CMMC 2.0 Checklist 2026: Complete Level 1 & Level 2 Requirements
A complete, actionable checklist of all CMMC 2.0 requirements for DoD contractors and their MSPs — covering all 17 Level 1 practices (across 6 domains) and the 110 Level 2 practices (across all 14 domains), updated for the 2025 final rule.
CMMC 2.0 Overview
The Cybersecurity Maturity Model Certification (CMMC) 2.0 is the Department of Defense's framework for ensuring contractors protect Controlled Unclassified Information (CUI) and Federal Contract Information (FCI). As of 2025, CMMC requirements are being phased into DoD contracts through DFARS clauses.
CMMC 2.0 has three levels. The vast majority of DoD contractors need either Level 1 (basic cyber hygiene, self-assessment) or Level 2 (advanced, 110 practices, may require C3PAO assessment). Level 3 applies only to the most sensitive programs.
CMMC 2.0 eliminated Level 1.5 and Level 4/5, reduced Level 2 from 130 to 110 practices, allowed self-assessments for most Level 2 contractors, and aligned requirements directly with NIST SP 800-171 Rev 2. The final rule took effect December 16, 2024.
NIST released SP 800-171 Rev 3 in May 2024, which restructures the practices, removes 60+ controls, and adds new organizationally-defined parameters. CMMC 2.0 still references Rev 2 as its authoritative basis — the DoD has not yet updated the CMMC framework to adopt Rev 3, and contractors today must comply against Rev 2 practices. The practice IDs and wording on this checklist follow the Rev 2 / CMMC 2.0 mapping. When CMMC adopts Rev 3 (expected sometime in 2025–2026), this page will be updated. Until then: use Rev 2 for CMMC compliance work, reference Rev 3 for forward-looking planning.
CMMC Level 1 Checklist — 17 Practices
Level 1 applies to all DoD contractors handling FCI (Federal Contract Information). It requires annual self-assessment and affirmation by a senior company official. All 17 practices come from FAR 52.204-21.
| □ | Practice ID | Requirement | Domain |
|---|---|---|---|
| Access Control (AC) | |||
| □ | AC.L1-3.1.1 | Limit system access to authorized users and devices | AC |
| □ | AC.L1-3.1.2 | Limit system access to types of transactions and functions authorized users are permitted to execute | AC |
| □ | AC.L1-3.1.20 | Verify and control connections to external systems | AC |
| □ | AC.L1-3.1.22 | Control information posted or processed on publicly accessible systems | AC |
| Identification & Authentication (IA) | |||
| □ | IA.L1-3.5.1 | Identify information system users, processes, and devices | IA |
| □ | IA.L1-3.5.2 | Authenticate the identities of users, processes, and devices before allowing access | IA |
| Media Protection (MP) | |||
| □ | MP.L1-3.8.3 | Sanitize or destroy information system media before disposal or reuse | MP |
| Physical Protection (PE) | |||
| □ | PE.L1-3.10.1 | Limit physical access to authorized individuals | PE |
| □ | PE.L1-3.10.3 | Escort visitors and monitor visitor activity | PE |
| □ | PE.L1-3.10.4 | Maintain audit logs of physical access | PE |
| □ | PE.L1-3.10.5 | Control and manage physical access devices | PE |
| System & Communications Protection (SC) | |||
| □ | SC.L1-3.13.1 | Monitor, control, and protect organizational communications at external boundaries and key internal boundaries | SC |
| □ | SC.L1-3.13.5 | Implement subnetworks for publicly accessible system components | SC |
| System & Information Integrity (SI) | |||
| □ | SI.L1-3.14.1 | Identify, report, and correct system flaws in a timely manner | SI |
| □ | SI.L1-3.14.2 | Provide protection from malicious code at appropriate locations within organizational information systems | SI |
| □ | SI.L1-3.14.4 | Update malicious code protection mechanisms when new releases are available | SI |
| □ | SI.L1-3.14.5 | Perform periodic scans and real-time scans of files from external sources | SI |
CMMC Level 2 Checklist — All 110 Practices
Level 2 requires implementation of all 110 practices from NIST SP 800-171 Rev 2, organized across 14 domains. Every practice is listed below. Practices marked Auto can be verified by SBCMSP's automated scanner — practices marked Manual require documentation review, policy attestation, or process observation that no tool can substitute for.
