CMMC Level 1 establishes foundational cybersecurity practices for protecting Federal Contract Information (FCI). This guide covers all 17 practices required for Level 1 certification with practical implementation guidance. This is part 2 of our CMMC series.
Understanding Level 1
CMMC Level 1 is designed for contractors who handle Federal Contract Information (FCI) but not Controlled Unclassified Information (CUI). The practices derive from FAR 52.204-21 and represent basic cyber hygiene that every organization should implement.
15 vs 17 Practices: FAR 52.204-21 contains 15 security requirements. The official CMMC Level 1 Assessment Guide (Version 2.13) maps these to 17 distinct practices with 59 assessment objectives.
Assessment Type: Annual self-assessment submitted to the Supplier Performance Risk System (SPRS). No third-party assessor required.
The 17 practices span six security domains:
- Access Control (AC): 4 practices
- Identification and Authentication (IA): 2 practices
- Media Protection (MP): 1 practice
- Physical Protection (PE): 4 practices
- System and Communications Protection (SC): 2 practices
- System and Information Integrity (SI): 4 practices
Access Control (AC) - 4 Practices
AC.L1-b.1.i: Authorized Access Control
Requirement: Limit information system access to authorized users, processes acting on behalf of authorized users, or devices (including other information systems).
What this means: Only people and devices you've explicitly approved should access your systems. This is the foundation of all access control.
Implementation example:
- Maintain a list of authorized users with unique accounts
- Disable default accounts or rename them
- Remove access promptly when employees leave
- Use Active Directory or similar to manage user accounts centrally
- Implement device authentication (domain join, certificates, or MAC filtering)
AC.L1-b.1.ii: Transaction and Function Control
Requirement: Limit information system access to the types of transactions and functions that authorized users are permitted to execute.
What this means: Users should only have access to what they need for their job. Nothing more. This is the principle of least privilege.
Implementation example:
- Create role-based access groups (e.g., "Accounting," "Engineering," "HR")
- Limit administrative privileges to IT staff who need them
- Regular employees should not have local admin rights
- Document who has access to what and review quarterly
AC.L1-b.1.iii: External Connection Control
Requirement: Verify and control/limit connections to and use of external information systems.
What this means: Know what external systems your organization connects to and control those connections.
Implementation example:
- Maintain an inventory of approved cloud services and external systems
- Require approval before connecting to new external systems
- Use a VPN for remote access to internal systems
- Block unauthorized cloud storage services (personal Dropbox, etc.)
AC.L1-b.1.iv: Public Information Control
Requirement: Control information posted or processed on publicly accessible information systems.
What this means: Have a process to review what goes on your public website or other publicly accessible systems to prevent accidental disclosure.
Implementation example:
- Designate who can post to public websites
- Require review/approval before publishing content
- Periodically review public-facing content for sensitive information
- Train employees on what should never be posted publicly
Identification and Authentication (IA) - 2 Practices
IA.L1-b.1.v: Identification
Requirement: Identify information system users, processes acting on behalf of users, or devices.
What this means: Every user, process, and device must have a unique identifier. No shared accounts.
Implementation example:
- Assign unique usernames to each employee (e.g., jsmith, not "admin1")
- Name devices clearly (e.g., "ACCT-LAPTOP-001")
- Eliminate shared accounts so each person gets their own
- Service accounts should be named and documented
IA.L1-b.1.vi: Authentication
Requirement: Authenticate (or verify) the identities of those users, processes, or devices, as a prerequisite to allowing access to organizational information systems.
What this means: Verify that users are who they claim to be before granting access. This typically means passwords, but multi-factor authentication is better.
Implementation example:
- Require strong passwords (12+ characters, complexity requirements)
- Implement multi-factor authentication (MFA) where possible
- Set account lockout after failed login attempts
- Require password changes periodically (or use MFA instead)
Media Protection (MP) - 1 Practice
MP.L1-b.1.vii: Media Disposal
Requirement: Sanitize or destroy information system media containing Federal Contract Information before disposal or release for reuse.
What this means: Before throwing away or repurposing hard drives, USB drives, or other storage media, ensure all FCI is completely removed.
Implementation example:
- Use certified data destruction software (DBAN, Blancco) for hard drives
- Physically destroy drives that can't be sanitized (shredding, degaussing)
- Maintain destruction logs with date, method, and responsible person
- Use a certified e-waste vendor and get destruction certificates
- Don't forget about copiers and printers with internal storage
Physical Protection (PE) - 4 Practices
PE.L1-b.1.viii: Physical Access Limitation
Requirement: Limit physical access to organizational information systems, equipment, and the respective operating environments to authorized individuals.
What this means: Not everyone should be able to walk into your server room or access areas where FCI is processed.
