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Requirements / Identification and Authentication (IA)

IA.L2-3.5.2

Authentication

Official Source Material

Authenticate (or verify) the identities of those users, processes, or devices, as a prerequisite to allowing access to organizational information systems.

Determine if:

  1. [a] the identity of each user is authenticated or verified as a prerequisite to system access;
  2. [b] the identity of each process acting on behalf of a user is authenticated or verified as a prerequisite to system access; and
  3. [c] the identity of each device accessing or connecting to the system is authenticated or verified as a prerequisite to system access.

Source: CMMC Assessment Guide - Level 2, Version 2.13, September 2024

Practitioner Guidance

How to meet it

Nothing gets access before proving what it is.

Users [a], processes acting on behalf of users [b], and devices [c] each authenticate before the system lets them in. For users and service accounts a modern directory does this by default. Your work is confirming that no path around it exists.

Hunt down default credentials before an assessor does.

Network gear, printers, cameras, and appliances ship with published usernames and passwords, and those credentials are easily found in a search. Change them at deployment, and put that step in the provisioning procedure so the practice is documented rather than remembered.

Devices authenticate through domain join or enrollment. Verification covers the fixed fleet.

The requirement says authenticated or verified. Devices joined to the domain or enrolled in Intune attest their identity when they connect, which satisfies [c]. A small office can verify instead, but the verification has to happen before access. Pair a maintained inventory of known devices with a gate that admits only inventoried devices, at fixed locations in a controlled area. Remote devices get real authentication, because no one can walk over and verify them.

Service accounts authenticate too, and the record of them is what you show.

A script or integration signs in with a credential, a certificate, or a token. Keep the IA.L2-3.5.1 service account list annotated with how each one authenticates. That record answers [b] and pays for itself again during log review and incident response.

Cloud-only does not remove the endpoints.

CUI (Controlled Unclassified Information) comes down from the cloud onto laptops for editing, printing, and building new documents. Those endpoints and their users authenticate like everything else. Moving the data to the cloud moves none of this requirement away.

What falls short

  • Anything still reachable with a default password. The identity presented is the manufacturer's, not the device's, so [c] fails on that path.

Edge cases

  • A machine or instrument that cannot authenticate to anything is handled by documenting it and restricting what it can reach. Cover it in the system security plan rather than pretending it authenticates.

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