CMMC 2.0 Level 2 Readiness Checklist
How to Use This Checklist
This checklist covers all 14 NIST SP 800-171 Rev 2 control families required for CMMC Level 2 certification. For each domain, you’ll find the key requirements, common mid-market gaps, and the evidence your C3PAO assessor will expect.
Self-Scoring Guide
Score each control family using the status framework below.
| Score | Status | Definition |
|---|---|---|
| ✅ 3 | Implemented | Control fully in place with documentation and evidence available |
| ⚠️ 1 | Partial | Some implementation exists but gaps remain — remediation needed |
| ❌ 0 | Not Implemented | Control is missing or not documented — priority remediation |
Scoring Target & Priority
Target: A perfect score across all 14 families is 42. Organizations scoring below 28 should prioritize remediation before scheduling a C3PAO assessment.
Focus first on: Access Control (AC), System & Communications Protection (SC), and Audit & Accountability (AU) — these three domains account for nearly half of all requirements.
CMMC 2.0 Phase Timeline
| Phase | Date | Requirement |
|---|---|---|
| Phase 1 | Nov 10, 2025 | Level 1 & Level 2 self-assessments in select contracts (active now) |
| Phase 2 | Nov 10, 2026 | Third-party C3PAO certification assessments required for Level 2 |
| Phase 3 | Nov 10, 2027 | Level 3 DIBCAC assessments for highly sensitive programs |
| Phase 4 | Nov 10, 2028 | Full CMMC implementation for all covered contracts |
The 14 Control Families
Each card below covers the key requirements, common mid-market gaps, and evidence your C3PAO assessor will expect. Use the scoring row at the bottom of each card to track your status, owner, and target remediation date.
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AC — Access Control
22 requirementsKey Requirements- Enforce least privilege and separation of duties
- Control remote access sessions via managed access points
- Limit unsuccessful logon attempts
- Terminate sessions after defined conditions
- Authorize wireless access before connection
- Control CUI flow per approved authorizations
- Use non-privileged accounts for non-security functions
Common Mid-Market GapsShared accounts, no session timeouts, uncontrolled remote access, missing role-based access controls
Evidence Your Assessor Will ExpectAccess control policies, RBAC matrix, session config screenshots, VPN/remote access logs, wireless access authorization records
Status: ✅ Implemented (3) ⚠️ Partial (1) ❌ Not Implemented (0)Notes / RemediationOwner Target Date -
AT — Awareness & Training
3 requirementsKey Requirements- Security awareness training for all users
- Role-based training for privileged users
- Insider threat awareness program
Common Mid-Market GapsNo documented training program, missing completion records, no insider threat component
Evidence Your Assessor Will ExpectTraining curriculum, completion records with dates, insider threat briefing materials
Status: ✅ Implemented (3) ⚠️ Partial (1) ❌ Not Implemented (0)Notes / RemediationOwner Target Date -
AU — Audit & Accountability
9 requirementsKey Requirements- Create and retain system audit logs
- Review and update logged events
- Alert on audit logging process failure
- Correlate audit records across systems
- Protect audit information from unauthorized access
- Reduce audit records to support analysis
Common Mid-Market GapsLogging not enabled on all CUI systems, missing required data elements (user ID, timestamp, action, success/failure), no log review cadence
Evidence Your Assessor Will ExpectSample audit logs from all CUI boundary systems, log review procedures and evidence, log retention configuration, SIEM dashboard screenshots
Status: ✅ Implemented (3) ⚠️ Partial (1) ❌ Not Implemented (0)Notes / RemediationOwner Target Date -
CM — Configuration Management
9 requirementsKey Requirements- Establish and maintain baseline configurations
- Track and control changes to systems
- Analyze security impact of changes before implementation
- Enforce least functionality (disable unnecessary services)
- Restrict and monitor user-installed software
Common Mid-Market GapsNo documented baselines, no formal change control process, unnecessary services running on CUI systems
Evidence Your Assessor Will ExpectBaseline configuration documents, change control board records, configuration scan results, software whitelist policy
Status: ✅ Implemented (3) ⚠️ Partial (1) ❌ Not Implemented (0)Notes / RemediationOwner Target Date -
IA — Identification & Authentication
11 requirementsKey Requirements- Enforce multi-factor authentication for all network access
- Use replay-resistant authentication for privileged accounts
- Enforce minimum password complexity and change requirements
- Identify and authenticate devices before connection
- Disable identifiers after defined inactivity period
Common Mid-Market GapsMFA not enforced for all access types, weak password policies, no device authentication, inactive accounts not disabled
Evidence Your Assessor Will ExpectMFA configuration screenshots, password policy settings, device authentication logs, account review records
Status: ✅ Implemented (3) ⚠️ Partial (1) ❌ Not Implemented (0)Notes / RemediationOwner Target Date -
IR — Incident Response
3 requirementsKey Requirements- Establish incident handling capability
- Track, document, and report incidents
- Test incident response capability
Common Mid-Market GapsPlan exists but never tested, no documented tabletop exercises, unclear escalation procedures
Evidence Your Assessor Will ExpectIncident response plan, tabletop exercise records with findings, incident log/tracker, after-action reports
