Level 2 · System and Communications Protection
SC.L2-3.13.10
Key Management
Cryptographic protection depends on the lifecycle and custody of its keys.
Official reference
The requirement
Establish and manage cryptographic keys for cryptography employed in organizational systems.
DoD CMMC Assessment Guide, Level 2, version 2.13. SC.L2-3.13.10; requirement and objectives, printed page 231 ↗
Assessment objectives
What must be established
Determine if each applicable objective is satisfied. The labels below follow the cited DoD assessment guide.
- [a]
cryptographic keys are established whenever cryptography is employed; and
- [b]
cryptographic keys are managed whenever cryptography is employed.
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.
GAVII Cybersecurity assessment approach
Connect the objective to the evidence
Identify how keys are established, stored, accessed, distributed, changed, and retired for the cryptography actually used. Do not request secret key material as assessment evidence.
Assessment focus: objectives [a], [b]. Use the methods together; a single example does not establish every objective.
Examine
Review key-management procedures, service configurations, access controls, and lifecycle records using redacted metadata.
Interview
Who can use or administer keys, and what happens when a key must be replaced or revoked?
Demonstrate or test
Trace a representative key through its approved lifecycle using identifiers and metadata rather than revealing the key.
Evidence gaps to look for
- Encryption is enabled but recovery keys are broadly accessible.
- Old keys or certificates remain active without ownership.
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: Eligible
Potentially eligible only if all Conditional Level 2 criteria are satisfied, including a score of at least 88 out of 110 and timely closeout. Eligibility is not a finding that this requirement is MET.
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 ↗SC.L2-3.13.10; requirement and objectives, printed page 231. 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 3.13.10. February 2020, updated January 2021.
- NIST SP 800-171A ↗Assessment procedure 3.13.10. 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.