AthenaCMMC Level 2Self-assessment
Level 2 (Self) checklist

The CMMC Level 2 Checklist: All 110 Controls for a Level 2 (Self) Assessment

This CMMC self assessment checklist covers the 110 security requirements of NIST SP 800-171 Rev. 2. Use it for a NIST 800-171 self-assessment, graded objective by objective against NIST SP 800-171A. During the current suspension of the C3PAO phase-in, DoD requirements may designate only Level 1 (Self) or Level 2 (Self). You score yourself, post the result to SPRS, and a senior Affirming Official attests to it. Build to the standard a C3PAO would test anyway.

Status reflects the July 2026 Phase 2 suspension.

By Doug Majewski, President, Athena Consulting Group, LLC · Last reviewed: October 17, 2026

Self-assessment progress

Answered
0 / 110
Met
0
Not met
0
Not applicable
0

A practice is only Met when every applicable assessment objective beneath it is satisfied. If even one objective fails, the whole practice is Not Met. Answering here produces a readiness view and a gap report — it is not a certification and not an official assessment result.

Not Applicable is not the same as Met. N/A is only offered for the specific requirements where it is documented as potentially valid, it never counts as a satisfied practice, and it needs a written justification an assessor can test. Practices satisfied (0) counts Met answers only.

Assess the 110 requirements

  • AC.L2-3.1.1
    6 objectives

    Limit system access to authorized users, processes acting on behalf of authorized users, and devices (including other systems).

    Status for AC.L2-3.1.1
  • AC.L2-3.1.2
    2 objectives

    Limit system access to the types of transactions and functions that authorized users are permitted to execute.

    Status for AC.L2-3.1.2
  • AC.L2-3.1.3
    5 objectives

    Control the flow of CUI in accordance with approved authorizations.

    Status for AC.L2-3.1.3
  • AC.L2-3.1.4
    3 objectives

    Separate the duties of individuals to reduce the risk of malevolent activity without collusion.

    Status for AC.L2-3.1.4
  • AC.L2-3.1.5
    4 objectives

    Employ the principle of least privilege, including for specific security functions and privileged accounts.

    Status for AC.L2-3.1.5
  • AC.L2-3.1.6
    2 objectives

    Use non-privileged accounts or roles when accessing nonsecurity functions.

    Status for AC.L2-3.1.6
  • AC.L2-3.1.7
    4 objectives

    Prevent non-privileged users from executing privileged functions and capture the execution of such functions in audit logs.

    Status for AC.L2-3.1.7
  • AC.L2-3.1.8
    2 objectives

    Limit unsuccessful logon attempts.

    Status for AC.L2-3.1.8
  • AC.L2-3.1.9
    2 objectives

    Provide privacy and security notices consistent with applicable CUI rules.

    Status for AC.L2-3.1.9
  • AC.L2-3.1.10
    3 objectives

    Use session lock with pattern-hiding displays to prevent access and viewing of data after a period of inactivity.

    Status for AC.L2-3.1.10
  • AC.L2-3.1.11
    2 objectives

    Terminate (automatically) a user session after a defined condition.

    Status for AC.L2-3.1.11
  • AC.L2-3.1.12
    4 objectives

    Monitor and control remote access sessions.

    Not applicable is only valid here: Only if no remote access to in-scope systems is permitted at all.

    Status for AC.L2-3.1.12
  • AC.L2-3.1.13
    2 objectives

    Employ cryptographic mechanisms to protect the confidentiality of remote access sessions.

    Not applicable is only valid here: Only if no remote access to in-scope systems is permitted at all.

    Status for AC.L2-3.1.13
  • AC.L2-3.1.14
    2 objectives

    Route remote access via managed access control points.

    Not applicable is only valid here: Only if no remote access to in-scope systems is permitted at all.

    Status for AC.L2-3.1.14
  • AC.L2-3.1.15
    4 objectives

    Authorize remote execution of privileged commands and remote access to security-relevant information.

    Not applicable is only valid here: Only if no remote access to in-scope systems is permitted at all.

    Status for AC.L2-3.1.15
  • AC.L2-3.1.16
    2 objectives

    Authorize wireless access prior to allowing such connections.

    Not applicable is only valid here: Only if no wireless access exists in the assessment scope.

    Status for AC.L2-3.1.16
  • AC.L2-3.1.17
    2 objectives

    Protect wireless access using authentication and encryption.

    Not applicable is only valid here: Only if no wireless access exists in the assessment scope.

    Status for AC.L2-3.1.17
  • AC.L2-3.1.18
    3 objectives

    Control connection of mobile devices.

    Not applicable is only valid here: Only if no mobile devices connect to in-scope systems.

    Status for AC.L2-3.1.18
  • AC.L2-3.1.19
    2 objectives

    Encrypt CUI on mobile devices and mobile computing platforms.

    Not applicable is only valid here: Only if CUI is never stored on mobile devices or platforms.

    Status for AC.L2-3.1.19
  • AC.L2-3.1.20
    6 objectives

    Verify and control/limit connections to and use of external systems.

    Not applicable is only valid here: Only if there are no external systems or connections in scope.

    Status for AC.L2-3.1.20
  • AC.L2-3.1.21
    3 objectives

    Limit use of portable storage devices on external systems.

    Not applicable is only valid here: Only if portable storage on external systems is technically impossible.

    Status for AC.L2-3.1.21
  • AC.L2-3.1.22
    5 objectives

    Control CUI posted or processed on publicly accessible systems.

    Not applicable is only valid here: Only if no publicly accessible system is operated in scope.

    Status for AC.L2-3.1.22
  • AT.L2-3.2.1
    4 objectives

    Ensure that managers, systems 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.

    Status for AT.L2-3.2.1
  • AT.L2-3.2.2
    3 objectives

    Ensure that personnel are trained to carry out their assigned information security-related duties and responsibilities.

    Status for AT.L2-3.2.2
  • AT.L2-3.2.3
    2 objectives

    Provide security awareness training on recognizing and reporting potential indicators of insider threat.

    Status for AT.L2-3.2.3
  • AU.L2-3.3.1
    6 objectives

    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.

