporting processes for investigation and response to indications of unlawful, unauthorized, suspicious, or unusual activity.
• AU.3.052:
  • Provide audit record reduction and report generation to support on-demand analysis and reporting.

Security Assessment Practices (CA)

• CA.3.161:
  • Monitor security controls on an ongoing basis to ensure the continued effectiveness of the controls.
• CA.3.162:
  • Employ a security assessment of enterprise software that has been developed internally, for internal use, and that has been organizationally defined as an area of risk.

Configuration Management (CM)

• CM.3.067:
  • Define, document, approve, and enforce physical and logical access restrictions associated with changes to organizational systems.
• CM.3.068:
  • Restrict, disable, or prevent the use of nonessential programs, functions, ports, protocols, and services.
• CM.3.069:
  • 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.

Identification and Authentication Practices (IA)

• IA.3.083:
  • Use multifactor authentication for local and network access to privileged accounts and for network access to non-privileged accounts.
• IA.3.084:
  • Employ replay-resistant authentication mechanisms for network access to privileged and non-privileged accounts.
• IA.3.085:
  • Prevent the reuse of identifiers for a defined period.
• IA.3.086:
  • Disable identifiers after a defined period of inactivity.

Incident Response (IR)

• IR.3.098:
  • Track, document, and report incidents to designated officials and/or authorities both internal and external to the organization.
• IR.3.099:
  • Test the organizational incident response capability.

Maintenance Practices (MA)

• MA.3.115:
  • Supervise the maintenance activities of personnel without required access authorization.
• MA.3.116:
  • Check media containing diagnostic and test programs for malicious code before the media are used in organizational systems.

Media Protections (MP)

• MP.3.122:
  • Mark media with necessary CUI markings and distribution limitations.
• MP.3.123:
  • Prohibit the use of portable storage devices when such devices have no identifiable owner.
• MP.3.124:
  • Control access to media containing CUI and maintain accountability for media during transport outside of controlled areas.
• MP.3.125:
  • Implement cryptographic mechanisms to protect the confidentiality of CUI stored on digital media during transport unless otherwise protected by alternative physical safeguards.

Physical Protections (PE)

• PE.3.136:
  • Enforce safeguarding measures for CUI at alternate work sites.

Recovery Practice (RE)

• RE.3.139:
  • Regularly perform complete, comprehensive, and resilient data backups as organizationally defined.

Risk Management (RM)

• RM.3.144:
  • Periodically perform risk assessments to identify and prioritize risks according to the defined risk categories, risk sources, and risk measurement criteria.
• RM.3.146:
  • Develop and implement risk mitigation plans.
• RM.3.147:
  • Manage non-vendor support products (e.g. End of life) separately and restrict as necessary to reduce risk.

Situational Awareness (SA)

• SA.3.169:
  • Receive and respond to cyber threat intelligence from information sharing forums and sources and communicate to stakeholders.

System and Communications Protection (SC)

• SC.3.177:
  • Employs FIPS-validated cryptography when used to protect the confidentiality of CUI.
• SC.3.180:
  • Employ architectural designs, software development techniques, and systems engineering principles that promote effective information security within organizational systems.
• SC.3.181:
  • Separate user functionality from system management functionality.
• SC.3.182:
  • Prevent unauthorized and unintended information to transfer via shared system resources.
• SC.3.183:
  • Deny network communications traffic by default and allow communications traffic by exception (i.e. deny all, permit by exception).
• SC.3.184:
  • 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).
• SC.3.185:
  • Implement cryptographic mechanisms to prevent unauthorized disclosure of CUI during transmission unless otherwise protected by alternative physical safeguards.
• SC.3.186:
  • Terminate network connections associated with communications sessions at the end of sessions or after a defined period of inactivity.
• SC.3.187:
  • Establish and manage cryptographic keys for cryptography employed in organizational systems.
• SC.3.188:
  • Control and monitor the use of mobile code.
• SC.3.189:
  • Control and monitor the use of Voice over Internet Protocol (VoIP) technologies.
• SC.3.190:
  • Protect authenticity of communications sessions.
• SC.3.191:
  • Protect the confidentiality of CUI at rest.
• SC.3.192:
  • Implement Domain Name System (DNS) filtering systems.
• SC.3.193:
  • Implement a policy restricting the publication of CUI on externally owned, publicly accessible websites (e.g. forums, LinkedIn, Facebook, Twitter).

System and Integrity (SI)

• SI.3.218:
  • Employ spam protecting mechanisms at information system access entry and exit points.
• SI.3.219:
  • Implement email forgery protections.
• SI.3.220:
  • Utilize sandboxing to detect or block potentially malicious emails.

How Do I Pass CMMC Level 1-3?

So where do we go from here? How can a company that provides products or services to the Department of Defense (DoD) maintain excellent cybersecurity hygiene, despite having limited resources and/or staff?

The vast list of controls required for Levels 1-3 will be unfamiliar to most businesses, and they will struggle to understand, identify, and implement them.

To solve this problem, many organizations are turning to managed service providers that not only specialize in offering compliant CMMC security solutions, but also provides readiness assessments to make sure your organization is ready to accomplish your CMMC Level goals.

Spry Squared offers a comprehensive CMMC readiness assessment for government contractors. We take on the task of preparing your organization for your upcoming CMMC audit, and help you obtain your Cybersecurity Maturity Model Certification.

Schedule a quick call to learn more about how Spry Squared, Inc. can help your organization prepare for your CMMC audit.