Status: ✅ Implemented (3) ⚠️ Partial (1) ❌ Not Implemented (0)Notes / RemediationOwner Target Date -
MA — Maintenance
6 requirementsKey Requirements- Perform maintenance on organizational systems
- Control maintenance tools and media
- Ensure remote maintenance sessions are monitored
- Supervise maintenance personnel without access authorization
Common Mid-Market GapsNo maintenance logging, uncontrolled remote maintenance sessions, maintenance tools not inventoried
Evidence Your Assessor Will ExpectMaintenance logs, remote session monitoring records, tools inventory, maintenance personnel authorization records
Status: ✅ Implemented (3) ⚠️ Partial (1) ❌ Not Implemented (0)Notes / RemediationOwner Target Date -
MP — Media Protection
9 requirementsKey Requirements- Protect and control CUI media during transport
- Mark CUI media with required distribution limitations
- Sanitize media before disposal or reuse
- Control access to media containing CUI
- Encrypt CUI on digital media during transport
Common Mid-Market GapsNo media labeling policy, incomplete sanitization procedures, unencrypted portable media
Evidence Your Assessor Will ExpectMedia handling policy, sanitization records, encryption verification, media inventory log
Status: ✅ Implemented (3) ⚠️ Partial (1) ❌ Not Implemented (0)Notes / RemediationOwner Target Date -
PS — Personnel Security
2 requirementsKey Requirements- Screen individuals prior to authorizing access to CUI systems
- Protect CUI during personnel actions (termination, transfer)
Common Mid-Market GapsNo screening documented, access not revoked upon termination/transfer
Evidence Your Assessor Will ExpectScreening policy, background check records, access revocation procedures and evidence, termination checklists
Status: ✅ Implemented (3) ⚠️ Partial (1) ❌ Not Implemented (0)Notes / RemediationOwner Target Date -
PE — Physical Protection
6 requirementsKey Requirements- Limit physical access to authorized individuals
- Escort visitors and monitor visitor activity
- Maintain audit logs of physical access
- Control and manage physical access devices
Common Mid-Market GapsNo visitor logs, uncontrolled access to server rooms, missing physical access logs
Evidence Your Assessor Will ExpectPhysical access policy, visitor sign-in logs, badge access records, physical access device inventory
Status: ✅ Implemented (3) ⚠️ Partial (1) ❌ Not Implemented (0)Notes / RemediationOwner Target Date -
RA — Risk Assessment
3 requirementsKey Requirements- Conduct periodic risk assessments
- Scan for vulnerabilities periodically and when new threats emerge
- Remediate vulnerabilities in accordance with risk assessments
Common Mid-Market GapsNo formal risk assessment on file, vulnerability scans not covering full CUI boundary, no remediation tracking
Evidence Your Assessor Will ExpectRisk assessment report, vulnerability scan results, remediation tracker with timelines, risk register
Status: ✅ Implemented (3) ⚠️ Partial (1) ❌ Not Implemented (0)Notes / RemediationOwner Target Date -
CA — Security Assessment
4 requirementsKey Requirements- Assess security controls periodically
- Develop and implement plans of action to address deficiencies
- Monitor security controls on an ongoing basis
- Develop and update system security plans
Common Mid-Market GapsSSP incomplete or outdated, no security control testing schedule, POA&M not maintained
Evidence Your Assessor Will ExpectCurrent SSP, assessment results, POA&M tracker, continuous monitoring plan
Status: ✅ Implemented (3) ⚠️ Partial (1) ❌ Not Implemented (0)Notes / RemediationOwner Target Date -
SC — System & Communications Protection
16 requirementsKey Requirements- Monitor and control communications at system boundaries
- Employ architectural designs with security as a principle
- Separate user and system management functionality
- Encrypt CUI in transit
- Encrypt CUI at rest
- Protect session authenticity
- Implement subnetwork isolation for publicly accessible components
Common Mid-Market GapsCUI not encrypted at rest, boundary protection gaps, no network segmentation, missing session encryption
Evidence Your Assessor Will ExpectNetwork architecture diagrams, encryption configuration evidence, firewall/IDS/IPS rules, TLS/SSL certificates
Status: ✅ Implemented (3) ⚠️ Partial (1) ❌ Not Implemented (0)Notes / RemediationOwner Target Date -
SI — System & Information Integrity
7 requirementsKey Requirements- Identify, report, and correct system flaws in a timely manner
- Provide protection from malicious code
- Update malicious code mechanisms regularly
- Monitor systems for unauthorized connections and access
- Identify unauthorized use of organizational systems
Common Mid-Market GapsPatch management gaps, AV/EDR not on all CUI endpoints, no unauthorized connection monitoring
Evidence Your Assessor Will ExpectPatch management records, AV/EDR deployment evidence, system monitoring dashboards, alerting configuration
Status: ✅ Implemented (3) ⚠️ Partial (1) ❌ Not Implemented (0)Notes / RemediationOwner Target Date
Need Help Getting CMMC Ready?
Idril Cybersecurity Services helps mid-market defense contractors achieve CMMC Level 2 certification through a structured, efficient compliance program.
Our CMMC Readiness Assessment includes:
- CUI boundary scoping across your full environment
- Gap assessment against all 110 NIST 800-171 controls
- Prioritized remediation roadmap with timelines and owners
- SSP development or review
- Evidence preparation guidance for C3PAO assessment
- Ongoing advisory through certification
8(a) Certified • WOSB • CMMI Level 3 • idrilservices.io • info@idrilservices.io