    Status for AU.L2-3.3.1
  • AU.L2-3.3.2
    2 objectives

    Ensure that the actions of individual system users can be uniquely traced to those users so they can be held accountable for their actions.

    Status for AU.L2-3.3.2
  • AU.L2-3.3.3
    3 objectives

    Review and update logged events.

    Status for AU.L2-3.3.3
  • AU.L2-3.3.4
    3 objectives

    Alert in the event of an audit logging process failure.

    Status for AU.L2-3.3.4
  • AU.L2-3.3.5
    2 objectives

    Correlate audit record review, analysis, and reporting processes for investigation and response to indications of unlawful, unauthorized, suspicious, or unusual activity.

    Status for AU.L2-3.3.5
  • AU.L2-3.3.6
    2 objectives

    Provide audit record reduction and report generation to support on-demand analysis and reporting.

    Status for AU.L2-3.3.6
  • AU.L2-3.3.7
    3 objectives

    Provide a system capability that compares and synchronizes internal system clocks with an authoritative source to generate time stamps for audit records.

    Status for AU.L2-3.3.7
  • AU.L2-3.3.8
    6 objectives

    Protect audit information and audit logging tools from unauthorized access, modification, and deletion.

    Status for AU.L2-3.3.8
  • AU.L2-3.3.9
    2 objectives

    Limit management of audit logging functionality to a subset of privileged users.

    Status for AU.L2-3.3.9
  • CM.L2-3.4.1
    6 objectives

    Establish and maintain baseline configurations and inventories of organizational systems (including hardware, software, firmware, and documentation) throughout the respective system development life cycles.

    Status for CM.L2-3.4.1
  • CM.L2-3.4.2
    2 objectives

    Establish and enforce security configuration settings for information technology products employed in organizational systems.

    Status for CM.L2-3.4.2
  • CM.L2-3.4.3
    4 objectives

    Track, review, approve or disapprove, and log changes to organizational systems.

    Status for CM.L2-3.4.3
  • CM.L2-3.4.4
    1 objectives

    Analyze the security impact of changes prior to implementation.

    Status for CM.L2-3.4.4
  • CM.L2-3.4.5
    8 objectives

    Define, document, approve, and enforce physical and logical access restrictions associated with changes to organizational systems.

    Status for CM.L2-3.4.5
  • CM.L2-3.4.6
    2 objectives

    Employ the principle of least functionality by configuring organizational systems to provide only essential capabilities.

    Status for CM.L2-3.4.6
  • CM.L2-3.4.7
    15 objectives

    Restrict, disable, or prevent the use of nonessential programs, functions, ports, protocols, and services.

    Status for CM.L2-3.4.7
  • CM.L2-3.4.8
    3 objectives

    Apply deny-by-exception (blacklisting) policy to prevent the use of unauthorized software or deny-all, permit-by-exception (whitelisting) policy to allow the execution of authorized software.

    Status for CM.L2-3.4.8
  • CM.L2-3.4.9
    3 objectives

    Control and monitor user-installed software.

    Status for CM.L2-3.4.9
  • IA.L2-3.5.1
    3 objectives

    Identify system users, processes acting on behalf of users, and devices.

    Status for IA.L2-3.5.1
  • IA.L2-3.5.2
    3 objectives

    Authenticate (or verify) the identities of users, processes, or devices, as a prerequisite to allowing access to organizational systems.

    Status for IA.L2-3.5.2
  • IA.L2-3.5.3
    4 objectives

    Use multifactor authentication for local and network access to privileged accounts and for network access to non-privileged accounts.

    Status for IA.L2-3.5.3
  • IA.L2-3.5.4
    1 objectives

    Employ replay-resistant authentication mechanisms for network access to privileged and non-privileged accounts.

    Status for IA.L2-3.5.4
  • IA.L2-3.5.5
    2 objectives

    Prevent reuse of identifiers for a defined period.

    Status for IA.L2-3.5.5
  • IA.L2-3.5.6
    2 objectives

    Disable identifiers after a defined period of inactivity.

    Status for IA.L2-3.5.6
  • IA.L2-3.5.7
    4 objectives

    Enforce a minimum password complexity and change of characters when new passwords are created.

    Status for IA.L2-3.5.7
  • IA.L2-3.5.8
    2 objectives

    Prohibit password reuse for a specified number of generations.

    Status for IA.L2-3.5.8
  • IA.L2-3.5.9
    1 objectives

    Allow temporary password use for system logons with an immediate change to a permanent password.

    Status for IA.L2-3.5.9
  • IA.L2-3.5.10
    2 objectives

    Store and transmit only cryptographically-protected passwords.

    Status for IA.L2-3.5.10
  • IA.L2-3.5.11
    1 objectives

    Obscure feedback of authentication information.

    Status for IA.L2-3.5.11
  • IR.L2-3.6.1
    7 objectives

    Establish an operational incident-handling capability for organizational systems that includes preparation, detection, analysis, containment, recovery, and user response activities.

    Status for IR.L2-3.6.1
  • IR.L2-3.6.2
    6 objectives

    Track, document, and report incidents to designated officials and/or authorities both internal and external to the organization.

    Status for IR.L2-3.6.2
  • IR.L2-3.6.3
    1 objectives

    Test the organizational incident response capability.

    Status for IR.L2-3.6.3
  • MA.L2-3.7.1
    1 objectives

    Perform maintenance on organizational systems.

    Status for MA.L2-3.7.1
  • MA.L2-3.7.2
    4 objectives

    Provide controls on the tools, techniques, mechanisms, and personnel used to conduct system maintenance.

    Status for MA.L2-3.7.2
  • MA.L2-3.7.3
    1 objectives

    Ensure equipment removed for off-site maintenance is sanitized of any CUI.

    Status for MA.L2-3.7.3
  • MA.L2-3.7.4
    1 objectives

    Check media containing diagnostic and test programs for malicious code before the media are used in organizational systems.

    Status for MA.L2-3.7.4
  • MA.L2-3.7.5
    2 objectives

    Require multifactor authentication to establish nonlocal maintenance sessions via external network connections and terminate such connections when nonlocal maintenance is complete.

