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 · 3.5 Identification & Authentication

3.5.1 Identify users, processes and devices

Identify system users, processes acting on behalf of users, and devices.
SPRS weight
5
5 points deducted from 110 when not implemented.
CMMC level
L1 + L2
Level 1 practice IA.L1-3.5.1, from FAR 52.204-21(b)(1)(v)
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 3.5.1 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 system users are identified.
  2. [b]Determine if processes acting on behalf of users are identified.
  3. [c]Determine if devices accessing the system are identified.
Examine
[SELECT FROM: Identification and authentication policy; procedures addressing user identification and authentication; security plan, system design documentation; system configuration settings and associated documentation; system audit logs and records; list of system accounts; other relevant documents or records].
Interview
[SELECT FROM: Personnel with system operations responsibilities; personnel with information security responsibilities; system or network administrators; personnel with account management responsibilities; system developers].
Test
[SELECT FROM: Organizational processes for uniquely identifying and authenticating users; mechanisms supporting or implementing identification and authentication capability].

If it is open: POA&M eligibility

Not POA&M-eligible: above the 1-point ceiling · 5 points deducted

Worth 5 points. No requirement over 1 point may appear on a Level 2 POA&M, so this has to be closed before the assessment.

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 3.5.1 maps

NIST SP 800-53 Rev 5

  • AC-2 Account Management
  • IA-1 Identification and Authentication Policy
  • IA-2 Identification and Authentication
  • IA-4 Identifier Management
  • IA-8 Identification and Authentication - Non-Organizational Users
  • IA-12 Identity Proofing

NIST CSF 2.0

  • Identities are managed Identity Management, Authentication and Access Control

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 3.5.1
get_assessment_objectives 3.5.1
generate_poam_entries ["3.5.1"]

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From MacZine

Working notes on Identification & Authentication

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