Identification & Authentication (IA): Why Knowing “Who” and “How” Matters More Than Passwords

The Forgotten Step That Opened the Door

Imagine this: It’s 2 a.m., and you’re awakened by the shrill tone of your phone. A third-party alert shows an unknown device logged on to a server that holds your company’s drawings for a U.S. DoD contract. Your IT manager (half-asleep) tries to determine if this is a valid remote access or if someone has found a back-door. The contract is with the Department of Defense, the data is Controlled Unclassified Information (CUI), and your company is one of the vital links in the defense supply chain. 

Because you didn’t enforce strong identification and authentication controls, the scenario is unfolding: your reputation is at risk, the contract could be lost, and you’re scrambling to prove you did everything right. 

Now imagine instead: That same login attempt fails because the device isn’t enrolled in your identity system, the user is required to authenticate with multi‐factor, the attempt is logged, flagged, and an alert is issued to your operations team. You’re awake, the issue is handled in minutes, no contract breach, no panic, no data exfiltration. 

This is the power of the IA control family in CMMC 2.0. It’s not just about checking boxes – it’s about knowing exactly who is getting access to what, when, how, and making sure they’re truly authorized. For small and mid-sized defense contractors, mastering IA equals staying in business. 

What Meeting the Objectives Might Look Like

Here’s what auditors typically expect from the Identification & Authentication (IA) control family at Level 2 of CMMC 2.0 (Advanced). These translate into concrete actions:

• You maintain a roster of all system users, devices, and processes that access your systems or transmit CUI. (Requirement IA.L2-3.5.1: identification of users, devices, processes.)
• You enforce a process to verify user identities (when granting new access) and re-verify periodically. 
• You require credentials (for example usernames + unique IDs) and authenticate users prior to system access, including use of multifactor authentication (MFA) for remote access and privileged accounts. 
• You ensure device identification (e.g., only corporate-enrolled or trusted devices) before allowing access to systems that handle CUI. 
• You manage authentication session parameters: time-outs, lockouts, anomaly detection for unusual logins. 
• You log authentication events (successes/failures) and monitor them for suspicious activity (ties into Audit & Accountability, but within IA the focus is on user/device credentials and access). 
• You revoke access promptly when users leave or change roles, and disable/terminate inactive accounts. 
• You document your identification/authentication policies and keep evidence of implementation, as your assessment will seek proof of practice + artifacts (policies, logs, configuration screenshots). 

In short: You have to prove who, what, when, and how access happens – and that you enforce controls to protect your identity and access processes. 

Why It Matters: Because strong defense starts long before an attack begins

Why should a small or mid-sized business in the Defense Industrial Base care deeply about IA controls? Because the business value extends far beyond compliance. 

• Protecting your contracts and revenue stream. If you handle CUI and fail the IA controls – your contract pipeline can be impacted. The DoD and primes can flow-down certification requirements – and a breach could lead to contract termination, suspension, or non-award. CMMC isn’t just a checkbox… it’s eligibility.
• Protecting reputation and trust. Your government or prime-contractor customer trusts you to safeguard CUI. If someone impersonates a user and exfiltrates data, it harms your standing, your future bidding potential, and can impose expensive remediation. 
• Reducing incident response costs. If you know who is accessing systems and you limit accounts to trusted devices and enforce authentication, you reduce the risk of credential-theft attacks (e.g., phishing, golden-ticket attacks) which are a common entry point for attackers. Fixing a credential breach costs far less than recovering from full data loss. 
• Operational resilience & efficiency. With strong IA, you’re not just reacting – you’re building an identity-centric infrastructure that can scale, that supports work-from-anywhere securely (important for SMBs), and that integrates with privilege-management and access-governance workflows. That means less friction, fewer password resets, fewer compromised accounts, and smoother audits. 
• Competitive differentiation. In the DIB environment, you can position your business as “we don’t just check compliance; we enforce identity and access controls proactively.” That can be a differentiator when bidding or when primes evaluate subcontractors. 

In short: IA controls are not an expense – they’re protecting your business license. 

Where Most Companies Slip Up

Here are some common pitfalls SMBs face when it comes to Identification & Authentication – and often stumble in their CMMC assessments. 

• Passwords only, no MFA (or weak MFA). Still relying on simple credentials or single-factor authentication for remote access or privileged accounts is a recurring gap. 
• Shared credentials and generic accounts. “Admin” or “Operator” accounts used by multiple people with no clear owner, no audit trail. 
• Access credentials for inactive users. Employee leaves or changes roles, but the account remains active. That stale account becomes a hidden risk. 
• Devices not managed/unknown devices accessing systems. Laptops or BYODs with no identity enrollment – they may get access because the network doesn’t verify device identity. 
• No formal process for user identification and onboarding/off-boarding. Ad-hoc practices (e.g., IT manually granting access without formal documentation) fail evidentiary proof. 
• Lack of MFA for remote access or CUI systems. Especially in smaller firms where cost/complexity is assumed high. 
• Access session mismanagement. No lockout or session time‐outs, no ability to detect anomalous logins (e.g., overseas access at odd hours). 
• Poor documentation and evidence of controls. You might have done things “in practice” but have no log files, policy documents, or system configuration snapshots to prove it. 
• Under-scoped identity controls. Only privileging user accounts, but forgetting service accounts, processes acting on behalf of users, machine accounts, or automated clients. 

How to Start Strong (and Grow Stronger)

Here’s a two-tiered approach: a “Starting Point” for compliance, and then the NEX Level enhancements to build real resilience and business advantage. 

A Starting Point: The Minimum to Meet Compliance

These are practical actions you can implement relatively quickly to satisfy the assessment objectives for IA and lay the foundation for good identity hygiene… 

1. Inventory all user accounts, devices, and processes that access systems storing or processing CUI (or classified as in-scope) 
2. Implement MFA for all remote access into CUI-systems, for privileged accounts, and at minimum for administrative logins. 
3. Disable or remove accounts immediately when employees leave or change roles – set up a documented off-boarding checklist. 
4. Establish a written identification & authentication policy which defines how identities are issued, how they’re authenticated, how device access is managed, how access is revoked, how shared accounts are handled.
5. Log authentication events (success/failures) and review them periodically for anomalies. 
6. Ensure only corporate/trusted devices access sensitive systems… for example a device enrollment program or at least device registration. 
7. Set session rules such as time-outs, account lockouts after a certain number of failed logins, remote login restrictions. 

By ticking off these seven steps, you can demonstrate to an assessor (or yourself) that your IA controls are actively managed and aligned with the IA family requirements under CMMC 2.0. 

The NEX Level: Turning Compliance into Competitive Advantage

Once you’ve covered the basics, here are advanced practices you can turn into competitive advantage… not just compliance. 

• Deploy an Identity Governance & Administration (IGA) solution – supports role-based access, automated provisioning/de-provisioning, periodic access certifications and attestations. This elevates IA into access governance. 
• Enforce device posture and zero trust approaches. Validate device integrity (e.g., endpoint agent, OS version, patch status) before allowing access. Combine with conditional access policies (location, time of day, anomalous behavior). 
• