13 Jul 2026CMMC Phase II suspended: no C3PAO assessments can be designated. DFARS 7012 and Rev 2 still apply.What changed, and what did not

NIST SP 800-171 Rev 2 · 3.1 Access Control

3.1.4 Separation of duties

Separate the duties of individuals to reduce the risk of malevolent activity without collusion.
SPRS weight
1
1 point deducted from 110 when not implemented.
CMMC level
L2
Level 2 only; not among the 17 Level 1 practices.
Assessment objectives
3
From NIST SP 800-171A, each one a “determine if” an assessor answers.

What an assessor checks

NIST SP 800-171A breaks 3.1.4 into 3 objectives. Every one has to be met for the requirement to be met; a partial answer scores as not implemented.

  1. [a]Determine if the duties of individuals requiring separation to reduce the risk of malevolent activity are defined.
  2. [b]Determine if organization-defined duties of individuals requiring separation are separated.
  3. [c]Determine if separate accounts for individuals whose duties and accesses must be separated to reduce the risk of malevolent activity or collusion are established
Examine
[SELECT FROM: Access control policy; procedures addressing divisions of responsibility and separation of duties; 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
[SELECT FROM: Personnel with responsibilities for defining divisions of responsibility and separation of duties; personnel with information security responsibilities; system or network administrators].
Test
[SELECT FROM: Mechanisms implementing separation of duties policy].

If it is open: POA&M eligibility

May be carried on a Level 2 POA&M · 1 point deducted

A 1-point requirement outside the six named exclusions - eligible to carry, and NOT MET until a closeout assessment confirms it.

A POA&M is only permitted at a score of 88 or above, and closes in one 180-day window. Check a full gap list or compute your score.

Where 3.1.4 maps

NIST SP 800-53 Rev 5

  • AC-5 Separation of Duties

NIST CSF 2.0

  • Access is managed

SOC 2

No direct mapping.

Query it from your own tools

This page and the MacTech CMMC MCP server render the same dataset. Ask your assistant and it will answer from the methodology, not from memory.

lookup_control 3.1.4
get_assessment_objectives 3.1.4
generate_poam_entries ["3.1.4"]

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From MacZine

Working notes on Access Control

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