CMMC Level 2 · Identification & Authentication

CMMC Level 2 3.5.7: Password Complexity

3.5.7 — Password Complexity — 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

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

This is a CMMC Level 2 requirement in the Identification & Authentication 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 (4)

  • 3.5.7[a] — password complexity requirements are defined
  • 3.5.7[b] — password change of character requirements are defined
  • 3.5.7[c] — minimum password complexity requirements as defined are enforced when new passwords are created
  • 3.5.7[d] — minimum password change of character requirements as defined are enforced when new passwords are created

What an assessor examines

Examine:

  • Identification and authentication policy
  • password policy
  • procedures addressing authenticator management
  • system security plan
  • system configuration settings and associated documentation
  • system design documentation
  • password configurations and associated documentation
  • other relevant documents or records

Interview:

  • Personnel with authenticator management responsibilities
  • personnel with information security responsibilities
  • system or network administrators

Test:

  • Mechanisms supporting or implementing authenticator management capability

Evidence that defends it

Document triggers and response

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 3.5.7 required for CMMC Level 2?

Yes. 3.5.7 (Password Complexity) 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 3.5.7?

Document triggers and response

Further reading

Related Athena pages and authoritative external references.

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