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NIST 800-171 Compliance Checklist: 110 Requirements and SPRS

A NIST 800-171 compliance checklist with all 110 Rev. 2 requirements, their SPRS points, Rev. 3 changes, CMMC status and a self-assessment guide. Free Excel.

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Written by
Trio Content Team
Published on
19 Oct 2026
Modified on
19 Oct 2026

If your company handles Controlled Unclassified Information (CUI) under a DoD contract, NIST SP 800-171 is the standard you're measured against. DoD contracts still use Revision 2: 110 security requirements. All but one are worth 5, 3 or 1 point in the score you post to the Supplier Performance Risk System (SPRS).

This NIST 800-171 compliance checklist lists all 110 requirements by family, with the points each one is worth. It explains Rev. 2 vs Rev. 3, how to run the self-assessment, how the SPRS score works, and where CMMC stands in October 2026. It also points out the requirements that live on laptops and phones.

To work through it, download our free NIST checklist workbook. Its SP 800-171 tab lists all 110 requirements and calculates your SPRS score once every requirement is marked Met, Partial or Not met. A PDF guide comes with it.

TL;DR

In short

  • DFARS 252.204-7012 requires SP 800-171 on contractor systems that handle CUI. DoD uses Revision 2: 110 requirements in 14 families.
  • Rev. 3 (May 2024, 97 requirements) is NIST's current version, but DoD and CMMC have not adopted it.
  • Your self-assessment score starts at 110 and loses 5, 3 or 1 point for each requirement not met. It can go as low as -203.
  • Write the system security plan (SSP) first: without one, you can't report a score.
  • CMMC Phase 1 (self-assessments) started November 10, 2025. DoD suspended Phase 2 (third-party assessments) in July 2026.

What NIST 800-171 is and who needs it

SP 800-171, "Protecting Controlled Unclassified Information in Nonfederal Systems and Organizations", sets the security requirements for company systems that store, process or transmit CUI. CUI is information the government creates or possesses, or that a contractor creates for it, that needs protection but isn't classified: technical drawings, specifications, export-controlled data and similar.

  • DoD contractors and subcontractors. DFARS 252.204-7012 requires 800-171 on covered contractor systems and cyber incident reports to DoD within 72 hours. It flows down to subcontractors that handle CUI.
  • Assessment and SPRS. DFARS 252.204-7019 requires a current assessment, no more than three years old, with the summary score posted in SPRS. Under DFARS class deviation 2026-O0025 (latest revision September 2026), the same rules sit in clause 252.240-7997.
  • Other agencies. A FAR rule that would apply 800-171 to CUI across all federal contracts was proposed in January 2025 and has not been finalized.

There is no NIST 800-171 certification. NIST does not certify organizations. You prove compliance with an assessment: your own (Basic), or one by DoD (Medium or High), and under CMMC, a CMMC assessment. For the bigger picture, see our guide to NIST compliance.

NIST 800-171 Rev. 2 vs Rev. 3: which one to use

Comparison of SP 800-171 Rev. 2 (110 requirements, used by DoD and CMMC today) and Rev. 3 (97 requirements, May 2024)
Comparison of SP 800-171 Rev. 2 (110 requirements, used by DoD and CMMC today) and Rev. 3 (97 requirements, May 2024)

NIST published Revision 3 in May 2024 and withdrew Revision 2 at the same time. Rev. 3 has 97 requirements in 17 families. It adds Planning, System and Services Acquisition, and Supply Chain Risk Management, folds some requirements together, and introduces organization-defined parameters: values such as time periods that the organization sets.

DoD hasn't moved. CMMC Level 2 (32 CFR Part 170) incorporates "NIST SP 800-171 R2" by reference, and the DFARS deviation signed in September 2026 names Revision 2 in 252.204-7012. For DoD contracts, assess against Rev. 2's 110 requirements. Use Rev. 3 as a preview of where the requirements are heading, not as the standard you report.

The NIST 800-171 checklist: all 110 requirements

The 110 requirements of Revision 2 sit in 14 families. Points are the value subtracted from 110 if the requirement isn't met, from the DoD scoring method in 32 CFR 170.24.