    Status for MA.L2-3.7.5
  • MA.L2-3.7.6
    1 objectives

    Supervise the maintenance activities of maintenance personnel without required access authorization.

    Status for MA.L2-3.7.6
  • MP.L2-3.8.1
    4 objectives

    Protect (i.e., physically control and securely store) system media containing CUI, both paper and digital.

    Status for MP.L2-3.8.1
  • MP.L2-3.8.2
    1 objectives

    Limit access to CUI on system media to authorized users.

    Status for MP.L2-3.8.2
  • MP.L2-3.8.3
    2 objectives

    Sanitize or destroy system media containing CUI before disposal or release for reuse.

    Status for MP.L2-3.8.3
  • MP.L2-3.8.4
    2 objectives

    Mark media with necessary CUI markings and distribution limitations.

    Status for MP.L2-3.8.4
  • MP.L2-3.8.5
    2 objectives

    Control access to media containing CUI and maintain accountability for media during transport outside of controlled areas.

    Status for MP.L2-3.8.5
  • MP.L2-3.8.6
    1 objectives

    Implement cryptographic mechanisms to protect the confidentiality of CUI stored on digital media during transport unless otherwise protected by alternative physical safeguards.

    Not applicable is only valid here: Only if CUI is never transported outside controlled areas on digital media.

    Status for MP.L2-3.8.6
  • MP.L2-3.8.7
    1 objectives

    Control the use of removable media on system components.

    Status for MP.L2-3.8.7
  • MP.L2-3.8.8
    1 objectives

    Prohibit the use of portable storage devices when such devices have no identifiable owner.

    Status for MP.L2-3.8.8
  • MP.L2-3.8.9
    1 objectives

    Protect the confidentiality of backup CUI at storage locations.

    Status for MP.L2-3.8.9
  • PS.L2-3.9.1
    1 objectives

    Screen individuals prior to authorizing access to organizational systems containing CUI.

    Status for PS.L2-3.9.1
  • PS.L2-3.9.2
    3 objectives

    Ensure that organizational systems containing CUI are protected during and after personnel actions such as terminations and transfers.

    Status for PS.L2-3.9.2
  • PE.L2-3.10.1
    4 objectives

    Limit physical access to organizational systems, equipment, and the respective operating environments to authorized individuals.

    Status for PE.L2-3.10.1
  • PE.L2-3.10.2
    4 objectives

    Protect and monitor the physical facility and support infrastructure for organizational systems.

    Status for PE.L2-3.10.2
  • PE.L2-3.10.3
    2 objectives

    Escort visitors and monitor visitor activity.

    Status for PE.L2-3.10.3
  • PE.L2-3.10.4
    1 objectives

    Maintain audit logs of physical access.

    Status for PE.L2-3.10.4
  • PE.L2-3.10.5
    3 objectives

    Control and manage physical access devices.

    Status for PE.L2-3.10.5
  • PE.L2-3.10.6
    2 objectives

    Enforce safeguarding measures for CUI at alternate work sites.

    Not applicable is only valid here: Only if no alternate work sites are used for in-scope work.

    Status for PE.L2-3.10.6
  • RA.L2-3.11.1
    2 objectives

    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.

    Status for RA.L2-3.11.1
  • RA.L2-3.11.2
    5 objectives

    Scan for vulnerabilities in organizational systems and applications periodically and when new vulnerabilities affecting those systems and applications are identified.

    Status for RA.L2-3.11.2
  • RA.L2-3.11.3
    2 objectives

    Remediate vulnerabilities in accordance with risk assessments.

    Status for RA.L2-3.11.3
  • CA.L2-3.12.1
    2 objectives

    Periodically assess the security controls in organizational systems to determine if the controls are effective in their application.

    Status for CA.L2-3.12.1
  • CA.L2-3.12.2
    3 objectives

    Develop and implement plans of action designed to correct deficiencies and reduce or eliminate vulnerabilities in organizational systems.

    Status for CA.L2-3.12.2
  • CA.L2-3.12.3
    1 objectives

    Monitor security controls on an ongoing basis to ensure the continued effectiveness of the controls.

    Status for CA.L2-3.12.3
  • CA.L2-3.12.4
    8 objectives

    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.

    Status for CA.L2-3.12.4
  • SC.L2-3.13.1
    8 objectives

    Monitor, control, and protect communications (i.e., information transmitted or received by organizational systems) at the external boundaries and key internal boundaries of organizational systems.

    Status for SC.L2-3.13.1
  • SC.L2-3.13.2
    6 objectives

    Employ architectural designs, software development techniques, and systems engineering principles that promote effective information security within organizational systems.

    Status for SC.L2-3.13.2
  • SC.L2-3.13.3
    3 objectives

    Separate user functionality from system management functionality.

    Status for SC.L2-3.13.3
  • SC.L2-3.13.4
    1 objectives

    Prevent unauthorized and unintended information transfer via shared system resources.

    Status for SC.L2-3.13.4
  • SC.L2-3.13.5
    2 objectives

    Implement subnetworks for publicly accessible system components that are physically or logically separated from internal networks.

    Status for SC.L2-3.13.5
  • SC.L2-3.13.6
    2 objectives

    Deny network communications traffic by default and allow network communications traffic by exception (i.e., deny all, permit by exception).

    Status for SC.L2-3.13.6
  • SC.L2-3.13.7
    1 objectives

    Prevent remote devices from simultaneously establishing non-remote connections with organizational systems and communicating via some other connection to resources in external networks (i.e., split tunneling).

    Not applicable is only valid here: Only if no remote devices establish non-remote connections.

    Status for SC.L2-3.13.7
  • SC.L2-3.13.8
    3 objectives

    Implement cryptographic mechanisms to prevent unauthorized disclosure of CUI during transmission unless otherwise protected by alternative physical safeguards.

    Status for SC.L2-3.13.8
  • SC.L2-3.13.9
    3 objectives

    Terminate network connections associated with communications sessions at the end of the sessions or after a defined period of inactivity.

    Status for SC.L2-3.13.9
  • SC.L2-3.13.10
    2 objectives

    Establish and manage cryptographic keys for cryptography employed in organizational systems.

