Level 2 · Access Control
AC.L2-3.1.2
Transaction & Function Control
Authorization must define what a user can do after signing in, not merely whether the user can log in.
Official reference
The requirement
Limit system access to the types of transactions and functions that authorized users are permitted to execute.
DoD CMMC Assessment Guide, Level 2, version 2.13. AC.L2-3.1.2; requirement and objectives, printed page 17 ↗
Assessment objectives
What must be established
Determine if each applicable objective is satisfied. The labels below follow the cited DoD assessment guide.
- [a]
the types of transactions and functions that authorized users are permitted to execute are defined; and
- [b]
system access is limited to the defined types of transactions and functions for authorized users.
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.ii: Transaction & Function Control
FCI access should be limited to the transactions and functions authorized for the user's role.
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 the types of transactions and functions that authorized users are permitted to execute.
DoD CMMC Assessment Guide, Level 1: AC.L1-b.1.ii; requirement and objectives, printed page 15 ↗
Level 1 assessment objectives and guidance
Determine if:
- [a]
the types of transactions and functions that authorized users are permitted to execute are defined; and
- [b]
system access is limited to the defined types of transactions and functions for authorized users.
A successful login does not establish appropriate authority. Identify the business functions available to each role, especially sharing, exporting, and administering the information system.
Examine
Review role definitions, business-owner approvals, and application permissions.
Interview
Which role may export FCI or change permissions, and who approved that authority?
Demonstrate or test
Demonstrate an allowed function and a denied function with representative test roles.
Level 1 evidence gaps
- Everyone receives the same broad application role.
- Role descriptions do not match effective permissions.
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.ii; requirement and objectives, printed page 15
- 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)(ii)
GAVII Cybersecurity assessment approach
Connect the objective to the evidence
Translate job responsibilities into permitted transactions. Review application permissions as well as operating-system groups, especially export, approval, and administrative functions.
Assessment focus: objectives [a], [b]. Use the methods together; a single example does not establish every objective.
Examine
Compare a role-permission matrix, business-owner approvals, and effective permissions from representative applications.
Interview
Which role can export contract data or approve a transaction, and who approved that distinction?
Demonstrate or test
Use two representative test roles to demonstrate an allowed function and a denied function without exposing production CUI.
Evidence gaps to look for
- Role names are documented but their effective permissions are not.
- Inherited group membership creates broader access than the matrix describes.
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.L2-3.1.2; requirement and objectives, printed page 17. 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 3.1.2. February 2020, updated January 2021.
- NIST SP 800-171A ↗Assessment procedure 3.1.2. 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.