Level 2 · System and Communications Protection
SC.L2-3.13.8
Data in Transit
Transmission protection should follow CUI through every relevant communication segment.
Official reference
The requirement
Implement cryptographic mechanisms to prevent unauthorized disclosure of CUI during transmission unless otherwise protected by alternative physical safeguards.
DoD CMMC Assessment Guide, Level 2, version 2.13. SC.L2-3.13.8; requirement and objectives, printed page 227 ↗
Assessment objectives
What must be established
Determine if each applicable objective is satisfied. The labels below follow the cited DoD assessment guide.
- [a]
cryptographic mechanisms intended to prevent unauthorized disclosure of CUI are identified;
- [b]
alternative physical safeguards intended to prevent unauthorized disclosure of CUI are identified; and
- [c]
either cryptographic mechanisms or alternative physical safeguards are implemented to prevent unauthorized disclosure of CUI during transmission.
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 is used and where alternative physical safeguards are relied upon. A protected user connection does not establish protection of a later service-to-service transfer.
Assessment focus: objectives [a], [b], [c]. Use the methods together; a single example does not establish every objective.
Examine
Review CUI flow diagrams, protocol configurations, encryption details, and documented alternative safeguards.
Interview
Where is CUI decrypted and retransmitted, and what protects each subsequent segment?
Demonstrate or test
Trace a synthetic transfer through the relevant endpoints and inspect the protection used on each segment.
Evidence gaps to look for
- Encryption protects the external hop but not an internal transfer.
- Alternative physical safeguards are named without describing their effect.
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
If this requirement is NOT MET, deduct 3 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 ↗SC.L2-3.13.8; requirement and objectives, printed page 227. 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 3.13.8. February 2020, updated January 2021.
- NIST SP 800-171A ↗Assessment procedure 3.13.8. 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.