    Status for SC.L2-3.13.10
  • SC.L2-3.13.11
    1 objectives

    Employ FIPS-validated cryptography when used to protect the confidentiality of CUI.

    Status for SC.L2-3.13.11
  • SC.L2-3.13.12
    3 objectives

    Prohibit remote activation of collaborative computing devices and provide indication of devices in use to users present at the device.

    Not applicable is only valid here: Only if no collaborative computing devices exist in scope.

    Status for SC.L2-3.13.12
  • SC.L2-3.13.13
    2 objectives

    Control and monitor the use of mobile code.

    Not applicable is only valid here: Only if mobile code is not used in scope.

    Status for SC.L2-3.13.13
  • SC.L2-3.13.14
    2 objectives

    Control and monitor the use of Voice over Internet Protocol (VoIP) technologies.

    Not applicable is only valid here: Only if Voice over IP is not used in scope.

    Status for SC.L2-3.13.14
  • SC.L2-3.13.15
    1 objectives

    Protect the authenticity of communications sessions.

    Status for SC.L2-3.13.15
  • SC.L2-3.13.16
    1 objectives

    Protect the confidentiality of CUI at rest.

    Status for SC.L2-3.13.16
  • SI.L2-3.14.1
    6 objectives

    Identify, report, and correct system flaws in a timely manner.

    Status for SI.L2-3.14.1
  • SI.L2-3.14.2
    2 objectives

    Provide protection from malicious code at designated locations within organizational systems.

    Status for SI.L2-3.14.2
  • SI.L2-3.14.3
    3 objectives

    Monitor system security alerts and advisories and take action in response.

    Status for SI.L2-3.14.3
  • SI.L2-3.14.4
    1 objectives

    Update malicious code protection mechanisms when new releases are available.

    Status for SI.L2-3.14.4
  • SI.L2-3.14.5
    3 objectives

    Perform periodic scans of organizational systems and real-time scans of files from external sources as files are downloaded, opened, or executed.

    Status for SI.L2-3.14.5
  • SI.L2-3.14.6
    3 objectives

    Monitor organizational systems, including inbound and outbound communications traffic, to detect attacks and indicators of potential attacks.

    Status for SI.L2-3.14.6
  • SI.L2-3.14.7
    2 objectives

    Identify unauthorized use of organizational systems.

    Status for SI.L2-3.14.7

Prioritized gap report

Nothing marked Not Met yet. Gaps appear here ordered by the points each one costs.

Sanitized example

Fictional contractor "Northgate Precision LLC". No real system names, hostnames, IPs, or findings — deliberately generic so it is safe to share.

Northgate Precision marks CM.L2-3.4.1 Not Met because their baseline configuration is documented for servers but not laptops — objective 3.4.1[a] fails, so the whole practice is Not Met. They mark AC.L2-3.1.16 Not Applicable with the justification "no wireless networking exists in the CUI enclave; wireless radios disabled by policy" — an assessor will test that claim, so it must be true.

One path forward

Free result → 7-day free trial → Athena workspace

  1. Free, right now: keep the result and downloads from this tool. No account, no e-mail required.
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  3. Athena workspace / evidence sprint: continuous objective-level tracking, evidence defensibility scoring, and assessor-ready artifacts.

Athena works at the assessment-objective level, keeps a provenance trail for every artifact, and scores how defensible your evidence is. We do not guarantee a certification outcome — no tool or consultant can.

The other free CMMC tools

Score all 110 requirements with official weighted deductions.
Every NIST SP 800-171A Rev. 2 objective with evidence planning.
Categorize assets and define your assessment boundary.
Build a DoD-oriented POA&M with eligibility warnings.
Day-one evidence list, mock intake, and readiness verdict.

Educational readiness aid. This is not legal advice, not an official assessment, not a certification, and not a submitted SPRS score. Your assessment results and any affirmation remain your organization's responsibility.

What changed in 2026: why Level 2 (Self) is the path contractors face now

The short version: the third-party phase-in is on hold, and the security requirements are not.

  • The suspension. On July 13, 2026, the Department of War suspended the November 2026 Phase 2 transition. During the suspension, DoD requirements may designate only CMMC Level 1 (Self) or Level 2 (Self).
  • Existing contracts. DoD has directed contracting officers to remove Level 2 (C3PAO) and Level 3 (DIBCAC) requirements from active solicitations and, by modification, from existing contracts.
  • The NIST assessment clause. Under DoD's current class deviation, contracting officers use DFARS 252.240-7997 for NIST SP 800-171 DoD Assessment requirements. The CMMC levels themselves remain in DFARS 252.204-7021.
  • The underlying obligation has not moved. DFARS 252.204-7012 still requires NIST SP 800-171 (DoD currently enforces Revision 2). It also requires you to report cyber incidents to DoD via DIBNet within 72 hours of discovery.
  • No end date yet. As of mid-October 2026, DoD has not announced an end to the Phase 2 suspension. Treat everything on this page as current to the Last reviewed date, and check CMMC status for updates.

A self-assessment is not an easier test. To reach Final Level 2 (Self), every requirement must be MET under the CMMC Scoring Methodology. A requirement is MET only when every applicable NIST SP 800-171A objective is satisfied. DoD also reserves the right to run a DCMA DIBCAC assessment of your organization. If your self-score would not survive that review, it is not a real score.

Which self-assessment does your contract actually call for?

Contractors use the phrase "NIST 800-171 self assessment checklist" for two different obligations. The control work is identical. The paperwork is not.

CMMC Level 2 (Self)NIST SP 800-171 DoD Assessment (Basic)
Where it comes fromThe CMMC requirement in your solicitation or contract (DFARS 252.204-7021), under 32 CFR 170.16The NIST SP 800-171 DoD Assessment clause. Under the current class deviation that is DFARS 252.240-7997; older contracts may still carry 252.204-7019/-7020
What you assessThe 110 requirements of NIST SP 800-171 Rev. 2, against the NIST SP 800-171A objectivesThe same 110 requirements
How you scoreCMMC Scoring Methodology (32 CFR 170.24)DoD Assessment Methodology
What goes into SPRSCMMC level, CMMC Status Date, assessment scope, all CAGE codes in scope, overall score, and POA&M usage and statusThe Basic Assessment summary score and related fields
AffirmationRequired: at completion, at POA&M closeout, and annually after a Final statusNot part of the Basic Assessment itself
How oftenEvery 3 years, with annual affirmationsPer the clause

The work is the same 110 requirements and the same objectives. If you build to the Level 2 (Self) standard, you cover both. Read the clause in your contract or solicitation before you submit anything. The clause decides which SPRS entry you owe.

