Level 2 · Identification and Authentication
IA.L2-3.5.1
Identification
Identification should distinguish people, their processes, and devices before access decisions are made.
Official reference
The requirement
Identify system users, processes acting on behalf of users, and devices.
DoD CMMC Assessment Guide, Level 2, version 2.13. IA.L2-3.5.1; requirement and objectives, printed page 112 ↗
Assessment objectives
What must be established
Determine if each applicable objective is satisfied. The labels below follow the cited DoD assessment guide.
- [a]
system users are identified;
- [b]
processes acting on behalf of users are identified; and
- [c]
devices accessing the system are identified.
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
IA.L1-b.1.v: Identification
Identities need to distinguish the users, processes, and devices accessing the FCI environment.
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.
Identify information system users, processes acting on behalf of users, or devices.
DoD CMMC Assessment Guide, Level 1: IA.L1-b.1.v; requirement and objectives, printed page 22 ↗
Level 1 assessment objectives and guidance
Determine if:
- [a]
system users are identified;
- [b]
processes acting on behalf of users are identified; and
- [c]
devices accessing the system are identified.
Connect identifiers to accountable owners. Identification establishes who or what an entity is; the separate authentication requirement checks that identity before access.
Examine
Review user accounts, process identities, device identifiers, and ownership records.
Interview
How can the organization identify the owner of a process or device shown in an access record?
Demonstrate or test
Trace one user, one process, and one device through the system's identity records.
Level 1 evidence gaps
- Generic accounts obscure individual users.
- Devices connect without a record linking them to an asset or owner.
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 ↗IA.L1-b.1.v; requirement and objectives, printed page 22
- 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)(v)
GAVII Cybersecurity assessment approach
Connect the objective to the evidence
Reconcile identifiers across identity services, applications, and device management. Naming conventions help only when they lead to an accountable identity and owner.
Assessment focus: objectives [a], [b], [c]. Use the methods together; a single example does not establish every objective.
Examine
Inspect user identifiers, service-process identities, device identifiers, and ownership records.
Interview
How is a service identity distinguished from a person's account, and who owns it?
Demonstrate or test
Trace representative user, process, and device identifiers through the relevant system records.
Evidence gaps to look for
- Shared or generic identifiers obscure ownership.
- Unmanaged devices appear in access records without an identified asset.
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: 5
If this requirement is NOT MET, deduct 5 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 ↗IA.L2-3.5.1; requirement and objectives, printed page 112. 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 3.5.1. February 2020, updated January 2021.
- NIST SP 800-171A ↗Assessment procedure 3.5.1. 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.