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CMMC scoping guide and worksheet

Before a Level 2 assessment, the rule wants every asset in your shop sorted into one of five categories, and each category carries its own paperwork. List the people, systems, machines, rooms and providers below, pick a category for each, and the worksheet draws the boundary and spells out what 32 CFR 170.19 asks of every line. Rule text read on 2026-10-22.

The tool: CMMC scoping guide and worksheet

Scoping is the same whoever assesses you. What is in force while the third-party requirement is suspended:

Status as of 2026-10-23
In force today
DFARS 252.204-7012 still applies: NIST SP 800-171 Rev 2 on systems that hold covered defense information, cyber incidents reported to DoD within 72 hours, and FedRAMP Moderate or equivalent for any cloud that holds it. DFARS 252.204-7012(b)(2), (c)
Suspended
Phase 2, due in November 2026, is suspended for every contractor, whatever its size: contracts are not adding the third-party Level 2 (C3PAO) or Level 3 (DIBCAC) requirements. DoW CIO memo of 2026-07-13, applied by Class Deviation 2026-O0025 Rev 3
Not yet known
The outcome of the CMMC Reform Task Force review is not confirmed as of 2026-10-23: no report or rule change has been published. Federal Register search, 2026-10-23

What still applies while Phase 2 is suspended

What CMMC scoping is

Scoping is deciding, in writing, which of your assets an assessment will look at. The rule is blunt about the order: “The CMMC Assessment Scope must be specified prior to assessment,” and the scope is “the set of all assets in the OSA's environment that will be assessed against CMMC security requirements.” A Level 2 self-assessment is run against exactly that set, so the line you draw here decides how much of the shop the 110 requirements land on.

“Asset” is wider than IT. Part 170's definition names hardware and software, and also humans and services, and its scoping section tells you to consider people, technology, facilities and External Service Providers. That is why the worksheet has a type for people and one for the building. Decide what you hold first: the FCI vs CUI comparison sorts the paperwork, and what counts as CUI covers the markings.

How to use the worksheet

Five steps
  1. 1List everything that could touch a drawingWalk the CUI from the moment it arrives (an email from the prime, a portal download) to the moment it leaves (a shipped part, a deleted file). Every person, laptop, share, printer, machine and service it passes is a line.
  2. 2Add what protects those thingsThe firewall, the sign-in and MFA service, the log console, the backup system and whoever runs them. These are Security Protection Assets even if no drawing ever lands on them.
  3. 3Pick one category per lineThe rule for the category appears under the line. If you hesitate, the sorter further down asks four questions and gives the category.
  4. 4Write the reason on every line you keep outOut-of-scope and Contractor Risk Managed lines show an Ask until they carry a reason. Those reasons are what an assessor reads first.
  5. 5Export and carry it into the SSPDownload the CSV for the asset inventory, print the sheet for the network-diagram session, and paste the copy into the system security plan.

The inventory is not optional paperwork. Without an up-to-date SSP (CA.L2-3.12.4) at the time of assessment, the assessment cannot be completed, and every in-scope category on this page has to appear in that SSP. The SSP template starts from the boundary you draw here.

The two sentences that move assets out

Most of what scoping saves you sits in the out-of-scope column, and two lines of table 3 decide what can go there.

The same table says Contractor Risk Managed Assets “are not required to be physically or logically separated from CUI assets.” That is the trade: separate an asset and it leaves the scope; leave it on the same network and it stays in, carried by your written policy. An enclave is the separation done on purpose, and the CMMC enclave comparison sets out the five ways small shops build one.

Worked example: a 22-person machine shop

The worksheet opens on a job shop that machines brackets and housings to a prime's drawings marked Distribution Statement D. Sixteen lines come out as 12 inside the boundary and 4 outside it. Eleven of the sixteen calls are obvious. These five are where shops lose an afternoon with their assessor:

Five hard calls
Five assets in the example shop and the category each lands in
AssetCategoryWhy
Shop-floor printerCUI AssetsIn scopeIt prints travellers with the drawing on them, and printing is processing under the rule's own definition. A printer that never gets a CUI job can go elsewhere.
CNC controllers and the CMMSpecialized AssetsIn scope, SSP reviewControllers are operational technology and the CMM is test equipment. They hold programs built from CUI drawings but cannot take an endpoint agent, so they are listed, managed by policy and shown on the diagram.
Badge reader on the engineering doorSecurity Protection AssetsIn scope, judgment callPart 170 lists physical access control as an example of operational technology, so some shops log it as Specialized. It also protects the room where CUI is printed. We list it where it protects; write your reasoning in the SSP.
Front-office PCsContractor Risk Managed AssetsIn scope, SSP reviewThey sit on the same network as the drawings share. Share permissions and a written rule keep CUI off them. Separate them and they could leave the scope instead.
Owner's home laptopOut-of-Scope AssetsOut of scopeIt reaches CUI only through a remote desktop that passes keyboard, video and mouse. Allow copy, paste, print or download and it is back in.

