Level 2 · Identification and Authentication
IA.L2-3.5.3
Multifactor Authentication
MFA coverage must be assessed by account type and access type, not by enrollment percentage alone.
Official reference
The requirement
Use multifactor authentication for local and network access to privileged accounts and for network access to non-privileged accounts.
DoD CMMC Assessment Guide, Level 2, version 2.13. IA.L2-3.5.3; requirement and objectives, printed page 117 ↗
Assessment objectives
What must be established
Determine if each applicable objective is satisfied. The labels below follow the cited DoD assessment guide.
- [a]
privileged accounts are identified;
- [b]
multifactor authentication is implemented for local access to privileged accounts;
- [c]
multifactor authentication is implemented for network access to privileged accounts; and
- [d]
multifactor authentication is implemented for network access to non-privileged accounts.
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
Examine local and network access to privileged accounts and network access to non-privileged accounts. Distinguish enrollment, policy assignment, enforcement, and exceptions at each relevant access path.
Assessment focus: objectives [a], [b], [c], [d]. Use the methods together; a single example does not establish every objective.
Examine
Review an access-path coverage matrix, MFA policies, exclusions, and representative authentication records.
Interview
Which local, remote, legacy, or emergency paths can bypass the intended second factor?
Demonstrate or test
Demonstrate representative privileged and non-privileged access paths, including an exception path, without capturing credentials.
Evidence gaps to look for
- MFA is enabled for VPN access but not other network access.
- Emergency or legacy accounts bypass enforcement without being recognized.
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
The rule specifies a 3-point deduction when MFA is implemented only for remote and privileged users, and a 5-point deduction when MFA is not implemented for any users. Assess the actual access paths and implementation against all objectives. Partial scoring does not make this requirement POA&M eligible.
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.L2-3.5.3; requirement and objectives, printed page 117. 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 3.5.3. February 2020, updated January 2021.
- NIST SP 800-171A ↗Assessment procedure 3.5.3. 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.