The Complete CMMC Level 2 Assessment Checklist for 2026
CMMC Level 2 requires demonstrating implementation of all 110 security practices from NIST SP 800-171 Rev 2. With the CMMC final rule in effect and C3PAO assessments underway, defense contractors need a clear roadmap from "we handle CUI" to "we can prove it to an assessor."
This checklist organizes all 110 practices by domain, with readiness tips for each. Use it as your preparation guide — or run our interactive readiness quiz to get a personalized assessment of where you stand.
Before the assessment: foundational prerequisites
Before working through individual controls, confirm these prerequisites are in place:
- CUI boundary defined. You know exactly which systems, networks, and users handle CUI. If you're unsure, start with our CUI Boundary Scoping Tool.
- DFARS clauses identified. You know which DFARS clauses flow down to your contracts and what they require. Use our DFARS Identifier to check.
- System Security Plan (SSP) exists. Even a draft SSP is required. It must describe your system boundary, data flows, and how each of the 110 practices is implemented.
- POA&M is current. Any controls not fully implemented must appear in your Plan of Action & Milestones with remediation dates.
- SPRS score submitted. Your Supplier Performance Risk System score must be posted to SPRS before contract award.
Access Control (AC) — 22 practices
Access Control is the largest domain and typically carries the most SPRS weight. Key areas:
- Account management (3.1.1-3.1.2). Limit system access to authorized users, processes, and devices. Readiness tip: Export your IAM principal list with last-login dates. Any account not used in 90 days should be disabled or justified.
- Access enforcement (3.1.3-3.1.5). Control CUI flow and enforce separation of duties. Readiness tip: Map every CUI data flow and show the enforcement mechanism (firewall rule, IAM policy, DLP rule) for each.
- Least privilege (3.1.5-3.1.8). Non-privileged accounts for non-security functions, privileged access restricted. Readiness tip: Show that admins use separate accounts for administrative vs. daily-use tasks.
- Remote access (3.1.12-3.1.15). Monitor, control, encrypt, and route remote access. Readiness tip: VPN logs showing encrypted tunnels, MFA enforcement, and session termination policies.
- Wireless access (3.1.16-3.1.17). Authorize, monitor, and protect wireless. Readiness tip: Wireless network configuration showing WPA3/WPA2-Enterprise, rogue AP detection.
- Mobile devices (3.1.18-3.1.19). Control and encrypt CUI on mobile devices. Readiness tip: MDM enrollment evidence, device encryption verification, remote wipe capability.
- External connections (3.1.20-3.1.22). Control connections to external systems. Readiness tip: Documented and approved external system connections with data flow descriptions.
Awareness and Training (AT) — 3 practices
All personnel must understand their security responsibilities. Evidence is usually training records.
- Security awareness (3.2.1). Readiness tip: Signed training acknowledgments with dates, covering CUI handling, phishing, and incident reporting.
- Role-based training (3.2.2). Readiness tip: Specialized training for admins, developers, and security personnel beyond general awareness.
- Insider threat awareness (3.2.3). Readiness tip: Training records showing insider threat indicators, reporting procedures, and annual refresher completion.
Audit and Accountability (AU) — 9 practices
Create, protect, and review audit logs. This is where your SIEM deployment matters.
- Audit events (3.3.1-3.3.2). Readiness tip: Show your SIEM collecting login events, privilege escalation, CUI access, and failed authentication across all in-scope systems.
- Audit log protection (3.3.3-3.3.4). Readiness tip: Demonstrate that audit logs are immutable (write-once storage) and access to log management is restricted to authorized admins.
- Audit review and reporting (3.3.5-3.3.6). Readiness tip: Weekly or daily log review procedures with documented findings and escalation records.
- Time synchronization (3.3.7). Readiness tip: NTP configuration across all systems with evidence of synchronized timestamps in logs.
- Audit reduction (3.3.8-3.3.9). Readiness tip: SIEM dashboards or queries that demonstrate audit reduction, analysis, and reporting capability.
Configuration Management (CM) — 9 practices
- Baseline configurations (3.4.1-3.4.2). Readiness tip: Documented system baselines (CIS benchmarks or equivalent) and change control procedures with approval records.
- Change tracking (3.4.3-3.4.5). Readiness tip: Change management system showing security impact analysis for each change and approved configuration settings.
- Least functionality (3.4.6-3.4.8). Readiness tip: Evidence of disabled unnecessary services, ports, and protocols. Application whitelisting or blacklisting policies.
- User-installed software (3.4.9). Readiness tip: Policy restricting user-installed software with technical enforcement (AppLocker, Group Policy).
Identification and Authentication (IA) — 11 practices
- User identification (3.5.1-3.5.2). Readiness tip: Unique user IDs for all accounts, no shared credentials, authentication required before access.
- Multi-factor authentication (3.5.3). Readiness tip: MFA enforced for all privileged and remote access. Hardware tokens or authenticator apps, not SMS. Show enrollment records.
- Replay-resistant authentication (3.5.4). Readiness tip: Authentication mechanisms that resist replay attacks (FIDO2, certificate-based, challenge-response).
- Identifier management (3.5.5-3.5.6). Readiness tip: Process for disabling identifiers after inactivity period, preventing identifier reuse.
