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CMMC Level 1 Checklist (FAR 52.204-21 Practices, Example Evidence)

CMMC Level 1 is the entry level of the Cybersecurity Maturity Model Certification program and applies to companies that handle only Federal Contract Information. This checklist walks the safeguarding practices drawn from FAR 52.204-21, shows what evidence usually satisfies each one, and ends with the annual affirmation steps.

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13 critical items still open - these are the highest-risk gaps.

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Scope: know where Federal Contract Information lives

Access control (4 practices)

Identification and authentication (2 practices)

Media protection and physical protection (5 practices)

System and communications protection (2 practices)

System and information integrity (4 practices)

Affirmation and upkeep

Level 1 is a self-assessment and it is pass or fail: every practice must be met (or properly marked not applicable) before your affirming official posts the result and affirmation in SPRS. Anything unchecked is a gap to close first. Items marked critical are the ones assessors and primes ask about most.

CMMC scoping review

Optional: a short call to check how your ERP and file shares fall in or out of FCI scope.

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How to use this CMMC Level 1 checklist

Start with the scope group: you cannot answer the practices until you know which systems touch FCI. Then work down each group, tick what is genuinely in place today and note the evidence you could show an assessor or a prime. Be strict. A policy that nobody follows is not a met practice. Print or export the result, assign an owner to every unchecked line and re-run the list when the fixes are done. Small shops often finish in an afternoon because the same few controls (MFA, antivirus, a visitor log, a firewall) cover many lines.

  • Scope first, then the six control groups, then affirmation.
  • Write the evidence next to each item, not just a tick.
  • Critical items are the ones most often questioned.

What Level 1 requires and what it does not

Level 1 covers basic safeguarding of FCI: information provided by or generated for the government under a contract that is not meant for public release. FAR 52.204-21 lists 15 safeguarding requirements, which CMMC expresses as 17 practices across access control, identification and authentication, media protection, physical protection, system and communications protection, and system and information integrity. Level 1 is a yearly self-assessment with an affirmation, with no third-party assessor. If you hold CUI, for example export-controlled technical drawings or data under DFARS 252.204-7012, you need Level 2, which is a much larger scope based on NIST SP 800-171. Confirm the level with your contract, not your assumptions.

Example evidence and common mistakes

Good evidence is simple and dated: an exported user list, a screenshot of the MFA policy, the antivirus console showing every device protected, a visitor log with the last six months of entries, a shred bin pickup receipt. The most common mistakes are scoping too narrowly (forgetting personal phones that read email with FCI), shared logins on the shop floor PC that opens drawings, unmanaged home laptops, no process for departing staff, and an affirmation signed by someone who never saw the evidence. Another frequent miss is treating the web site and social posts as out of scope when a proud post could reveal contract details.

  • Forgotten devices: phones, tablets, USB drives, personal laptops.
  • Shared accounts on production terminals that display drawings.
  • No leaver checklist for keys, badges and accounts.
  • Affirming official has not reviewed the evidence.

Annual affirmation and keeping it current

After the self-assessment, an affirming official confirms the result in SPRS for each CAGE code in scope. Repeat every year and whenever the environment changes materially, such as a new cloud service, a new site or a different IT provider. Keep the evidence folder, the scope diagram and the dated checklist together so you can answer a prime's request in minutes. Rules and effective dates for the CMMC program have shifted during rulemaking, so check the current DoD and contract language before you rely on any date in this page.

Frequently Asked Questions

Who needs a CMMC Level 1 assessment?

Contractors and subcontractors that process, store or transmit Federal Contract Information but no CUI. Your contract or prime will say the required level. If any CUI is involved you generally need Level 2 instead.

Is there an official CMMC Level 1 form?

There is no paper certificate. You do a self-assessment against the practices and an affirming official enters the result and affirmation in SPRS. This checklist is a working record of that assessment, not a government form.

How many practices are in CMMC Level 1?

FAR 52.204-21 has 15 basic safeguarding requirements. CMMC maps them to 17 practices that are assessed through a set of objectives. All must be met for a passing Level 1 result.

Do I need a consultant or C3PAO for Level 1?

No assessor is required at Level 1, since it is a self-assessment. A consultant can help with scoping and evidence, but your affirming official remains accountable for the accuracy of the affirmation.

If your drawings and POs live in an ERP, we can show how to keep FCI inside your own network with a private AI layer, so staff get answers without sending data to a public service. This checklist works without us.

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