Implementation example:
- Lock server rooms and network closets
- Use badge access or keys for sensitive areas
- Keep workstations in areas not accessible to the public
- Secure laptops with cable locks when unattended
PE.L1-b.1.ix: Visitor Escort and Monitoring
Requirement: Escort visitors and monitor visitor activity.
What this means: Visitors shouldn't wander your facility unescorted, especially near systems containing FCI.
Implementation example:
- Require visitors to sign in and receive a visitor badge
- Escort visitors at all times in sensitive areas
- Brief employees on visitor escort procedures
- Collect visitor badges upon departure
PE.L1-b.1.x: Physical Access Logs
Requirement: Maintain audit logs of physical access.
What this means: Keep records of who accessed secure areas and when.
Implementation example:
- Use electronic badge readers that log access automatically
- Maintain a paper sign-in log if electronic isn't feasible
- Keep visitor logs with name, company, time in/out, and escort
- Retain logs for at least one year
PE.L1-b.1.xi: Physical Access Device Management
Requirement: Control and manage physical access devices.
What this means: Track keys, badges, and other access devices. Know who has them and recover them when people leave.
Implementation example:
- Maintain an inventory of all keys and badges issued
- Collect access devices during employee offboarding
- Deactivate badges immediately when employees depart
- Rekey locks if keys are lost or not returned
System and Communications Protection (SC) - 2 Practices
SC.L1-b.1.xii: Boundary Protection
Requirement: Monitor, control, and protect organizational communications at the external boundaries and key internal boundaries of the information systems.
What this means: Use firewalls and other boundary defenses to protect your network from external threats.
Implementation example:
- Deploy a firewall at your network perimeter
- Configure firewall rules to block unnecessary inbound traffic
- Use a next-generation firewall or UTM device for small businesses
- Segment your network if you have guest WiFi
SC.L1-b.1.xiii: Public-Access System Separation
Requirement: Implement subnetworks for publicly accessible system components that are physically or logically separated from internal networks.
What this means: If you have public-facing systems (like a web server), keep them separated from your internal network.
Implementation example:
- Place public web servers in a DMZ (demilitarized zone)
- Keep guest WiFi on a separate VLAN from corporate network
- Don't expose internal systems directly to the internet
- Use a cloud provider for public-facing services to isolate them
System and Information Integrity (SI) - 4 Practices
SI.L1-b.1.xiv: Flaw Remediation
Requirement: Identify, report, and correct information and information system flaws in a timely manner.
What this means: Keep your systems patched and updated. When security vulnerabilities are announced, fix them promptly.
Implementation example:
- Enable automatic updates for operating systems
- Patch third-party software regularly (browsers, Adobe, Java)
- Subscribe to vendor security bulletins
- Test patches in a non-production environment when possible
- Critical patches should be applied within 30 days
SI.L1-b.1.xv: Malicious Code Protection
Requirement: Provide protection from malicious code at appropriate locations within organizational information systems.
What this means: Deploy antivirus/anti-malware software at key locations in your environment.
Implementation example:
- Install endpoint protection on all workstations and servers
- Enable real-time scanning of files
- Consider modern EDR (Endpoint Detection and Response) solutions
- Enable email filtering to block malicious attachments
SI.L1-b.1.xvi: Update Malicious Code Protection
Requirement: Update malicious code protection mechanisms when new releases are available.
What this means: Keep your antivirus signatures and protection software up to date.
Implementation example:
- Configure automatic signature updates (daily at minimum)
- Enable automatic software updates for your endpoint protection
- Monitor update status across all endpoints
- Alert on systems that fall behind on updates
SI.L1-b.1.xvii: System and File Scanning
Requirement: Perform periodic scans of the information system and real-time scans of files from external sources as files are downloaded, opened, or executed.
What this means: Run scheduled full-system scans and scan files in real-time as they enter your environment.
Implementation example:
- Run full system scans weekly
- Enable on-access scanning for all file operations
- Scan email attachments before delivery
- Scan downloaded files before execution
- Scan removable media when connected
Self-Assessment Process
Level 1 requires annual self-assessment. Here's how to approach it:
- Review each practice against your current implementation
- Document evidence of implementation (screenshots, policies, logs)
- Calculate your score using the DoD Assessment Methodology
- Submit to SPRS (Supplier Performance Risk System)
- Affirm annually that you remain in compliance
Important: False claims of compliance can result in False Claims Act liability. Ensure your self-assessment is accurate and honest.
Key Takeaways
- Level 1 has 17 practices (derived from FAR 52.204-21's 15 requirements) focused on basic cyber hygiene
- These practices protect Federal Contract Information (FCI)
- Annual self-assessment is required with no third party needed
- Most practices are foundational IT security that you should already have
- Document everything because you need evidence of implementation
Next in the Series
Ready for more advanced requirements? The next article covers CMMC Level 2: Access Control & Identity, diving into the enhanced requirements for protecting Controlled Unclassified Information (CUI).
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