Level 2 · Physical Protection
PE.L2-3.10.5
Manage Physical Access
Keys, badges, codes, and other physical-access devices need identifiable custody and lifecycle management.
Official reference
The requirement
Control and manage physical access devices.
DoD CMMC Assessment Guide, Level 2, version 2.13. PE.L2-3.10.5; requirement and objectives, printed page 188 ↗
Assessment objectives
What must be established
Determine if each applicable objective is satisfied. The labels below follow the cited DoD assessment guide.
- [a]
physical access devices are identified;
- [b]
physical access devices are controlled; and
CAP location planning flagged ↓ - [c]
physical access devices are managed.
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.ix: Manage Visitors & Physical Access
Visitor handling, physical-access logs, and access-device management must work together.
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. This combined FAR requirement maps to PE.L2-3.10.3, PE.L2-3.10.4, PE.L2-3.10.5.
Escort visitors and monitor visitor activity; maintain audit logs of physical access; and control and manage physical access devices.
DoD CMMC Assessment Guide, Level 1: PE.L1-b.1.ix; requirement and objectives, printed page 31 ↗
Level 1 assessment objectives and guidance
Determine if:
- [a]
visitors are escorted;
- [b]
visitor activity is monitored;
- [c]
audit logs of physical access are maintained;
- [d]
physical access devices are identified;
- [e]
physical access devices are controlled; and
- [f]
physical access devices are managed.
This single FAR-based Level 1 requirement combines activities represented by three separate Level 2 requirements. Check all six Level 1 objectives rather than assessing visitor sign-in alone.
Examine
Review escort procedures, visitor and access logs, badge or key inventories, issuance records, and recovery procedures.
Interview
Who escorts a visitor, who maintains access records, and how are lost or returned access devices handled?
Demonstrate or test
Walk through a fictional visit, retrieve a sanitized access record, and trace a test badge from issue to revocation.
Level 1 evidence gaps
- Visitors sign in but are not escorted.
- Access logs are not retained.
- Returned badges remain active.
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.ix; requirement and objectives, printed page 31
- 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)(ix)
GAVII Cybersecurity assessment approach
Connect the objective to the evidence
Follow issuance, changes, recovery, and loss handling. Knowing how many keys exist is not enough if their current holders or permissions are unknown.
Assessment focus: objectives [a], [b], [c]. Use the methods together; a single example does not establish every objective.
Examine
Inspect device inventories, issuance records, access permissions, recovery records, and lost-device procedures.
Interview
How is access revoked when a badge is lost or a key cannot be recovered?
Demonstrate or test
Trace a representative access device from approval through issuance and revocation, with appropriate observation of enforcement.
Evidence gaps to look for
- An employee returns a badge but its access remains active.
- Shared codes are not changed when access should end.
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: 1
If this requirement is NOT MET, deduct 1 point 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 is explicitly excluded by 32 CFR 170.21(a)(2)(iii); 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.
CAP §P.11, pages 10–11 ↗Check the source
References and related requirements
- DoD CMMC Assessment Guide, Level 2 ↗PE.L2-3.10.5; requirement and objectives, printed page 188. 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 3.10.5. February 2020, updated January 2021.
- NIST SP 800-171A ↗Assessment procedure 3.10.5. 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.