Depending on your contract, Level 2 may require a C3PAO (third-party) assessment rather than self-assessment. Check your DFARS clauses. All 110 practices apply at Level 2 — the technical (Auto-assessable) controls are what SBCMSP automates; the operational/policy controls require evidence packages your assessor will review.
Access Control (AC) — 22 Practices
| □ | Practice | Requirement | Assessment |
|---|---|---|---|
| □ | AC.L2-3.1.3 | Control the flow of CUI in accordance with approved authorizations | Auto |
| □ | AC.L2-3.1.4 | Separate duties of individuals to reduce risk of malevolent activity without collusion | Manual |
| □ | AC.L2-3.1.5 | Employ the principle of least privilege, including for specific security functions and privileged accounts | Auto |
| □ | AC.L2-3.1.6 | Use non-privileged accounts or roles when accessing non-security functions | Auto |
| □ | AC.L2-3.1.7 | Prevent non-privileged users from executing privileged functions; capture in audit logs | Manual |
| □ | AC.L2-3.1.8 | Limit unsuccessful logon attempts | Auto — Agent |
| □ | AC.L2-3.1.9 | Provide privacy and security notices consistent with applicable CUI rules | Manual |
| □ | AC.L2-3.1.10 | Use session lock with pattern-hiding displays to prevent access and viewing of data after a period of inactivity | Auto — Agent |
| □ | AC.L2-3.1.11 | Terminate (automatically) a user session after a defined condition | Auto — Agent |
| □ | AC.L2-3.1.12 | Monitor and control remote access sessions | Auto |
| □ | AC.L2-3.1.13 | Employ cryptographic mechanisms to protect the confidentiality of remote access sessions | Auto — TLS |
| □ | AC.L2-3.1.14 | Route remote access via managed access control points | Manual |
| □ | AC.L2-3.1.15 | Authorize remote execution of privileged commands and remote access to security-relevant information | Manual |
| □ | AC.L2-3.1.16 | Authorize wireless access prior to allowing such connections | Manual |
| □ | AC.L2-3.1.17 | Protect wireless access using authentication and encryption | Auto — Agent |
| □ | AC.L2-3.1.18 | Control connection of mobile devices | Manual |
| □ | AC.L2-3.1.19 | Encrypt CUI on mobile devices and mobile computing platforms | Auto — BitLocker |
| □ | AC.L2-3.1.21 | Limit use of portable storage devices on external systems | Manual |
Awareness & Training (AT) — 3 Practices
| □ | Practice | Requirement | Assessment |
|---|---|---|---|
| □ | AT.L2-3.2.1 | Ensure that managers, system administrators, and users of organizational systems are made aware of the security risks associated with their activities and of the applicable policies, standards, and procedures related to the security of those systems | Manual |
| □ | AT.L2-3.2.2 | Ensure that personnel are trained to carry out their assigned information-security-related duties and responsibilities | Manual |
| □ | AT.L2-3.2.3 | Provide security awareness training on recognizing and reporting potential indicators of insider threat | Manual |
Audit & Accountability (AU) — 9 Practices
| □ | Practice | Requirement | Assessment |
|---|---|---|---|
| □ | AU.L2-3.3.1 | Create and retain system audit logs and records to the extent needed to enable the monitoring, analysis, investigation, and reporting of unlawful or unauthorized system activity | Auto — Agent |
| □ | AU.L2-3.3.2 | Ensure that the actions of individual system users can be uniquely traced to those users so they can be held accountable for their actions | Auto — Agent |
| □ | AU.L2-3.3.3 | Review and update logged events | Manual |
| □ | AU.L2-3.3.4 | Alert in the event of an audit logging process failure | Auto — Alerts |
| □ | AU.L2-3.3.5 | Correlate audit record review, analysis, and reporting processes for investigation | Manual |
| □ | AU.L2-3.3.6 | Provide audit record reduction and report generation to support analysis | Manual |
| □ | AU.L2-3.3.7 | Provide a system capability that compares and synchronizes internal system clocks with an authoritative source | Auto — Agent |
| □ | AU.L2-3.3.8 | Protect audit information and audit logging tools from unauthorized access, modification, and deletion | Auto — Agent |
| □ | AU.L2-3.3.9 | Limit management of audit logging functionality to a subset of privileged users | Manual |