How the self-assessment works

Under the July 2026 suspension of the C3PAO phase-in, Level 2 (Self) is the CMMC assessment new DoD requirements can designate. Check the clause in yours. The standard has not changed. Every one of the 110 requirements has to be MET against the NIST SP 800-171A objectives, so build and evidence each control to the standard a C3PAO would test.

The workflow, at a glance:

  1. Scope. Identify the assets that process, store or transmit CUI, plus the Security Protection Assets that protect them (32 CFR 170.19(c)). Wrong scope = wrong score. Start with Scope Check and the CUI boundary guide.
  2. Assess every objective. Work through each of the 110 requirements against NIST SP 800-171A, using the EXAMINE, INTERVIEW and TEST methods. Grading is all-or-nothing per requirement.
  3. Score. Start at 110 and subtract the value of each NOT MET requirement under the CMMC Scoring Methodology (32 CFR 170.24).
  4. POA&M. Only put on the POA&M what 32 CFR 170.21(a)(2) allows: the score ratio must be at least 0.8 (88 of 110), the items must be 1-point requirements (with the 3.13.11 non-FIPS exception), and none of the six excluded requirements can appear. Close it out within 180 days of the Conditional CMMC Status Date.
  5. Submit to SPRS. Enter the CMMC level, CMMC Status Date, assessment scope, all CAGE codes in scope, the overall score, and POA&M usage and status.
  6. Affirm. The Affirming Official attests in SPRS at completion, again after any POA&M closeout, and annually after a Final status. See the affirmation step below.

Score it before anyone signs it.

Run the free Quick Score against all 110 requirements and see where the deductions land.

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The 14 domains — 110 controls total

CodeDomainControlsWhat it coversEvidence guides
ACAccess Control22Least privilege, session control, remote access, external systems.3.1.1 · 3.1.2 · 3.1.20
ATAwareness & Training3Security awareness for users and privileged roles.Control library
AUAudit & Accountability9Logging, review, protection, and retention of audit records.3.3.1
CMConfiguration Management9Baselines, change control, least functionality, USB/software allow-lists.3.4.1 · 3.4.2
IAIdentification & Authentication11Unique IDs, MFA, password complexity, credential management.3.5.1 · 3.5.2 · 3.5.3 · 3.5.3 government cloud
IRIncident Response3IR plan, handling, reporting, and testing.3.6.1 · 3.6.2
MAMaintenance6Controlled maintenance, media sanitization, remote maintenance MFA.Control library
MPMedia Protection9Marking, storage, transport, and sanitization of media and CUI.3.8.3
PSPersonnel Security2Screening and termination/transfer procedures.Control library
PEPhysical Protection6Facility access, visitor logs, alternate sites, monitoring.Control library
RARisk Assessment3Risk assessments and vulnerability scanning cadence.3.11.2
CASecurity Assessment4SSP, control assessment, POA&M, continuous monitoring.3.12.1 · 3.12.2 · 3.12.4
SCSystem & Communications Protection16Boundary protection, FIPS crypto, session termination, DNS.3.13.1 · 3.13.2 · 3.13.5 · 3.13.8 · 3.13.11
SISystem & Information Integrity7Flaw remediation, malicious code protection, monitoring, alerts.3.14.1 · 3.14.2 · 3.14.6
—Total110

How to self-score: the CMMC Scoring Methodology

You start at 110, the total number of Level 2 requirements. Each requirement carries a value of 1, 3 or 5 points, assigned by the CMMC Scoring Methodology in 32 CFR 170.24. Use the values in the rule. This page does not restate per-control values.

The rules that decide your number:

  • Objectives decide the requirement. If one or more applicable NIST SP 800-171A objectives are not satisfied, the requirement is NOT MET, and you lose its full value.
  • N/A counts as MET. An objective assessed as N/A is treated the same as MET. Write down why it does not apply. An assessor will ask.
  • Two requirements can earn partial credit: IA.L2-3.5.3 (multifactor authentication) and SC.L2-3.13.11 (FIPS-validated cryptography). The deductions depend on how far the control is implemented. Use the values in 32 CFR 170.24(c)(2)(i)(B)(4).
  • A POA&M is not a fix. A requirement that has not been implemented is NOT MET, whether or not it appears on a POA&M.
  • Scores can go negative. 32 CFR 170.24 says the subtraction "may result in a negative score." Adding up every deduction the rule lists gives a lowest possible Level 2 score of −203. That figure is derived; the rule itself states no floor.

Conditional vs Final status

  • Final Level 2 (Self). Every requirement is MET, which is the maximum score of 110 (32 CFR 170.16(a)(1); 170.24(c)(2)). You can reach it at the start or after you close out your POA&M.
  • Conditional Level 2 (Self). Your self-assessment produces a POA&M that meets every condition in 32 CFR 170.21(a)(2):
    • the score divided by 110 is at least 0.8, which is 88 points;
    • every requirement on the POA&M is worth 1 point. The one exception is SC.L2-3.13.11, which may be on the POA&M when encryption is used but is not FIPS-validated;
    • none of these six requirements is on the POA&M: AC.L2-3.1.20, AC.L2-3.1.22, CA.L2-3.12.4, PE.L2-3.10.3, PE.L2-3.10.4, PE.L2-3.10.5.
  • The 180-day clock. You must close out the POA&M within 180 days of the Conditional CMMC Status Date. If you don't, Conditional status expires, and for Level 2 (Self) standard contractual remedies apply.
  • Below that bar there is no CMMC status, and you cannot receive an award where the contract requires one.

For what to POA&M and how to write it, see the CMMC POA&M template and the POA&M generator. For the arithmetic with worked examples, see how to calculate your SPRS score.

