Level 2 · Access Control
AC.L2-3.1.1
Authorized Access Control
A current account inventory connects every user, process, and device to an authorization decision.
Official reference
The requirement
Limit system access to authorized users, processes acting on behalf of authorized users, and devices (including other systems).
DoD CMMC Assessment Guide, Level 2, version 2.13. AC.L2-3.1.1; requirement and objectives, printed page 14 ↗
Assessment objectives
What must be established
Determine if each applicable objective is satisfied. The labels below follow the cited DoD assessment guide.
- [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; and
- [f]
system access is limited to authorized devices (including other systems).
MET requires evidence that all applicable objectives are satisfied. Final, approved evidence is needed. A NOT APPLICABLE determination needs a scope-based basis and is equivalent to MET for scoring. Enduring exceptions and temporary deficiencies have specific conditions under 32 CFR 170.24; they are not a general permission to defer implementation.
Included Level 1 coverage · FCI
AC.L1-b.1.i: Authorized Access Control
Access to systems handling FCI should be limited to identified, authorized people, processes, and devices.
Level 2 includes Level 1 safeguarding coverage. This is the FAR-based Level 1 assessment context mapped into the 110-requirement library, not an additional Level 2 requirement.
Limit information system access to authorized users, processes acting on behalf of authorized users, or devices (including other information systems).
DoD CMMC Assessment Guide, Level 1: AC.L1-b.1.i; requirement and objectives, printed page 12 ↗
Level 1 assessment objectives and guidance
Determine if:
- [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; and
- [f]
system access is limited to authorized devices (including other systems).
Start with the covered contractor information system and its actual users, integrations, and devices. Level 1 protects FCI; do not silently substitute a CUI-only scope or claim that a Level 2 certification is needed to satisfy this requirement.
Examine
Compare approved users, process owners, device records, and effective access settings for the FCI environment.
Interview
Who authorizes a new user, integration, or device to access the FCI system?
Demonstrate or test
Trace an approved user and device into a representative service and show how an unauthorized identity is restricted.
Level 1 evidence gaps
- The staff roster excludes service accounts and connected devices.
- An external application has accounts that are absent from the central directory.
Level 1 has no weighted deduction. All applicable requirements must be fully implemented; the self-assessment is MET or NOT MET in its entirety.
Level 1 does not permit a POA&M. CAP P.11 addresses Level 2 certification planning, not a mandatory on-site rule for Level 1 self-assessments. Choose evidence and observations adequate to evaluate the actual physical environment and applicable objectives.
- DoD CMMC Assessment Guide, Level 1 ↗AC.L1-b.1.i; requirement and objectives, printed page 12
- 32 CFR 170.24: Assessment findings and scoring ↗170.24(b) and (c)(1)
- 32 CFR 170.21: POA&M eligibility and closeout ↗170.21(a)(1) and (b)
- FAR 52.204-21: Basic safeguarding ↗52.204-21(b)(1)(i)
GAVII Cybersecurity assessment approach
Connect the objective to the evidence
Start with the in-scope system inventory, then reconcile accounts and connected devices. An identity directory alone can miss local accounts, application identities, and service integrations.
Assessment focus: objectives [a], [b], [c], [d], [e], [f]. Use the methods together; a single example does not establish every objective.
Examine
Compare approved access requests, active account exports, service-account owners, and device enrollment records for the same systems.
Interview
Who approves a new service identity, and how do you detect an account that has no current owner?
Demonstrate or test
Trace an approved user and device into an application, then show how an unapproved account or device is denied using a safe test environment.
Evidence gaps to look for
- A list of people is presented without service identities or devices.
- Disabled directory accounts remain active inside a separate application.
GAVII Cybersecurity’s examples illustrate ways to examine, interview, and test. They are not a mandatory artifact list or a guarantee of an assessment result. Combine methods and address every applicable objective in the actual scope.
Assessment constraints
Scoring and POA&M eligibility
Score: 5
If this requirement is NOT MET, deduct 5 points from the Level 2 maximum of 110. The deduction applies to the requirement, not separately to each objective.
Scoring rule ↗POA&M: Not eligible
This requirement has a deduction greater than 1 point and does not qualify for the limited encryption exception. It cannot be deferred on the POA&M used for Conditional Level 2 status.
POA&M rule ↗Conditional Level 2 requires a score of at least 88 out of 110 and satisfaction of every eligibility condition. A 1-point requirement is not automatically eligible. The permitted POA&M must be closed through the appropriate closeout assessment within 180 days of the Conditional CMMC Status Date. An operational remediation plan does not confer Conditional Status.
Assessment planning
Location and observation
Not specifically listed in CAP P.11
This requirement is not specifically listed in CAP P.11. That does not establish that remote assessment is sufficient: the Lead CCA and C3PAO determine an adequate approach for the actual scope and evidence.
CAP §P.11, pages 10–11 ↗Check the source
References and related requirements
- DoD CMMC Assessment Guide, Level 2 ↗AC.L2-3.1.1; requirement and objectives, printed page 14. 2.13, September 2024.
- 32 CFR 170.24: Assessment findings and scoring ↗170.24(b) and (c)(2). Current electronic Code of Federal Regulations.
- 32 CFR 170.21: POA&M eligibility and closeout ↗170.21(a)(2) and (b). Current electronic Code of Federal Regulations.
- NIST SP 800-171 Rev. 2 ↗Requirement 3.1.1. February 2020, updated January 2021.
- NIST SP 800-171A ↗Assessment procedure 3.1.1. June 2018.
- Cyber AB CMMC Assessment Process (CAP) ↗P.11, printed pages 10-11; Level 2 certification assessment-location planning. 2.0, December 2024.
Program timing and contract applicability can change independently of these requirements. Check current DoD program notices and your solicitation or contract before making a compliance decision. Open the official DoD resource hub.