The 110 SP 800-171 Rev. 2 requirements by family, each shaded by its SPRS weight of 5, 3 or 1 points
The 110 SP 800-171 Rev. 2 requirements by family, each shaded by its SPRS weight of 5, 3 or 1 points
IDFamilyRequirementsPoints at stake
3.1Access Control2254
3.2Awareness and Training311
3.3Audit and Accountability919
3.4Configuration Management933
3.5Identification and Authentication1127
3.6Incident Response311
3.7Maintenance618
3.8Media Protection923
3.9Personnel Security28
3.10Physical Protection614
3.11Risk Assessment39
3.12Security Assessment413
3.13System and Communications Protection1642
3.14System and Information Integrity731
Total110313

Requirement text is quoted from NIST SP 800-171 Rev. 2. Requirements marked (device) have a device side; more on those below.

3.1 Access Control (22)

IDRequirementSPRS points
☐3.1.1Limit system access to authorized users, processes acting on behalf of authorized users, and devices (including other systems).5
☐3.1.2Limit system access to the types of transactions and functions that authorized users are permitted to execute.5
☐3.1.3Control the flow of CUI in accordance with approved authorizations.1
☐3.1.4Separate the duties of individuals to reduce the risk of malevolent activity without collusion.1
☐3.1.5Employ the principle of least privilege, including for specific security functions and privileged accounts.3
☐3.1.6Use non-privileged accounts or roles when accessing nonsecurity functions.1
☐3.1.7Prevent non-privileged users from executing privileged functions and capture the execution of such functions in audit logs.1
☐3.1.8Limit unsuccessful logon attempts.1
☐3.1.9Provide privacy and security notices consistent with applicable CUI rules.1
☐3.1.10Use session lock with pattern-hiding displays to prevent access and viewing of data after a period of inactivity. (device)1
☐3.1.11Terminate (automatically) a user session after a defined condition.1
☐3.1.12Monitor and control remote access sessions.5
☐3.1.13Employ cryptographic mechanisms to protect the confidentiality of remote access sessions.5
☐3.1.14Route remote access via managed access control points.1
☐3.1.15Authorize remote execution of privileged commands and remote access to security-relevant information.1
☐3.1.16Authorize wireless access prior to allowing such connections.5
☐3.1.17Protect wireless access using authentication and encryption.5
☐3.1.18Control connection of mobile devices. (device)5
☐3.1.19Encrypt CUI on mobile devices and mobile computing platforms. (device)3
☐3.1.20Verify and control/limit connections to and use of external systems.1
☐3.1.21Limit use of portable storage devices on external systems.1
☐3.1.22Control CUI posted or processed on publicly accessible systems.1

3.2 Awareness and Training (3)

IDRequirementSPRS points
☐3.2.1Ensure that managers, systems administrators, and users of organizational systems are made aware of the security risks associated with their activities and of the applicable policies, standards, and procedures related to the security of those systems.5
☐3.2.2Ensure that personnel are trained to carry out their assigned information security-related duties and responsibilities.5
☐3.2.3Provide security awareness training on recognizing and reporting potential indicators of insider threat.1

3.3 Audit and Accountability (9)

IDRequirementSPRS points
☐3.3.1Create and retain system audit logs and records to the extent needed to enable the monitoring, analysis, investigation, and reporting of unlawful or unauthorized system activity. (device)5
☐3.3.2Ensure that the actions of individual system users can be uniquely traced to those users, so they can be held accountable for their actions.3
☐3.3.3Review and update logged events.1
☐3.3.4Alert in the event of an audit logging process failure.1
☐3.3.5Correlate audit record review, analysis, and reporting processes for investigation and response to indications of unlawful, unauthorized, suspicious, or unusual activity.5
☐3.3.6Provide audit record reduction and report generation to support on-demand analysis and reporting.1
☐3.3.7Provide a system capability that compares and synchronizes internal system clocks with an authoritative source to generate time stamps for audit records.1
☐3.3.8Protect audit information and audit logging tools from unauthorized access, modification, and deletion.1
☐3.3.9Limit management of audit logging functionality to a subset of privileged users.1