- Password management (3.5.7-3.5.11). Readiness tip: Password complexity requirements meeting NIST guidelines, encrypted password storage, and obscured password display.
Incident Response (IR) — 3 practices
- Incident handling (3.6.1). Readiness tip: Documented IR plan covering preparation, detection, analysis, containment, eradication, and recovery. Must include DIB-specific reporting to DC3.
- Incident reporting (3.6.2). Readiness tip: Evidence of incident tracking and reporting procedures, including 72-hour notification requirements for cyber incidents affecting CUI.
- Incident response testing (3.6.3). Readiness tip: Tabletop exercise records from the past 12 months with lessons learned and plan updates.
Maintenance (MA) — 6 practices
- System maintenance (3.7.1-3.7.2). Readiness tip: Maintenance schedules, patch management records, and maintenance personnel authorization lists.
- Equipment sanitization (3.7.3). Readiness tip: Procedures for sanitizing equipment removed for off-site maintenance, with media sanitization records.
- Maintenance tools (3.7.4-3.7.5). Readiness tip: Approved tools list, inspection procedures for tools brought on-site, and media inspection before use.
- Remote maintenance (3.7.6). Readiness tip: Supervised remote maintenance sessions with logging and session termination when complete.
Media Protection (MP) — 9 practices
- Media protection (3.8.1-3.8.3). Readiness tip: CUI marking procedures, physical and digital media access controls, and media sanitization records (NIST 800-88).
- Media marking (3.8.4-3.8.5). Readiness tip: CUI marking on media and controlled areas, with distribution limitation markings.
- Media transport (3.8.6-3.8.7). Readiness tip: Encryption of CUI on portable media, controlled transport procedures with accountability records.
- Media disposal (3.8.8-3.8.9). Readiness tip: Sanitization and destruction records per NIST SP 800-88 for all media that contained CUI.
Personnel Security (PS) — 2 practices
- Personnel screening (3.9.1). Readiness tip: Background check procedures and records for all personnel with CUI access.
- Personnel termination/transfer (3.9.2). Readiness tip: Offboarding checklists showing access revocation within required timeframes, with dates and responsible parties.
Physical Protection (PE) — 6 practices
- Physical access (3.10.1-3.10.2). Readiness tip: Access control lists for facilities handling CUI, visitor logs, and escort procedures.
- Physical access monitoring (3.10.3-3.10.4). Readiness tip: Badge reader logs, camera footage retention policies, and tamper-evident measures for physical access devices.
- Facility protection (3.10.5-3.10.6). Readiness tip: Alternative work site security measures and CUI positioning/shielding to limit unauthorized viewing.
Risk Assessment (RA) — 3 practices
- Risk assessments (3.11.1). Readiness tip: Annual risk assessment covering CUI systems, threat identification, and risk prioritization.
- Vulnerability scanning (3.11.2-3.11.3). Readiness tip: Regular vulnerability scan results (Nessus, Qualys, etc.) with remediation tracking and scan-to-fix timelines.
Security Assessment (CA) — 4 practices
- Security control assessment (3.12.1). Readiness tip: Self-assessment results or third-party assessment against all 110 practices with findings documented.
- Plan of action (3.12.2). Readiness tip: Current POA&M with specific milestones, responsible parties, and target completion dates for each open finding.
- Continuous monitoring (3.12.3-3.12.4). Readiness tip: Security control monitoring procedures and system-level security plans updated per changes.
System and Communications Protection (SC) — 16 practices
This is the second-largest domain. Key focus areas:
- Boundary protection (3.13.1-3.13.2). Readiness tip: Network diagrams showing authorization boundary, firewall rules, DMZ architecture, and CUI data flow paths.
- Encryption (3.13.8, 3.13.11). Readiness tip: FIPS 140-2/140-3 validated encryption for CUI in transit and at rest. Show certificate configurations and encryption module details.
- Network segmentation (3.13.5-3.13.6). Readiness tip: VLAN configurations, firewall rules, and evidence of subnetwork isolation for publicly accessible components.
- Communication integrity (3.13.9-3.13.10). Readiness tip: TLS 1.2+ enforcement, certificate management, and DNS security measures.
- Session management (3.13.15-3.13.16). Readiness tip: Session lock after inactivity, session termination policies, and cryptographic session management.
System and Information Integrity (SI) — 7 practices
- Flaw remediation (3.14.1). Readiness tip: Patch management records showing timely remediation of identified vulnerabilities with defined SLAs.
- Malicious code protection (3.14.2-3.14.5). Readiness tip: Endpoint protection deployment records, signature update logs, and malicious code scanning at network entry/exit points.
- Security alerts (3.14.3). Readiness tip: Process for monitoring security advisories (CISA KEV, vendor bulletins) and implementing relevant patches.
- System monitoring (3.14.6-3.14.7). Readiness tip: IDS/IPS deployment evidence, monitoring procedures for unauthorized access attempts, and alert response records.
Next steps
Working through this checklist is step one. The real challenge is producing evidence that an assessor can validate — not just policies saying you intend to do these things, but proof that you're doing them, continuously.
If you want to see what machine-readable compliance evidence looks like for your infrastructure, book a 30-minute scan. We'll hand you the first three component-definitions mapped to your environment.