The CMMC Level 2 checklist by family: what to check and the evidence to keep

Each family below gives three things:

  • the requirement list, using the NIST SP 800-171 Rev. 2 requirement numbers with short names abridged from the NIST statements;
  • what an assessor would EXAMINE, INTERVIEW and TEST;
  • the failure pattern we see most often.

Lineage runs Practice ID (e.g. AC.L2-3.1.1) → NIST SP 800-171 Rev. 2 requirement 3.1.1 → its NIST SP 800-171A objectives.

Access Control (AC): 22 requirements, 3.1.1–3.1.22

All 22 AC requirements
  • 3.1.1 Limit system access to authorized users, processes and devices
  • 3.1.2 Limit system access to the transactions and functions users are permitted to execute
  • 3.1.3 Control the flow of CUI per approved authorizations
  • 3.1.4 Separate the duties of individuals
  • 3.1.5 Employ least privilege, including for security functions and privileged accounts
  • 3.1.6 Use non-privileged accounts or roles for nonsecurity functions
  • 3.1.7 Prevent non-privileged users from executing privileged functions; log such execution
  • 3.1.8 Limit unsuccessful logon attempts
  • 3.1.9 Provide privacy and security notices consistent with CUI rules
  • 3.1.10 Use session lock with pattern-hiding displays after inactivity
  • 3.1.11 Terminate user sessions automatically after a defined condition
  • 3.1.12 Monitor and control remote access sessions
  • 3.1.13 Use cryptographic mechanisms to protect remote access sessions
  • 3.1.14 Route remote access via managed access control points
  • 3.1.15 Authorize remote execution of privileged commands and remote access to security-relevant information
  • 3.1.16 Authorize wireless access before allowing connections
  • 3.1.17 Protect wireless access using authentication and encryption
  • 3.1.18 Control connection of mobile devices
  • 3.1.19 Encrypt CUI on mobile devices and mobile computing platforms
  • 3.1.20 Verify and control/limit connections to and use of external systems
  • 3.1.21 Limit use of portable storage devices on external systems
  • 3.1.22 Control CUI posted or processed on publicly accessible systems
  • EXAMINE: the access control policy, an IdP user and role export, the privileged account list, the remote access configuration, and a CUI flow diagram.
  • INTERVIEW: the IT administrator, on joiner/mover/leaver handling.
  • TEST: log in as a standard user and try a privileged function.
  • Common failure: there is no list of authorized external systems for 3.1.20. That requirement cannot go on a POA&M, so the gap blocks Conditional status.
  • Evidence guides: 3.1.1 access control, 3.1.2 least privilege, 3.1.20 external connections.

Awareness & Training (AT): 3 requirements, 3.2.1–3.2.3

All 3 AT requirements
  • 3.2.1 Make managers, administrators and users aware of security risks and applicable policies and procedures
  • 3.2.2 Train personnel to carry out their security-related duties
  • 3.2.3 Provide awareness training on recognizing and reporting insider threat indicators
  • EXAMINE: the training content, dated completion records, and the insider-threat module.
  • INTERVIEW: a randomly chosen user, about what they would report and to whom.
  • Common failure: generic training with no CUI handling or insider-threat content.
  • Evidence guides: control library.

Audit & Accountability (AU): 9 requirements, 3.3.1–3.3.9

All 9 AU requirements
  • 3.3.1 Create and retain system audit logs and records
  • 3.3.2 Ensure user actions can be uniquely traced to those users
  • 3.3.3 Review and update logged events
  • 3.3.4 Alert on an audit logging process failure
  • 3.3.5 Correlate audit record review, analysis and reporting
  • 3.3.6 Provide audit record reduction and report generation
  • 3.3.7 Synchronize system clocks with an authoritative time source
  • 3.3.8 Protect audit information and logging tools from unauthorized access, modification and deletion
  • 3.3.9 Limit management of audit logging to a subset of privileged users
  • EXAMINE: the log source inventory, retention settings, review records, and the time-sync configuration.
  • TEST: generate an event and trace it all the way to the SIEM or log store.
  • Common failure: logs are collected but nobody reviews them, and there is no record that a review ever happened.
  • Evidence guides: 3.3.1 audit logging.

Configuration Management (CM): 9 requirements, 3.4.1–3.4.9

All 9 CM requirements
  • 3.4.1 Establish and maintain baseline configurations and inventories
  • 3.4.2 Establish and enforce security configuration settings
  • 3.4.3 Track, review, approve or disapprove, and log changes
  • 3.4.4 Analyze the security impact of changes before implementation
  • 3.4.5 Define, document, approve and enforce access restrictions associated with changes
  • 3.4.6 Employ least functionality: provide only essential capabilities
  • 3.4.7 Restrict, disable or prevent nonessential programs, functions, ports, protocols and services
  • 3.4.8 Apply deny-by-exception or deny-all, permit-by-exception policy for software
  • 3.4.9 Control and monitor user-installed software
  • EXAMINE: the baseline configurations, change tickets, the software allow-list, and the list of disabled services.
  • TEST: compare one endpoint against its baseline.
  • Common failure: the baseline exists as a document, but nothing enforces it.
  • Evidence guides: 3.4.1 baseline configuration, 3.4.2 configuration enforcement.

Identification & Authentication (IA): 11 requirements, 3.5.1–3.5.11

All 11 IA requirements
  • 3.5.1 Identify system users, processes acting on behalf of users, and devices
  • 3.5.2 Authenticate users, processes or devices before allowing access
  • 3.5.3 Use MFA for local and network access to privileged accounts and network access to non-privileged accounts
  • 3.5.4 Employ replay-resistant authentication for network access
  • 3.5.5 Prevent reuse of identifiers for a defined period
  • 3.5.6 Disable identifiers after a defined period of inactivity
  • 3.5.7 Enforce minimum password complexity and change of characters
  • 3.5.8 Prohibit password reuse for a specified number of generations
  • 3.5.9 Allow temporary passwords only with an immediate change to a permanent password
  • 3.5.10 Store and transmit only cryptographically-protected passwords
  • 3.5.11 Obscure feedback of authentication information

Incident Response (IR): 3 requirements, 3.6.1–3.6.3

All 3 IR requirements
  • 3.6.1 Establish an operational incident-handling capability
  • 3.6.2 Track, document and report incidents to internal and external officials and authorities
  • 3.6.3 Test the organizational incident response capability
  • EXAMINE: the IR plan, incident tickets, a tabletop after-action report, and the procedure for reporting to DoD via DIBNet within 72 hours under DFARS 252.204-7012.
  • INTERVIEW: the IR lead.
  • Common failure: the plan has never been tested, which fails 3.6.3.
  • Evidence guides: 3.6.1 incident handling, 3.6.2 incident reporting.