3.4 Configuration Management (9)

IDRequirementSPRS points
☐3.4.1Establish and maintain baseline configurations and inventories of organizational systems (including hardware, software, firmware, and documentation) throughout the respective system development life cycles. (device)5
☐3.4.2Establish and enforce security configuration settings for information technology products employed in organizational systems. (device)5
☐3.4.3Track, review, approve or disapprove, and log changes to organizational systems.1
☐3.4.4Analyze the security impact of changes prior to implementation.1
☐3.4.5Define, document, approve, and enforce physical and logical access restrictions associated with changes to organizational systems.5
☐3.4.6Employ the principle of least functionality by configuring organizational systems to provide only essential capabilities. (device)5
☐3.4.7Restrict, disable, or prevent the use of nonessential programs, functions, ports, protocols, and services. (device)5
☐3.4.8Apply deny-by-exception (blacklisting) policy to prevent the use of unauthorized software or deny-all, permit-by-exception (whitelisting) policy to allow the execution of authorized software. (device)5
☐3.4.9Control and monitor user-installed software. (device)1

3.5 Identification and Authentication (11)

IDRequirementSPRS points
☐3.5.1Identify system users, processes acting on behalf of users, and devices.5
☐3.5.2Authenticate (or verify) the identities of users, processes, or devices, as a prerequisite to allowing access to organizational systems.5
☐3.5.3Use multifactor authentication for local and network access to privileged accounts and for network access to non-privileged accounts. (device)5 (partial credit)
☐3.5.4Employ replay-resistant authentication mechanisms for network access to privileged and nonprivileged accounts.1
☐3.5.5Prevent reuse of identifiers for a defined period.1
☐3.5.6Disable identifiers after a defined period of inactivity.1
☐3.5.7Enforce a minimum password complexity and change of characters when new passwords are created.1
☐3.5.8Prohibit password reuse for a specified number of generations.1
☐3.5.9Allow temporary password use for system logons with an immediate change to a permanent password.1
☐3.5.10Store and transmit only cryptographically-protected passwords.5
☐3.5.11Obscure feedback of authentication information.1

3.6 Incident Response (3)

IDRequirementSPRS points
☐3.6.1Establish an operational incident-handling capability for organizational systems that includes preparation, detection, analysis, containment, recovery, and user response activities.5
☐3.6.2Track, document, and report incidents to designated officials and/or authorities both internal and external to the organization.5
☐3.6.3Test the organizational incident response capability.1

3.7 Maintenance (6)

IDRequirementSPRS points
☐3.7.1Perform maintenance on organizational systems.3
☐3.7.2Provide controls on the tools, techniques, mechanisms, and personnel used to conduct system maintenance.5
☐3.7.3Ensure equipment removed for off-site maintenance is sanitized of any CUI.1
☐3.7.4Check media containing diagnostic and test programs for malicious code before the media are used in organizational systems.3
☐3.7.5Require multifactor authentication to establish nonlocal maintenance sessions via external network connections and terminate such connections when nonlocal maintenance is complete.5
☐3.7.6Supervise the maintenance activities of maintenance personnel without required access authorization.1

3.8 Media Protection (9)

IDRequirementSPRS points
☐3.8.1Protect (i.e., physically control and securely store) system media containing CUI, both paper and digital.3
☐3.8.2Limit access to CUI on system media to authorized users.3
☐3.8.3Sanitize or destroy system media containing CUI before disposal or release for reuse. (device)5
☐3.8.4Mark media with necessary CUI markings and distribution limitations.1
☐3.8.5Control access to media containing CUI and maintain accountability for media during transport outside of controlled areas.1
☐3.8.6Implement cryptographic mechanisms to protect the confidentiality of CUI stored on digital media during transport unless otherwise protected by alternative physical safeguards.1
☐3.8.7Control the use of removable media on system components. (device)5
☐3.8.8Prohibit the use of portable storage devices when such devices have no identifiable owner.3
☐3.8.9Protect the confidentiality of backup CUI at storage locations.1

3.9 Personnel Security (2)

IDRequirementSPRS points
☐3.9.1Screen individuals prior to authorizing access to organizational systems containing CUI.3
☐3.9.2Ensure that organizational systems containing CUI are protected during and after personnel actions such as terminations and transfers.5

3.10 Physical Protection (6)

IDRequirementSPRS points
☐3.10.1Limit physical access to organizational systems, equipment, and the respective operating environments to authorized individuals.5
☐3.10.2Protect and monitor the physical facility and support infrastructure for organizational systems.5
☐3.10.3Escort visitors and monitor visitor activity.1
☐3.10.4Maintain audit logs of physical access.1
☐3.10.5Control and manage physical access devices.1
☐3.10.6Enforce safeguarding measures for CUI at alternate work sites.1

