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CMMC policy templates

Fourteen plain-English security policies, one for each NIST SP 800-171 Rev 2 family, written for a 5 to 50 person shop. Enter your company, your people and a few settings once; every clause names the requirement it answers, and each policy can be edited, copied, printed or downloaded.

What a CMMC policy is, and what it is not

A security policy is the written rule your shop follows for one family of NIST SP 800-171 requirements: who may sign in, how long logs are kept, what happens to a drive before it leaves the building. CMMC Level 2 is the 110 requirements of NIST SP 800-171 Rev 2, grouped in 14 families, so this generator writes 14 policies and tags every clause with the requirement it answers.

Rev 2 has no requirement that says “write a policy”. NIST tailored the policy-and-procedure controls (AC-1, AU-1 and the rest) out of the requirement set and marked them NFO, “expected to be routinely satisfied by nonfederal organizations without specification”. In practice the policy still carries weight: NIST SP 800-171A lists the family's policy first among the documents an assessor may examine, and many of its objectives ask that something be “defined”, such as how many failed logons lock an account. A policy is the natural place to define it. Rev 3 makes the duty explicit in requirement 03.15.01, but DoD binds Rev 2 today; how the two revisions and CMMC fit together is in CMMC vs NIST SP 800-171.

Caution

A policy alone does not meet a requirement. An assessor checks each requirement's objectives against what is implemented, and examines the settings, logs and records that show it. A policy that says screens lock after 15 minutes is a finding if the screens do not. Write what you do, then do what you wrote, and keep the evidence the policy lists.

How to use the policy generator

Five steps
  1. 01Fill in your shop. Company, the person who owns the policies, the person who approves them, who runs your IT and where your CUI lives.
  2. 02Set the values. Open the settings and type what your systems actually enforce: lockout, screen lock, password rules, log retention, patch window.
  3. 03Pick the policies. All fourteen are ticked. Untick a family only if your system security plan already covers it in another document.
  4. 04Edit until it is true. Open each policy, change any sentence that does not describe your shop, and delete what you do not do. Copy or download each one.
  5. 05Approve, train, file. The approver signs and dates each policy, staff are told what changed, and the system security plan points to where the policies live.

The policies are one layer of the paperwork. The system security plan template describes how each requirement is implemented and should point to these policies; the NIST SP 800-171 checklist tells you which requirements are actually met; and anything not met yet belongs in the POA&M builder, within the limits the rule sets.

The numbers NIST leaves to you

NIST never says how many failed logons should lock an account or how long to keep logs. NIST SP 800-171A asks only that the value be defined, and in the next objective it usually checks that the defined value is implemented. That is why the generator asks for numbers: each one below is an objective an assessor will look for in writing, and then in your settings.

14 values to define
NIST SP 800-171A objectives that ask for a defined value
ObjectiveWhat 800-171A asks (its words)Example shopSet in
3.1.8[a]The means of limiting unsuccessful logon attempts is defined.5 failed triesForm
3.1.10[a]The period of inactivity after which the system initiates a session lock is defined.15 minutesForm
3.1.11[a]Conditions requiring a user session to terminate are defined.8 hours; end of shiftPolicy text
3.3.1[e]Retention requirements for audit records are defined.365 daysForm
3.5.6[a]A period of inactivity after which an identifier is disabled is defined.45 daysForm
3.5.7[a]Password complexity requirements are defined.14 characters, mixedForm
3.5.8[a]The number of generations during which a password cannot be reused is specified.24 passwordsForm
3.11.1[a]The frequency to assess risk to organizational operations, organizational assets, and individuals is defined.Every 12 monthsForm
3.11.2[a]The frequency to scan for vulnerabilities in organizational systems and applications is defined.monthlyForm
3.12.1[a]The frequency of security control assessments is defined.Every 12 monthsForm
3.12.4[g]The frequency to update the system security plan is defined.Every 12 monthsForm
3.13.9[a]A period of inactivity to terminate network connections associated with communications sessions is defined.Set per systemPolicy text
3.14.1[e]The time within which to correct system flaws is specified.14 days (critical)Form
3.14.5[a]The frequency for malicious code scans is defined.Weekly full scanPolicy text

Pick numbers your systems can enforce today, not the strictest you have read about. If the policy says 14 days to patch a critical flaw and the patch report shows 40, the policy has created a finding instead of preventing one.

Worked example: a 22-person CNC shop

The tool opens on a fictional job shop, Halvorsen Precision Machining LLC: 22 people, drawings marked as CUI arriving from a prime, an outside IT provider, and CUI kept in a small enclave of cloud email, cloud storage and four CAD/CAM workstations. The operations manager owns the policies and the president approves them.

Weak and strong

AC.L2-3.1.8

Weak

Access to systems is restricted appropriately and accounts are protected against password guessing.

