CMMC Level 2 · Access Control

CMMC Level 2 3.1.4: Separation Of Duties

3.1.4 — Separation Of Duties — is one of the 110 CMMC Level 2 requirements. This page gives the exact requirement text, every assessment objective, and what evidence an assessor will ask for.

Last reviewed: October 18, 2026

What this requirement asks

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

This is a CMMC Level 2 requirement in the Access Control family, drawn from NIST SP 800-171 Rev. 2. An assessor evaluates it objective by objective — every objective below must be supported by evidence, not just described in a policy.

Assessment objectives (3)

  • 3.1.4[a] — the duties of individuals requiring separation are defined
  • 3.1.4[b] — responsibilities for duties that require separation are assigned to separate individuals
  • 3.1.4[c] — access privileges that enable individuals to exercise the duties that require separation are granted to separate individuals

What an assessor examines

Examine:

  • Access control policy
  • procedures addressing divisions of responsibility and separation of duties
  • system security plan
  • system configuration settings and associated documentation
  • list of divisions of responsibility and separation of duties
  • system access authorizations
  • system audit logs and records
  • other relevant documents or records

Interview:

  • Personnel with responsibilities for defining divisions of responsibility and separation of duties
  • personnel with information security responsibilities
  • system or network administrators

Test:

  • Mechanisms implementing separation of duties policy

Evidence that defends it

Show distinct admin/audit roles; RBAC mappings prove separation

Check your readiness

Score this requirement against your own environment with the Level 2 self-assessment checklist, or estimate your SPRS score with the free CMMC compliance tool. Self-reported answers are planning signals only — they do not establish a verified or assessor-accepted result.

Frequently asked questions

Is 3.1.4 required for CMMC Level 2?

Yes. 3.1.4 (Separation Of Duties) is one of the 110 Level 2 requirements from NIST SP 800-171 Rev. 2. Every assessment objective must be met with supporting evidence.

What evidence satisfies 3.1.4?

Show distinct admin/audit roles; RBAC mappings prove separation

Further reading

Related Athena pages and authoritative external references.

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