Maintenance (MA): 6 requirements, 3.7.1–3.7.6

All 6 MA requirements
  • 3.7.1 Perform maintenance on organizational systems
  • 3.7.2 Control the tools, techniques, mechanisms and personnel used for maintenance
  • 3.7.3 Sanitize equipment removed for off-site maintenance of any CUI
  • 3.7.4 Check diagnostic and test media for malicious code before use
  • 3.7.5 Require MFA for nonlocal maintenance sessions over external connections, and terminate them when done
  • 3.7.6 Supervise maintenance personnel without required access authorization
  • EXAMINE: maintenance logs, the MFA configuration for remote maintenance, and escort records for maintenance personnel.
  • Common failure: vendor remote sessions run with no MFA, and nobody terminates them afterwards.
  • Evidence guides: control library.

Media Protection (MP): 9 requirements, 3.8.1–3.8.9

All 9 MP requirements
  • 3.8.1 Protect (physically control and securely store) system media containing CUI, paper and digital
  • 3.8.2 Limit access to CUI on system media to authorized users
  • 3.8.3 Sanitize or destroy media containing CUI before disposal or reuse
  • 3.8.4 Mark media with CUI markings and distribution limitations
  • 3.8.5 Control access to and maintain accountability for CUI media during transport
  • 3.8.6 Use cryptography to protect CUI on digital media during transport
  • 3.8.7 Control the use of removable media on system components
  • 3.8.8 Prohibit portable storage devices with no identifiable owner
  • 3.8.9 Protect the confidentiality of backup CUI at storage locations
  • EXAMINE: CUI marking samples, sanitization certificates, the removable-media policy or GPO, and the encrypted backup configuration.
  • Common failure: there are no sanitization records for drives that have been disposed of.
  • Evidence guides: 3.8.3 media sanitization; for marking, see the CUI marking guide.

Personnel Security (PS): 2 requirements, 3.9.1–3.9.2

Both PS requirements
  • 3.9.1 Screen individuals before authorizing access to systems containing CUI
  • 3.9.2 Protect systems containing CUI during and after personnel actions such as terminations and transfers
  • EXAMINE: screening records and a termination checklist with timestamps showing when access was revoked.
  • Common failure: accounts are still active after the person has left.
  • Evidence guides: control library.

Physical Protection (PE): 6 requirements, 3.10.1–3.10.6

All 6 PE requirements
  • 3.10.1 Limit physical access to systems, equipment and operating environments to authorized individuals
  • 3.10.2 Protect and monitor the physical facility and support infrastructure
  • 3.10.3 Escort visitors and monitor visitor activity
  • 3.10.4 Maintain audit logs of physical access
  • 3.10.5 Control and manage physical access devices
  • 3.10.6 Enforce safeguarding measures for CUI at alternate work sites
  • EXAMINE: visitor logs, a badge system export, the escort procedure, and the alternate work site policy.
  • Common failure: treating physical controls as "easy points" to POA&M later. 3.10.3, 3.10.4 and 3.10.5 cannot go on a POA&M.
  • Evidence guides: control library.

Risk Assessment (RA): 3 requirements, 3.11.1–3.11.3

All 3 RA requirements
  • 3.11.1 Periodically assess risk to operations, assets and individuals
  • 3.11.2 Scan for vulnerabilities periodically and when new vulnerabilities are identified
  • 3.11.3 Remediate vulnerabilities in accordance with risk assessments
  • EXAMINE: the risk assessment, dated scan reports, and remediation tickets.
  • TEST: compare the scan scope against the asset inventory.
  • Common failure: scans miss assets that are in scope.
  • Evidence guides: 3.11.2 vulnerability scanning.

Security Assessment (CA): 4 requirements, 3.12.1–3.12.4

All 4 CA requirements
  • 3.12.1 Periodically assess security controls for effectiveness
  • 3.12.2 Develop and implement plans of action to correct deficiencies
  • 3.12.3 Monitor security controls on an ongoing basis
  • 3.12.4 Develop, document and periodically update system security plans

System & Communications Protection (SC): 16 requirements, 3.13.1–3.13.16

All 16 SC requirements
  • 3.13.1 Monitor, control and protect communications at external and key internal boundaries
  • 3.13.2 Employ architectural designs, development techniques and engineering principles that promote security
  • 3.13.3 Separate user functionality from system management functionality
  • 3.13.4 Prevent unauthorized and unintended information transfer via shared system resources
  • 3.13.5 Implement subnetworks for publicly accessible components, separated from internal networks
  • 3.13.6 Deny network traffic by default; allow by exception
  • 3.13.7 Prevent split tunneling for remote devices
  • 3.13.8 Use cryptography to prevent unauthorized disclosure of CUI in transmission
  • 3.13.9 Terminate network connections at session end or after defined inactivity
  • 3.13.10 Establish and manage cryptographic keys
  • 3.13.11 Employ FIPS-validated cryptography to protect the confidentiality of CUI
  • 3.13.12 Prohibit remote activation of collaborative computing devices; indicate use
  • 3.13.13 Control and monitor the use of mobile code
  • 3.13.14 Control and monitor the use of VoIP technologies
  • 3.13.15 Protect the authenticity of communications sessions
  • 3.13.16 Protect the confidentiality of CUI at rest

System & Information Integrity (SI): 7 requirements, 3.14.1–3.14.7

All 7 SI requirements
  • 3.14.1 Identify, report and correct system flaws in a timely manner
  • 3.14.2 Provide protection from malicious code at designated locations
  • 3.14.3 Monitor security alerts and advisories and take action
  • 3.14.4 Update malicious code protection when new releases are available
  • 3.14.5 Perform periodic scans and real-time scans of files from external sources
  • 3.14.6 Monitor systems, including inbound and outbound traffic, to detect attacks
  • 3.14.7 Identify unauthorized use of organizational systems
  • EXAMINE: patch reports, an AV/EDR console export, alert subscriptions, and the monitoring configuration.
  • TEST: confirm EDR is active on a sample endpoint.
  • Common failure: patch SLAs are missed and there are no exception records.
  • Evidence guides: 3.14.1 flaw remediation, 3.14.2 malicious code, 3.14.6 monitoring.

