CMMC 2.0 Level 2 · NIST SP 800-171

Your DoD contract now scores CMMC. IA.L2-3.5.3 wants MFA for privileged and network access — is it on AD and your network gear?

CMMC 2.0 Level 2 mirrors the 110 controls of NIST SP 800-171, and the identification-and-authentication family is where assessments stall. IA.L2-3.5.3 requires multi-factor authentication for local and network access to privileged accounts, and for network access to non-privileged accounts. IA.L2-3.5.4 adds that authentication must be replay-resistant. These apply to the systems that handle CUI — domain controllers, file servers, and the network paths into them — not just email. Authnull enforces a phishing-resistant factor across AD, Windows, Linux, and RADIUS, and produces the per-login evidence your assessor and SSP need.

At a glance
FrameworkCMMC 2.0 Level 2
Key controlsIA.L2-3.5.3 · 3.5.4 · AC.L2-3.1.12
Applies toDoD contractors handling CUI
TimingPhasing into DoD contracts
You walk away withSSP & POA&M evidence
Mapped to specific controls — not a generic MFA checklist.
The line that put you here
Use multifactor authentication for local and network access to privileged accounts and for network access to non-privileged accounts.
— NIST SP 800-171 r2, IA.L2-3.5.3
A C3PAO assessment is pass/fail per control — there is no partial credit. IA.L2-3.5.3 is one of the controls most likely to be marked NOT MET when MFA stops at the cloud IdP.
Requirement mapping

Requirement → Authnull

ControlWhat it requiresHow Authnull covers itStatus
IA.L2-3.5.3MFA for local & network access to privileged accounts; network access to non-privileged accounts.AD logon, local Windows console, and SSH MFA covers both local and network access — privileged and standard users alike.Covered
IA.L2-3.5.4Employ replay-resistant authentication mechanisms.FIDO2 / security-key and cryptographic push factors are replay-resistant by design.Covered
AC.L2-3.1.12Monitor and control remote access sessions.RADIUS MFA on VPN plus per-session logs deliver both the control and the monitoring record.Covered
AC.L2-3.1.1Limit system access to authorized users and devices.Factor binding ties each session to a known user and device before access is granted.Covered
Why your IdP report isn't enough

The gap is always below the cloud login.

Your IdP already satisfies
Microsoft 365 GCC sign-in
Cloud collaboration apps
What it leaves for the audit
AD / domain controllers
CUI file & app servers
VPN into the enclave
Linux SSH

Authnull enforces MFA on every path on the right — at the directory, OS, and RADIUS layer — so the column that fails the audit becomes the column that passes it.

Evidence

What you hand the assessor.

SSP-ready control mapping

Each enforced path mapped to its 800-171 control for your System Security Plan and assessor walkthrough.

Assessment artifacts

Per-login records by user, system and factor — the evidence a C3PAO samples during a Level 2 assessment.

Replay-resistant factors

Meets IA.L2-3.5.4 with FIDO2 and cryptographic push — no custom work.

Turn IA.L2-3.5.3 from NOT MET to MET.

Enforce replay-resistant MFA across AD, servers, and remote access, with evidence mapped to your SSP. Start free, or review your boundary with a compliance engineer.

Talk to a compliance engineer