Strong

An account locks after 5 failed sign-in attempts in a row and stays locked until Northgate IT unlocks it or the lockout period ends.

The weak line defines nothing, so objective [a] has no answer and an assessor has no number to test the setting against.

IR.L2-3.6.2

Weak

Incidents will be reported to the appropriate authorities in a timely manner.

Strong

Cyber incidents affecting covered defense information are reported to DoD at https://dibnet.dod.mil within 72 hours of discovery, and the report number goes to the prime.

DFARS 252.204-7012 already sets the clock and the place. A policy that does not say them leaves staff to guess on the worst day of the year.

Then follow one sentence all the way through. The policy defines the number, the system enforces it, and a record proves it. Miss either of the last two and the requirement is not met, however good the wording.

One setting, end to end
Policy
AC 4.1: "An account locks after 5 failed sign-in attempts…"
Setting
The account lockout threshold in the identity system, set to 5.
Evidence
A dated screenshot or export of that setting, filed with the SSP.
Objectives
3.1.8[a] defined (the policy), 3.1.8[b] implemented (the setting).

The incident clause matters even with CMMC's third-party phase on hold: DFARS 252.204-7012 still binds, and its 72-hour reporting rule belongs in the policy your staff will open on the day something goes wrong.

Where the rule leans on your policies: the shop floor

For two kinds of asset, the CMMC rule itself points at your policies rather than at the 110 requirements. Both are common in a machine shop: the CNC controls, coordinate measuring machine and test rigs that may run a program built from a CUI drawing, and the office laptops that could hold CUI but are not meant to.

Rule text

Specialized Assets

Assets that can process, store, or transmit CUI but are unable to be fully secured, including: Internet of Things (IoT) devices, Industrial Internet of Things (IIoT) devices, Operational Technology (OT), Government Furnished Equipment (GFE), Restricted Information Systems, and Test Equipment.

Show these assets are managed using the contractor's risk-based security policies, procedures, and practices.

Contractor Risk Managed Assets

Assets that can, but are not intended to, process, store, or transmit CUI because of security policy, procedures, and practices in place.

If OSA's risk-based security policies, procedures, and practices documentation or other findings raise questions about these assets, the assessor can conduct a limited check to identify deficiencies.

32 CFR 170.19(c)(1), table 3

So the policies are not only paperwork for the 110 requirements. For specialized assets they are the thing the assessor reviews, and for contractor risk managed assets they are what keeps CUI off a machine in the first place. Name those machines in the policies: the configuration management policy can say how a networked controller is isolated and who may load programs onto it, and the media protection policy can say how a USB stick moves a program to an old control that has no network at all. Decide which machines fall where with the CMMC scoping worksheet first.

Takeaway

Add one sentence per machine type to the policy that governs it, then make the asset inventory, the system security plan and the policy name the same machines. Two more places worth a careful sentence: how drives are wiped before a machine or PC is sold (see NIST 800-88 media sanitization), and what the yearly training actually covers (see CUI training).

Questions about CMMC policies

Questions
Do I need 14 separate policy documents?

No format is required. NIST's own discussion in Rev 3 says policies “can be included as part of the organizational security policy or be represented by separate policies that address each family”. One document with 14 sections works as well as 14 files, as long as every family is covered and the system security plan says where to find it. The generator gives you both: copy one policy, or copy or download all of them as one file.

Will these policies make my shop CMMC compliant?

No. A policy states what you will do. Each requirement is met only when it is implemented and you can show the evidence, and a Level 2 self-assessment is scored on the requirements, not on the paperwork. Check where you stand with the NIST SP 800-171 checklist and the SPRS score calculator.

Do I need policies for CMMC Level 1?

Level 1 is the 15 basic safeguarding requirements of FAR 52.204-21, and it is MET or NOT MET in its entirety. None of the 15 is a policy requirement, but writing down who may use which systems and how media is destroyed makes the yearly self-assessment and affirmation easier to stand behind. The CMMC Level 1 checklist covers what each one asks.

How often do policies have to be reviewed?

Rev 2 sets no cycle for policies; the policy controls were left to organizations. Rev 3's 03.15.01 asks you to review and update them at a frequency you define. The generator uses your review cycle for the policies, the risk assessment, the control assessment and the SSP update, because Rev 2 asks you to define a frequency for each of the last three. Twelve months is the example, not a rule.

Who should approve and sign them?

Someone with the authority to make the shop follow them, usually the owner or president. That is often the same person who acts as the Affirming Official, the senior representative who affirms the assessment in SPRS, but signing a policy and affirming in SPRS are separate acts.

Is anything I type saved or sent anywhere?

No. The policies are built in your browser; nothing is stored or sent, and closing the page clears it. Download or copy your text before you leave.