Level 2 · Identification and Authentication
IA.L2-3.5.2
Authentication
Authentication must verify the relevant identity before access is granted.
Official reference
The requirement
Authenticate (or verify) the identities of users, processes, or devices, as a prerequisite to allowing access to organizational systems.
DoD CMMC Assessment Guide, Level 2, version 2.13. IA.L2-3.5.2; requirement and objectives, printed page 114 ↗
Assessment objectives
What must be established
Determine if each applicable objective is satisfied. The labels below follow the cited DoD assessment guide.
- [a]
the identity of each user is authenticated or verified as a prerequisite to system access;
- [b]
the identity of each process acting on behalf of a user is authenticated or verified as a prerequisite to system access; and
- [c]
the identity of each device accessing or connecting to the system is authenticated or verified as a prerequisite to system access.
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.vi: Authentication
An identity must be verified before access to the covered information system is granted.
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.
Authenticate (or verify) the identities of those users, processes, or devices, as a prerequisite to allowing access to organizational information systems.
DoD CMMC Assessment Guide, Level 1: IA.L1-b.1.vi; requirement and objectives, printed page 24 ↗
Level 1 assessment objectives and guidance
Determine if:
- [a]
the identity of each user is authenticated or verified as a prerequisite to system access;
- [b]
the identity of each process acting on behalf of a user is authenticated or verified as a prerequisite to system access; and
- [c]
the identity of each device accessing or connecting to the system is authenticated or verified as a prerequisite to system access.
Review user, process, and device authentication paths. This Level 1 requirement does not independently create the Level 2 MFA requirement, although stronger authentication may be a sound implementation choice.
Examine
Inspect authentication settings, trust relationships, and representative access records without collecting credentials.
Interview
What verifies the identity of an integration or device before it receives access?
Demonstrate or test
Demonstrate accepted and rejected test identities on representative access paths.
Level 1 evidence gaps
- Only interactive user logon is reviewed.
- An integration uses uncontrolled credentials or admits an unverified device.
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.vi; requirement and objectives, printed page 24
- 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)(vi)
GAVII Cybersecurity assessment approach
Connect the objective to the evidence
Include nonhuman identities and devices, not only interactive user logons. Identify how each applicable access path verifies identity and handles failed verification.
Assessment focus: objectives [a], [b], [c]. Use the methods together; a single example does not establish every objective.
Examine
Review authentication configurations, identity trust relationships, credentials or certificate management, and access records.
Interview
What verifies the identity of an integration or device before it connects?
Demonstrate or test
Demonstrate a successful authentication and a rejected invalid identity for representative access paths using test accounts.
Evidence gaps to look for
- A user login is shown while service connections rely on uncontrolled shared credentials.
- Device verification is omitted.
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.L2-3.5.2; requirement and objectives, printed page 114. 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 3.5.2. February 2020, updated January 2021.
- NIST SP 800-171A ↗Assessment procedure 3.5.2. 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.