Notice what the example does not do: it does not shrink the boundary by renaming things. The firewall, the sign-in service and the MSP stay inside the line because they protect what is inside it, and no category lets them out.

Not sure where an asset goes?

Four questions, in the order the rule reads them. Run one asset through at a time and copy the category back into the worksheet.

Sort one asset

    Does CUI ever get opened, saved, printed or sent on it?

    Process, store or transmit, in the rule's words. Paper counts: a printed drawing on a desk is stored.

    Cloud services and MSPs: table 4

    Outside providers are sorted by two questions: is it a cloud service provider, and does it hold CUI, Security Protection Data, or neither? Security Protection Data is the configuration data, logs, vulnerability status and passwords for your in-scope systems, which is why an MSP that never sees a drawing still lands inside the line. A cloud password manager that holds those passwords is sorted the same way; four of them are read against this table in password managers for CMMC.

    Rule text, table 4
    32 CFR 170.19(c)(2)(i) table 4, ESP scoping requirements
    The ESP holdsA cloud service providerNot a cloud service provider
    CUI (with or without SPD)The CSP shall meet the FedRAMP requirements in 48 CFR 252.204-7012.The services provided by the ESP are in the OSA's assessment scope and shall be assessed as part of the OSA's assessment.
    SPD (without CUI)The services provided by the CSP are in the OSA's assessment scope and shall be assessed as Security Protection Assets.The services provided by the ESP are in the OSA's assessment scope and shall be assessed as Security Protection Assets.
    Neither CUI nor SPDA service provider that does not process CUI or SPD does not meet the CMMC definition of an ESP.A service provider that does not process CUI or SPD does not meet the CMMC definition of an ESP.

    32 CFR 170.19(c)(2)(i), read 2026-10-22

    In practice: a cloud that holds CUI must be FedRAMP Authorized at Moderate or higher in the FedRAMP Marketplace, or meet equivalent requirements, and its Customer Responsibility Matrix goes in your SSP. Your own equipment that connects to it stays in your scope. The CMMC vs FedRAMP comparison explains the difference, and the GCC High alternatives page reads the Marketplace for the usual email and file choices.

    For an MSP the paperwork is the same either way: the use of the provider, its relationship to you and its services go in your SSP and in its service description and responsibility matrix. The CMMC MSP comparison shows how providers split that work with a shop.

    Questions shops ask about scoping

    Questions
    Are our CNC machines in scope?

    If a program built from a CUI drawing is loaded on them, yes, as Specialized Assets: listed in the inventory, treated in the SSP, shown on the network diagram and managed under your own risk-based policies. The assessor reviews the SSP for them and does not test them against the other Level 2 requirements.

    Do people really go on an asset inventory?

    Part 170 defines an asset to include humans, and its scoping section tells you to consider people alongside technology, facilities and service providers. In practice a role line (“programmers, 4 people”) is enough; the names live in your access lists.

    Is a badge reader a Security Protection Asset or a Specialized Asset?

    Part 170 lists physical access control mechanisms as an example of operational technology, and operational technology is a Specialized Asset type. A badge reader that guards the CUI room also provides a security function to the scope. The rule does not settle the overlap; pick one, say why in the SSP, and keep it consistent.

    Does scoping work the same way at Level 1?

    It is simpler. Systems that process, store or transmit FCI are in scope; everything else is out, with no documentation required for the out-of-scope ones, and Specialized Assets are not part of the Level 1 scope at all. The Level 1 checklist covers the 15 requirements that apply.

    Does the Phase 2 suspension change scoping?

    No. Part 170 has not been amended since it took effect on 2024-12-16, and the scoping section is part of it. The suspension changes who assesses, not what is assessed: a Level 2 (Self) assessment runs on the scope you draw here. The status box above shows what applies today.

    Can our MSP get certified so we do not have to assess it?

    The rule lets a provider “voluntarily undergo a CMMC certification assessment to reduce the ESP's effort required during the OSA's assessment.” Its services still sit in your scope and in your SSP; a certification reduces the work, it does not move the line.

    Is this worksheet an assessment?

    No. It sorts and documents; it does not test anything, and nothing you type leaves your browser. Score the requirements with the NIST SP 800-171 checklist and the SPRS score calculator.