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.