Configuration Management (CM) — 9 Practices
| □ | Practice | Requirement | Assessment |
|---|---|---|---|
| □ | CM.L2-3.4.1 | Establish and maintain baseline configurations and inventories of organizational systems (including hardware, software, firmware, and documentation) throughout the respective system development life cycles | Manual |
| □ | CM.L2-3.4.2 | Establish and enforce security configuration settings for IT products employed in organizational systems | Auto — Agent |
| □ | CM.L2-3.4.3 | Track, review, approve or disapprove, and log changes to organizational systems | Manual |
| □ | CM.L2-3.4.4 | Analyze the security impact of changes prior to implementation | Manual |
| □ | CM.L2-3.4.5 | Define, document, approve, and enforce physical and logical access restrictions associated with changes | Manual |
| □ | CM.L2-3.4.6 | Employ the principle of least functionality — configure systems to provide only essential capabilities | Auto — Agent |
| □ | CM.L2-3.4.7 | Restrict, disable, or prevent the use of nonessential programs, functions, ports, protocols, and services | Auto — Agent |
| □ | CM.L2-3.4.8 | Apply deny-by-exception (blacklist) or permit-by-exception (whitelist) policy for unauthorized software | Manual |
| □ | CM.L2-3.4.9 | Control and monitor user-installed software | Auto — Agent |
Identification & Authentication (IA) — 11 Practices
| □ | Practice | Requirement | Assessment |
|---|---|---|---|
| □ | IA.L2-3.5.3 | Use multifactor authentication for local and network access to privileged accounts and for network access to non-privileged accounts | Auto — M365 |
| □ | IA.L2-3.5.4 | Employ replay-resistant authentication mechanisms for network access to privileged and non-privileged accounts | Auto |
| □ | IA.L2-3.5.5 | Prevent reuse of identifiers for a defined period | Manual |
| □ | IA.L2-3.5.6 | Disable identifiers after a defined period of inactivity | Auto — M365/Agent |
| □ | IA.L2-3.5.7 | Enforce a minimum password complexity and change of characters when new passwords are created | Auto — Agent |
| □ | IA.L2-3.5.8 | Prohibit password reuse for a specified number of generations | Auto — Agent |
| □ | IA.L2-3.5.9 | Allow temporary password use for system logons with an immediate change to a permanent password | Manual |
| □ | IA.L2-3.5.10 | Store and transmit only cryptographically protected passwords | Auto |
| □ | IA.L2-3.5.11 | Obscure feedback of authentication information during the authentication process | Manual |
Incident Response (IR) — 3 Practices
| □ | Practice | Requirement | Assessment |
|---|---|---|---|
| □ | IR.L2-3.6.1 | Establish an operational incident-handling capability for organizational systems that includes preparation, detection, analysis, containment, recovery, and user-response activities | Manual |
| □ | IR.L2-3.6.2 | Track, document, and report incidents to designated officials and/or authorities | Manual |
| □ | IR.L2-3.6.3 | Test the organizational incident response capability | Manual |
Maintenance (MA) — 6 Practices
| □ | Practice | Requirement | Assessment |
|---|---|---|---|
| □ | MA.L2-3.7.1 | Perform maintenance on organizational systems | Manual |
| □ | MA.L2-3.7.2 | Provide effective controls on tools, techniques, mechanisms, and personnel used to conduct system maintenance | Manual |
| □ | MA.L2-3.7.3 | Ensure equipment removed for off-site maintenance is sanitized of any CUI | Manual |
| □ | MA.L2-3.7.4 | Check media containing diagnostic and test programs for malicious code before use in organizational systems | Manual |
| □ | MA.L2-3.7.5 | Require multifactor authentication to establish nonlocal maintenance sessions, and terminate sessions when complete | Auto — M365 |
| □ | MA.L2-3.7.6 | Supervise the maintenance activities of maintenance personnel without required access authorization | Manual |
Media Protection (MP) — 9 Practices
| □ | Practice | Requirement | Assessment |
|---|---|---|---|
| □ | MP.L2-3.8.1 | Protect (physically control and securely store) system media containing CUI, both paper and digital | Manual |
| □ | MP.L2-3.8.2 | Limit access to CUI on system media to authorized users | Manual |