Checklist structure — how to run it by domain

For each of the 14 domains, make the same four passes:

  1. Read every requirement's objectives in NIST SP 800-171A. Those objectives, not the requirement summary, are what gets graded.
  2. Ask "who does this, on what asset, and how do I know?" The answer is your evidence. Get it with EXAMINE, INTERVIEW and TEST. An assessor uses all three, so your self-assessment should too.
  3. Mark each objective MET or NOT MET. If any objective is not met, the whole requirement is not met.
  4. Capture the evidence artifact (policy, config export, log sample, screenshot) with the date and the person who produced it. Keep the artifacts for six years from the CMMC Status Date.

For family-by-family evidence examples, see the Athena CMMC control evidence library. It has evidence guides for 24 requirements across 10 families, and each is linked from its family in the checklist above.

Score all 110 controls — free Quick Score

Score each requirement against its objectives and see which ones drive your deductions.

  • All 110 controls
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The affirmation step: what the Affirming Official signs

Who signs. The Affirming Official is the senior-level representative of each organization seeking assessment (OSA). That person is responsible for the OSA's compliance with CMMC Program requirements and has the authority to affirm continuing compliance. A prime and each of its subcontractors are separate OSAs, and each affirms its own status.

What they sign.

  • The Affirming Official's name, title and contact information.
  • A statement that the OSA "has implemented and will maintain implementation of all applicable CMMC security requirements" for every information system in the CMMC Assessment Scope.

When.

  • At the completion of the Level 2 self-assessment.
  • After any POA&M closeout self-assessment.
  • Annually after the Final CMMC Status Date.

Where. Electronically, in SPRS.

Before the Affirming Official signs, check:

  • The assessed scope matches the SSP boundary and the CAGE codes you enter in SPRS.
  • The score you report matches the objective-level assessment record, line by line.
  • Every POA&M item is eligible under 32 CFR 170.21(a)(2) and has a closeout date inside the 180-day window.
  • Every piece of evidence can be retrieved today, not just described.
  • Nothing "planned" or "in progress" has been scored as MET.

An affirmation is a representation to the Government. Treat it with the same care as any other certification you sign on a federal contract, and get your own counsel's advice on what it means for your organization.

Five failure patterns that sink a self-assessment

  1. Scoring the requirement instead of the objectives. "We have MFA" is not a score. One unmet objective makes the whole requirement NOT MET.
  2. Scope drift. The SSP boundary does not match the systems that actually touch CUI. The score is then for a system that doesn't exist.
  3. Putting the wrong requirements on the POA&M. These include the SSP (3.12.4), 3.1.20, 3.1.22 and 3.10.3–3.10.5, and any 3- or 5-point requirement other than the 3.13.11 non-FIPS case. Any one of them on the POA&M means it does not meet 170.21(a)(2).
  4. Counting the 180 days from the wrong date. The clock runs from the Conditional CMMC Status Date, not from the day you finished assessing.
  5. Policies with no operating evidence. A policy says what should happen. Logs, tickets and records show that it did. Without them the objective is not met.

More patterns from real findings: common CMMC audit failures.

Check your score before your Affirming Official signs

Score your 110 controls against the objectives, see where the deductions land, and fix them before anyone signs.

Prepared by the Athena Consulting Group CMMC practice. Athena is not a C3PAO and does not certify; this page explains the published rules so you can prepare.

Frequently asked questions

How many controls are in CMMC Level 2?

110: the security requirements of NIST SP 800-171 Rev. 2, organized into 14 families and evaluated against the assessment objectives in NIST SP 800-171A.

Can I self-assess for CMMC Level 2?

Yes, where your contract calls for Level 2 (Self). During the July 2026 suspension of the C3PAO phase-in, DoD requirements may designate only Level 1 (Self) or Level 2 (Self). Your clause still decides. Some contracts instead require a NIST SP 800-171 DoD Assessment posted to SPRS.

What's the passing SPRS score for CMMC Level 2?

Final Level 2 (Self) requires every requirement MET, the maximum score of 110 (32 CFR 170.16(a)(1); 170.24(c)(2)), either at the start or after POA&M closeout. Conditional Level 2 (Self) needs a POA&M that meets 32 CFR 170.21(a)(2): a score of at least 88 of 110, only eligible 1-point items, and none of the six excluded requirements. The POA&M must be closed out within 180 days of the Conditional CMMC Status Date. Below that bar there is no CMMC status, and no award where the contract requires one.

What's the difference between a requirement and an objective?

A requirement is the top-level control, for example 3.5.3, Use multifactor authentication. Objectives are the specific determinations made about that requirement, per NIST SP 800-171A. Scoring is per requirement, but grading is per objective: miss one objective and the requirement is NOT MET.

Who signs a CMMC Level 2 self-assessment?

The Affirming Official, a senior-level representative of the organization who is responsible for CMMC compliance and has authority to affirm it. They affirm in SPRS at completion of the self-assessment, after any POA&M closeout, and annually after a Final status.

How often is a Level 2 self-assessment required?

Every three years, with an affirmation annually in between.

Is a NIST 800-171 self-assessment the same as CMMC Level 2 (Self)?

They cover the same 110 requirements and the same objectives. The clause, the SPRS fields and the affirmation rules differ. Check which clause is in your contract before you submit.

Can DoD check a self-assessment?

Yes. DoD reserves the right to conduct a DCMA DIBCAC assessment of an organization that has self-assessed. If that assessment finds the requirements are not achieved or maintained, its results take precedence over any pre-existing CMMC status (32 CFR 170.16(a)(1)(iv)).

Further reading

Related Athena pages and authoritative external references.