3.11 Risk Assessment (3)

IDRequirementSPRS points
☐3.11.1Periodically assess the risk to organizational operations (including mission, functions, image, or reputation), organizational assets, and individuals, resulting from the operation of organizational systems and the associated processing, storage, or transmission of CUI.3
☐3.11.2Scan for vulnerabilities in organizational systems and applications periodically and when new vulnerabilities affecting those systems and applications are identified. (device)5
☐3.11.3Remediate vulnerabilities in accordance with risk assessments.1

3.12 Security Assessment (4)

IDRequirementSPRS points
☐3.12.1Periodically assess the security controls in organizational systems to determine if the controls are effective in their application.5
☐3.12.2Develop and implement plans of action designed to correct deficiencies and reduce or eliminate vulnerabilities in organizational systems.3
☐3.12.3Monitor security controls on an ongoing basis to ensure the continued effectiveness of the controls.5
☐3.12.4Develop, document, and periodically update system security plans that describe system boundaries, system environments of operation, how security requirements are implemented, and the relationships with or connections to other systems.Not scored

3.13 System and Communications Protection (16)

IDRequirementSPRS points
☐3.13.1Monitor, control, and protect communications (i.e., information transmitted or received by organizational systems) at the external boundaries and key internal boundaries of organizational systems.5
☐3.13.2Employ architectural designs, software development techniques, and systems engineering principles that promote effective information security within organizational systems.5
☐3.13.3Separate user functionality from system management functionality.1
☐3.13.4Prevent unauthorized and unintended information transfer via shared system resources.1
☐3.13.5Implement subnetworks for publicly accessible system components that are physically or logically separated from internal networks.5
☐3.13.6Deny network communications traffic by default and allow network communications traffic by exception (i.e., deny all, permit by exception).5
☐3.13.7Prevent remote devices from simultaneously establishing non-remote connections with organizational systems and communicating via some other connection to resources in external networks (i.e., split tunneling).1
☐3.13.8Implement cryptographic mechanisms to prevent unauthorized disclosure of CUI during transmission unless otherwise protected by alternative physical safeguards.3
☐3.13.9Terminate network connections associated with communications sessions at the end of the sessions or after a defined period of inactivity.1
☐3.13.10Establish and manage cryptographic keys for cryptography employed in organizational systems.1
☐3.13.11Employ FIPS-validated cryptography when used to protect the confidentiality of CUI.5 (partial credit)
☐3.13.12Prohibit remote activation of collaborative computing devices and provide indication of devices in use to users present at the device.1
☐3.13.13Control and monitor the use of mobile code.1
☐3.13.14Control and monitor the use of Voice over Internet Protocol (VoIP) technologies.1
☐3.13.15Protect the authenticity of communications sessions.5
☐3.13.16Protect the confidentiality of CUI at rest. (device)1

3.14 System and Information Integrity (7)

IDRequirementSPRS points
☐3.14.1Identify, report, and correct system flaws in a timely manner. (device)5
☐3.14.2Provide protection from malicious code at designated locations within organizational systems.5
☐3.14.3Monitor system security alerts and advisories and take action in response.5
☐3.14.4Update malicious code protection mechanisms when new releases are available.5
☐3.14.5Perform periodic scans of organizational systems and real-time scans of files from external sources as files are downloaded, opened, or executed.3
☐3.14.6Monitor organizational systems, including inbound and outbound communications traffic, to detect attacks and indicators of potential attacks.5
☐3.14.7Identify unauthorized use of organizational systems.3

The 800-171 requirements that live on laptops and phones

16 of the 110 requirements have a device side. Many of them can be shown with a device management report for every device at once, though two (3.3.1 and 3.5.3) are only partly device work:

