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

3.5.7 Password complexity

Enforce a minimum password complexity and change of characters when new passwords are created.
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
4
From NIST SP 800-171A, each one a “determine if” an assessor answers.

What an assessor checks

NIST SP 800-171A breaks 3.5.7 into 4 objectives. Every one has to be met for the requirement to be met; a partial answer scores as not implemented.

  1. [a]Determine if password complexity requirements are defined.
  2. [b]Determine if password change of character requirements are defined.
  3. [c]Determine if minimum password complexity requirements as defined are enforced when new passwords are created.
  4. [d]Determine if minimum password change of character requirements as defined are enforced when new passwords are created.
Examine
[SELECT FROM: Identification and authentication policy; password policy; procedures addressing authenticator management; security plan; system design documentation; system configuration settings and associated documentation; password configurations and associated documentation; other relevant documents or records].
Interview
[SELECT FROM: Personnel with authenticator management responsibilities; personnel with information security responsibilities; system or network administrators; system developers].
Test
[SELECT FROM: Mechanisms supporting or implementing password-based authenticator management capability].

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 3.5.7 maps

NIST SP 800-53 Rev 5

  • IA-5 Authenticator Management

NIST CSF 2.0

  • Authentication 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 3.5.7
get_assessment_objectives 3.5.7
generate_poam_entries ["3.5.7"]

Install the MCP server, free, no account.

From MacZine

Working notes on Identification & Authentication

The full run →