CMMC Level 1 · GuideSEC / GDE

Guide

Does CMMC Level 1 require multi-factor authentication?

Short Answer

No. Multi-factor authentication is not one of the fifteen CMMC Level 1 requirements. It is a Level 2 requirement under NIST SP 800-171. Level 1 asks you to identify users and verify their identity before access, which unique accounts and passwords can satisfy.

What Level 1 does ask for on identity

Two of the fifteen requirements cover identity. Identification, IA.L1-b.1.v, is about telling users, processes, and devices apart. Authentication, IA.L1-b.1.vi, is about verifying that identity before granting access. Neither one names MFA.

Other things people think Level 1 requires but it does not

None of these is a Level 1 requirement either. A System Security Plan is required at Level 2. A third-party assessment applies only when a contract calls for Level 2 (C3PAO). The FedRAMP Moderate condition applies to cloud services that process, store, or transmit CUI, and no CMMC level names GCC High or any other product. MFA is a strong control, and many small suppliers use it anyway. It is simply not one of the fifteen you are assessed against at Level 1.

Primary Sources

Source Authority

Primary Authority
FAR 52.204-21(b)(1)
Framework Version
CMMC Assessment Guide, Level 1 v2.13 (September 2024)
Written By
AssessrLog, from the primary sources listed above

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