| □ | MP.L1-3.8.3 | Sanitize or destroy system media containing FCI before disposal or release for reuse (Level 1) | Manual |
| □ | MP.L2-3.8.4 | Mark media with necessary CUI markings and distribution limitations | Manual |
| □ | MP.L2-3.8.5 | Control access to media containing CUI and maintain accountability for media during transport outside controlled areas | Manual |
| □ | MP.L2-3.8.6 | Implement cryptographic mechanisms to protect the confidentiality of CUI stored on digital media during transport | Auto — BitLocker |
| □ | MP.L2-3.8.7 | Control the use of removable media on system components | Auto — Agent |
| □ | MP.L2-3.8.8 | Prohibit the use of portable storage devices when such devices have no identifiable owner | Manual |
| □ | MP.L2-3.8.9 | Protect the confidentiality of backup CUI at storage locations | Manual |
Personnel Security (PS) — 2 Practices
| □ | Practice | Requirement | Assessment |
|---|---|---|---|
| □ | PS.L2-3.9.1 | Screen individuals prior to authorizing access to organizational systems containing CUI | Manual |
| □ | PS.L2-3.9.2 | Ensure that organizational systems containing CUI are protected during and after personnel actions such as terminations and transfers | Manual |
Physical Protection (PE) — 6 Practices
| □ | Practice | Requirement | Assessment |
|---|---|---|---|
| □ | PE.L1-3.10.1 | Limit physical access to organizational systems and equipment to authorized individuals (Level 1) | Manual |
| □ | PE.L2-3.10.2 | Protect and monitor the physical facility and support infrastructure for organizational systems | Manual |
| □ | PE.L1-3.10.3 | Escort visitors and monitor visitor activity (Level 1) | Manual |
| □ | PE.L1-3.10.4 | Maintain audit logs of physical access (Level 1) | Manual |
| □ | PE.L1-3.10.5 | Control and manage physical access devices (Level 1) | Manual |
| □ | PE.L2-3.10.6 | Enforce safeguarding measures for CUI at alternate work sites | Manual |
Risk Assessment (RA) — 3 Practices
| □ | Practice | Requirement | Assessment |
|---|---|---|---|
| □ | RA.L2-3.11.1 | Periodically assess the risk to organizational operations (including mission, functions, image, or reputation), organizational assets, and individuals, resulting from the operation of organizational systems and the associated processing, storage, or transmission of CUI | Manual |
| □ | RA.L2-3.11.2 | Scan for vulnerabilities in organizational systems and applications periodically and when new vulnerabilities affecting those systems and applications are identified | Auto — Vuln Scan |
| □ | RA.L2-3.11.3 | Remediate vulnerabilities in accordance with risk assessments | Manual |
Security Assessment (CA) — 4 Practices
| □ | Practice | Requirement | Assessment |
|---|---|---|---|
| □ | CA.L2-3.12.1 | Periodically assess the security controls in organizational systems to determine if the controls are effective | Auto — Daily |
| □ | CA.L2-3.12.2 | Develop and implement plans of action designed to correct deficiencies and reduce or eliminate vulnerabilities (POA&M) | Manual |
| □ | CA.L2-3.12.3 | Monitor security controls on an ongoing basis to ensure the continued effectiveness of the controls | Auto — Continuous |
| □ | CA.L2-3.12.4 | Develop, document, and periodically update system security plans that describe system boundaries, system environments of operation, how security requirements are implemented, and the relationships with or connections to other systems | Manual |
System & Communications Protection (SC) — 16 Practices
| □ | Practice | Requirement | Assessment |
|---|---|---|---|
| □ | SC.L2-3.13.2 | Employ architectural designs, software development techniques, and systems engineering principles that promote effective information security | Manual |
| □ | SC.L2-3.13.3 | Separate user functionality from system management functionality | Manual |
| □ | SC.L2-3.13.4 | Prevent unauthorized and unintended information transfer via shared system resources | Auto — Agent |
| □ | SC.L2-3.13.6 | Deny network communications traffic by default and allow network communications traffic by exception | Auto — Firewall |
| □ | SC.L2-3.13.7 | Prevent remote devices from simultaneously establishing non-remote connections with organizational systems (split tunneling) | Auto — Agent |
