SC.L2-3.13.11: CUI Encryption Assessment Guide

Official reference

The requirement

Employ FIPS-validated cryptography when used to protect the confidentiality of CUI.

DoD CMMC Assessment Guide, Level 2, version 2.13. SC.L2-3.13.11; requirement and objectives, printed page 234 ↗

Assessment objectives

What must be established

Determine if each applicable objective is satisfied. The labels below follow the cited DoD assessment guide.

[a]
FIPS-validated cryptography is employed to protect the confidentiality of CUI.

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 where cryptography protects CUI confidentiality, then connect deployed versions, configuration, and operational mode to the applicable validation evidence. Distinguish a validated module from a vendor statement that a product uses strong algorithms.

Assessment focus: objectives [a]. Use the methods together; a single example does not establish every objective.

Examine

Review module certificates, security policies, deployed versions, approved-mode settings, and the CUI protection architecture.

Interview

Which validated module protects each relevant CUI flow or storage location, and how do you verify its required operating configuration?

Demonstrate or test

Trace one deployed cryptographic function to its validation record and inspect the configuration without exposing keys or CUI.

Evidence gaps to look for

An algorithm name is presented as validation.
The deployed module version or operating mode does not match the cited evidence.

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: 3 or 5

Deduct 3 points if encryption is employed but is not FIPS-validated; deduct 5 points if encryption is not employed. The limited POA&M exception applies only to the implemented-but-not-FIPS-validated case, subject to all Conditional Level 2 criteria.

Scoring rule ↗

POA&M: Limited encryption exception

Only the case in which encryption is employed but is not FIPS-validated can use this exception. A missing encryption implementation is not eligible. All other Conditional Level 2 conditions and closeout requirements still apply.

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.L2-3.13.11; requirement and objectives, printed page 234. 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 3.13.11. February 2020, updated January 2021.
NIST SP 800-171A ↗Assessment procedure 3.13.11. 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.

CUI Encryption