IDWhat it asksPointsWhat a device management tool can do
3.1.10Use session lock with pattern-hiding displays to prevent access and viewing of data after a period of inactivity.1Screen lock after inactivity
3.1.18Control connection of mobile devices.5Enroll mobile devices and apply passcode and encryption policy
3.1.19Encrypt CUI on mobile devices and mobile computing platforms.3Enforce encryption on phones and report status
3.3.1Create and retain system audit logs and records to the extent needed to enable the monitoring, analysis, investigation, …5Partly: admin event log of console actions, with export
3.4.1Establish and maintain baseline configurations and inventories of organizational systems (including hardware, software, …5Device inventory and policy baselines
3.4.2Establish and enforce security configuration settings for information technology products employed in organizational sys…5Enforce passcode, encryption, USB and firewall settings
3.4.6Employ the principle of least functionality by configuring organizational systems to provide only essential capabilities…5App and USB restrictions
3.4.7Restrict, disable, or prevent the use of nonessential programs, functions, ports, protocols, and services.5App block list, USB and host firewall controls
3.4.8Apply deny-by-exception (blacklisting) policy to prevent the use of unauthorized software or deny-all, permit-by-excepti…5App allow and block lists
3.4.9Control and monitor user-installed software.1App lists (partly: monitoring of user installs stays with you)
3.5.3Use multifactor authentication for local and network access to privileged accounts and for network access to non-privile…5 (partial credit)Partly: MFA for trio.so console admins only
3.8.3Sanitize or destroy system media containing CUI before disposal or release for reuse.5Wipe company-owned devices before reuse
3.8.7Control the use of removable media on system components.5Restrict USB storage (Mac, Windows)
3.11.2Scan for vulnerabilities in organizational systems and applications periodically and when new vulnerabilities affecting …5Vulnerability findings with CVSS, EPSS and CISA KEV
3.13.16Protect the confidentiality of CUI at rest.1BitLocker and FileVault enforcement
3.14.1Identify, report, and correct system flaws in a timely manner.5OS updates plus vulnerability findings

Some endpoint requirements need other tools. Malware protection, its updates and scans (3.14.2, 3.14.4, 3.14.5) come from your EDR or antivirus. FIPS-validated cryptography (3.13.11) depends on how the operating system's encryption module is configured, so confirm it separately. Device logs (3.3.1) come from your logging tools.

How to do a NIST 800-171 self-assessment

The Basic assessment in the DoD Assessment Methodology is a self-assessment. It's the one most contractors post in SPRS.

Six steps of an SP 800-171 self-assessment: scope, write the SSP, assess, score, plan fixes, post to SPRS
Six steps of an SP 800-171 self-assessment: scope, write the SSP, assess, score, plan fixes, post to SPRS
  1. Scope. Find where CUI is stored, processed and sent: the systems, the people and the devices. A smaller boundary means fewer systems to protect, so many companies put CUI in a separate enclave.
  2. Write the system security plan (SSP). Describe the boundary, the environment and how each requirement is implemented (requirement 3.12.4). Without an SSP, you can't report a score.
  3. Assess each requirement. SP 800-171A (June 2018) breaks the 110 requirements into 320 assessment objectives. NIST withdrew it in May 2024 along with Rev. 2, but CMMC still references it. A requirement is met only when every one of its objectives is. Collect the evidence as you go.
  4. Score. Start at 110 and subtract the points for each requirement that isn't met. The Excel tracker does this for you.
  5. Plan the fixes. Write a plan of action (POA&M) for each gap with an owner and a date. A POA&M doesn't earn the points back: the requirement still counts as not met until it's done.
  6. Post the result in SPRS. Enter the assessment date, the summary score (for example, 95 out of 110), the scope and CAGE codes, the SSP it covers, and the date you expect to reach 110. Repeat at least every three years, and update when things change.

How the SPRS score works

The score runs from 110 down to -203, the lowest possible score if nothing is met (worked out from the weights in 32 CFR 170.24). There are 44 five-point requirements, 14 three-point requirements and 51 one-point requirements. 3.12.4, the SSP, has no points because without it there's no score at all.

SPRS score scale from 110 down to the lowest possible score of minus 203, with requirement weights of 5, 3 and 1 points
SPRS score scale from 110 down to the lowest possible score of minus 203, with requirement weights of 5, 3 and 1 points
  • Partial credit exists for two requirements only: 3.5.3 (MFA) and 3.13.11 (FIPS-validated cryptography) can lose 3 points instead of 5 when they're partly in place.
  • Everything else is met or not met. A requirement that's 90% done counts as not met.
  • For CMMC Level 2, a conditional status needs a score of at least 88 (80% of 110), and the open POA&M items can only be one-point requirements (plus 3.13.11 in a limited case). They have to be closed within 180 days.

Where CMMC stands in October 2026

CMMC is how DoD checks that 800-171 is in place. Level 2 uses the same 110 requirements.

