Level 2 · System and Information Integrity
SI.L2-3.14.5
System & File Scanning
Periodic scanning and real-time scanning address different detection opportunities.
Official reference
The requirement
Perform periodic scans of organizational systems and real-time scans of files from external sources as files are downloaded, opened, or executed.
DoD CMMC Assessment Guide, Level 2, version 2.13. SI.L2-3.14.5; requirement and objectives, printed page 256 ↗
Assessment objectives
What must be established
Determine if each applicable objective is satisfied. The labels below follow the cited DoD assessment guide.
- [a]
the frequency for malicious code scans is defined;
- [b]
malicious code scans are performed with the defined frequency; and
- [c]
real-time malicious code scans of files from external sources as files are downloaded, opened, or executed are performed.
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
SI.L1-b.1.xv: System & File Scanning
Scheduled scans and real-time scanning of incoming files need separate verification.
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.
Perform periodic scans of the information system and real-time scans of files from external sources as files are downloaded, opened, or executed.
DoD CMMC Assessment Guide, Level 1: SI.L1-b.1.xv; requirement and objectives, printed page 47 ↗
Level 1 assessment objectives and guidance
Determine if:
- [a]
the frequency for malicious code scans is defined;
- [b]
malicious code scans are performed with the defined frequency; and
- [c]
real-time malicious code scans of files from external sources as files are downloaded, opened, or executed are performed.
Define the periodic scan frequency and inspect completed scans. Then check the handling of files from external sources as they are downloaded, opened, or executed.
Examine
Review scan schedules, results, real-time settings, and exclusions.
Interview
Which paths bring files into the FCI system, and how are scanning exclusions controlled?
Demonstrate or test
Show a completed periodic scan and safely demonstrate real-time handling using approved benign test material.
Level 1 evidence gaps
- Real-time protection is mistaken for evidence of periodic scanning.
- Broad exclusions bypass important incoming-file paths.
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 ↗SI.L1-b.1.xv; requirement and objectives, printed page 47
- 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)(xv)
GAVII Cybersecurity assessment approach
Connect the objective to the evidence
Define the periodic frequency and verify execution. Separately examine real-time scanning of files from external sources as they are downloaded, opened, or executed.
Assessment focus: objectives [a], [b], [c]. Use the methods together; a single example does not establish every objective.
Examine
Review scan frequency definitions, scheduled-scan results, real-time protection settings, and exclusions.
Interview
Which paths introduce files from external sources, and how are scanning exclusions approved?
Demonstrate or test
Show a completed periodic scan and demonstrate real-time handling with a vendor-approved benign test file or equivalent safe validation.
Evidence gaps to look for
- Real-time protection is offered as proof of periodic scans.
- Broad exclusions remove important external-file paths from coverage.
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 ↗SI.L2-3.14.5; requirement and objectives, printed page 256. 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 3.14.5. February 2020, updated January 2021.
- NIST SP 800-171A ↗Assessment procedure 3.14.5. 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.