Level 2 · Physical Protection
PE.L2-3.10.1
Limit Physical Access
Physical access control should connect an authorized-person list with the systems, equipment, and spaces it protects.
Official reference
The requirement
Limit physical access to organizational systems, equipment, and the respective operating environments to authorized individuals.
DoD CMMC Assessment Guide, Level 2, version 2.13. PE.L2-3.10.1; requirement and objectives, printed page 180 ↗
Assessment objectives
What must be established
Determine if each applicable objective is satisfied. The labels below follow the cited DoD assessment guide.
- [a]
authorized individuals allowed physical access are identified;
- [b]
physical access to organizational systems is limited to authorized individuals;
CAP location planning flagged ↓ - [c]
physical access to equipment is limited to authorized individuals; and
CAP location planning flagged ↓ - [d]
physical access to operating environments is limited to authorized individuals.
CAP location planning flagged ↓
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
PE.L1-b.1.viii: Limit Physical Access
Physical access to FCI systems, equipment, and operating environments needs an explicit authorization boundary.
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 physical access to organizational information systems, equipment, and the respective operating environments to authorized individuals.
DoD CMMC Assessment Guide, Level 1: PE.L1-b.1.viii; requirement and objectives, printed page 29 ↗
Level 1 assessment objectives and guidance
Determine if:
- [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; and
- [d]
physical access to operating environments is limited to authorized individuals.
A building entrance control may not protect every place where the covered system operates. Review who may enter the relevant spaces and how that permission is enforced.
Examine
Inspect authorized-person lists, protected-area definitions, and lock or badge arrangements.
Interview
Who may access the equipment and work areas, and how are changes in authorization communicated?
Demonstrate or test
Walk through the relevant access restrictions using an appropriate observation method for the self-assessment.
Level 1 evidence gaps
- The main entrance is controlled but the equipment area is unrestricted.
- The authorized-person list is outdated.
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 ↗PE.L1-b.1.viii; requirement and objectives, printed page 29
- 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)(viii)
GAVII Cybersecurity assessment approach
Connect the objective to the evidence
Review the actual places where scoped systems operate, not only the main entrance. CAP location planning highlights observation of the physical restrictions.
Assessment focus: objectives [a], [b], [c], [d]. Use the methods together; a single example does not establish every objective.
Examine
Inspect physical-access authorizations, facility boundaries, lock or badge arrangements, and access changes.
Interview
Who may enter each protected area, and how is that authorization kept current?
Demonstrate or test
Arrange an appropriate observation of access to representative systems, equipment, and operating environments.
Evidence gaps to look for
- A reception process exists but server or work areas remain unrestricted.
- The authorized-person list is outdated.
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
Location planning flagged
CAP P.11 specifically highlights the marked objectives for assessment-location planning. Agree with the C3PAO how the environment can be adequately observed, including any scope-specific need for on-site activity. These markers do not establish a universal in-person requirement.
Flagged objectives: [b], [c], [d].
CAP §P.11, pages 10–11 ↗Check the source
References and related requirements
- DoD CMMC Assessment Guide, Level 2 ↗PE.L2-3.10.1; requirement and objectives, printed page 180. 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 3.10.1. February 2020, updated January 2021.
- NIST SP 800-171A ↗Assessment procedure 3.10.1. 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.