  • The rules. The CMMC program rule (32 CFR Part 170) took effect December 16, 2024, and the DFARS rule that puts CMMC into contracts took effect November 10, 2025. That date started Phase 1: Level 1 and Level 2 self-assessments.
  • Phase 2 suspended. On July 13, 2026, DoD suspended the planned November 2026 start of Phase 2, which would have required third-party (C3PAO) Level 2 assessments. Under the September 2026 deviation, contracts can require at most a Level 1 or Level 2 self-assessment for now.
  • 800-171 still applies. The suspension doesn't change DFARS 252.204-7012. You still need to implement the 110 requirements and keep a current SPRS score.

Level 3 adds 24 requirements from SP 800-172 (February 2021). NIST published SP 800-172 Rev. 3 in May 2026, but CMMC still references the 2021 version.

Download the free NIST checklist and SPRS tracker

The download is the trio.so NIST compliance checklist, an Excel workbook and a PDF guide. For 800-171, use:

  • SP 800-171 tab: all 110 requirements with the NIST text and point values. Mark each one Met, Partial or Not met; the SPRS score is complete once all 110 are marked.
  • POA&M tab: gaps with owners, milestones and dates.
  • Device controls tab: the 800-171 requirements a device management tool can support, and what stays with you.
  • PDF: the SPRS score explained on one page, and the 65-item NIST compliance checklist mapped to 800-171.

Federal systems use the full catalog instead: see the NIST 800-53 controls list.

How trio.so helps with the device requirements

Your 800-171 program, the SSP and the score stay your organization's responsibility. trio.so supports the device requirements from one console:

  • Inventory and baselines (3.4.1, 3.4.2): every enrolled Windows, Mac, iOS and Android device, with passcode, screen lock and encryption enforced as policy (BitLocker and FileVault on Windows and Mac), and USB and firewall settings on Mac and Windows.
  • Encryption (3.1.19, 3.13.16): enforce BitLocker and FileVault on laptops and encryption on phones, and see encryption status per device. Confirm FIPS validation (3.13.11) for your OS configuration.
  • Session lock (3.1.10): screen lock after inactivity.
  • Software (3.4.6 to 3.4.8): app allow and block lists; USB storage restriction on Mac and Windows (3.8.7).
  • Patching and vulnerabilities (3.14.1, 3.11.2): OS updates on Windows, macOS, iOS and Android, and vulnerability findings ranked by CVSS, EPSS and CISA KEV.
  • Lost devices and reuse: lock Macs, iPhones and Android devices, and wipe company-owned devices before reuse (3.8.3).
  • Evidence: an admin event log of console actions with export, and compliance evidence you can export for your assessment.

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Sources. Last reviewed October 2026. Requirement text is quoted from NIST SP 800-171 Rev. 2. The device mapping is ours, not NIST's or DoD's. This article is guidance, not legal advice.

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Frequently Asked Questions (FAQ)

Have questions? We've got answers. This section covers some of the most commonly asked questions related to this topic.

Revision 2, which DoD contracts and CMMC Level 2 use, has 110 requirements in 14 families. Revision 3 (May 2024) has 97 requirements in 17 families.

For DoD contracts, Rev. 2. CMMC Level 2 and the current DFARS 252.204-7012 deviation (September 2026) both reference Rev. 2, even though NIST has withdrawn it in favor of Rev. 3.

Start at 110 and subtract 5, 3 or 1 point for each requirement not met, using the weights in 32 CFR 170.24. Only 3.5.3 and 3.13.11 allow partial credit. The lowest possible score is -203.

110 means every requirement is met. For a CMMC Level 2 conditional status you need at least 88, with only one-point items left on the POA&M, closed within 180 days.

Scope where CUI lives, write the system security plan, assess the 320 objectives in SP 800-171A, score against 110, write a POA&M for the gaps, and post the score in SPRS.

The assessment must be no more than three years old when you're awarded a contract, unless the solicitation sets a shorter period. Update it sooner when your systems or your score change.

No. NIST doesn't certify organizations. You show compliance through an assessment under the DoD Assessment Methodology (your own Basic self-assessment, or a DoD Medium or High assessment) or a CMMC assessment, not a NIST certificate.

CMMC Phase 1 began November 10, 2025 with Level 1 and Level 2 self-assessments. DoD suspended Phase 2, third-party Level 2 assessments, in July 2026. The 800-171 requirements under DFARS 252.204-7012 still apply.

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