| □ | SC.L2-3.13.8 | Implement cryptographic mechanisms to prevent unauthorized disclosure of CUI during transmission unless otherwise protected by alternative physical safeguards | Auto — TLS |
| □ | SC.L2-3.13.9 | Terminate network connections at the end of sessions or after a defined period of inactivity | Auto — Firewall |
| □ | SC.L2-3.13.10 | Establish and manage cryptographic keys for cryptography employed in organizational systems | Manual |
| □ | SC.L2-3.13.11 | Employ FIPS-validated cryptography when used to protect the confidentiality of CUI | Auto — Agent |
| □ | SC.L2-3.13.12 | Prohibit remote activation of collaborative computing devices and provide indication of devices in use to users present at the device | Manual |
| □ | SC.L2-3.13.13 | Control and monitor the use of mobile code | Manual |
| □ | SC.L2-3.13.14 | Control and monitor the use of Voice over Internet Protocol (VoIP) technologies | Manual |
| □ | SC.L2-3.13.15 | Protect the authenticity of communications sessions | Auto — TLS/HTTPS |
| □ | SC.L2-3.13.16 | Protect the confidentiality of CUI at rest | Auto — BitLocker |
System & Information Integrity (SI) — 7 Practices
| □ | Practice | Requirement | Assessment |
|---|---|---|---|
| □ | SI.L2-3.14.3 | Monitor system security alerts and advisories and take action in response | Auto — Alerts |
| □ | SI.L2-3.14.6 | Monitor organizational systems including inbound and outbound communications traffic, to detect attacks and indicators of potential attacks | Auto — Daily |
| □ | SI.L2-3.14.7 | Identify unauthorized use of organizational systems | Auto — Logins |
Which CMMC Practices Can Be Automated?
Approximately 60-70% of CMMC Level 2 technical practices can be assessed automatically with the right tooling. SBCMSP covers the external attack surface (encryption, headers, DNS, authentication exposure) and internal workstation/server controls (patching, BitLocker, AD hardening, audit policy).
Access & Identity: AC.L2-3.1.5/6/8/10/11/12/13/17/19, IA.L2-3.5.3/4/6/7/8/10. Audit & Logging: AU.L2-3.3.1/2/4/7/8. Config Hardening: CM.L2-3.4.2/6/7/9. Encryption & Network: SC.L2-3.13.4/6/7/8/9/11/15/16, MP.L2-3.8.6/7. Risk & Assessment: RA.L2-3.11.2, CA.L2-3.12.1/3. Monitoring: SI.L1-3.14.2/5, SI.L2-3.14.3/6/7. Wireless & Maintenance: AC.L2-3.1.17, MA.L2-3.7.5. Approximately 40 of the 110 practices have a direct automated check.
The remaining ~70 practices — policy documentation (AT, IR, PS), physical security (PE), personnel screening, supply chain management, incident response procedures, change management approvals, media handling, system security plans — require manual documentation review, attestations, or process observation. No tool can substitute for those evidence packages. SBCMSP's Compliance reports surface gaps in the automated controls so you can spend assessment-prep time on the manual ones.
CMMC 2.0 Timeline & Enforcement
CMMC 2.0 is being phased into DoD contracts following the final rule effective December 16, 2024:
Phase 1 (now): CMMC Level 1 self-assessment required in DFARS contracts. Level 2 self-assessment for some contracts.
Phase 2 (late 2025): Level 2 C3PAO assessments required for contracts with critical CUI. Self-assessments accepted for non-critical CUI.
Phase 3 (2026): Full rollout. All Level 2 and 3 contracts require certified assessments.
MSPs supporting DoD contractors are typically considered "managed service providers" under the CMMC framework and must also demonstrate compliance when they have access to client CUI systems.
Next Steps for MSPs
If you're an MSP helping clients prepare for CMMC:
1. Assess first. Run a CMMC assessment on each client to identify gaps before their contracts require certification.
2. Document everything. CMMC assessors review documentation. Start your clients' System Security Plan (SSP) and Plan of Action & Milestones (POA&M) now.
3. Automate the technical controls. Use tooling to continuously verify technical controls rather than relying on annual assessment snapshots.
4. Monitor continuously. A control that passed last quarter can fail today. Continuous monitoring catches regressions before your client's next assessment.