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 · 3.13 System & Communications Protection

3.13.10 Cryptographic key management

Establish and manage cryptographic keys for cryptography employed in organizational systems.
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
2
From NIST SP 800-171A, each one a “determine if” an assessor answers.

What an assessor checks

NIST SP 800-171A breaks 3.13.10 into 2 objectives. Every one has to be met for the requirement to be met; a partial answer scores as not implemented.

  1. [a]Determine if cryptographic keys are established whenever cryptography is employed.
  2. [b]Determine if cryptographic keys are managed whenever cryptography is employed.
Examine
[SELECT FROM: System and communications protection policy; procedures addressing cryptographic key establishment and management; security plan; system design documentation; cryptographic mechanisms; system configuration settings and associated documentation; system audit logs and records; other relevant documents or records].
Interview
[SELECT FROM: System or network administrators; personnel with information security responsibilities; personnel with responsibilities for cryptographic key establishment and management].
Test
[SELECT FROM: Mechanisms supporting or implementing cryptographic key establishment and management].

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 3.13.10 maps

NIST SP 800-53 Rev 5

  • SC-12 Cryptographic Key Establishment and Management

NIST CSF 2.0

No direct mapping.

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 3.13.10
get_assessment_objectives 3.13.10
generate_poam_entries ["3.13.10"]

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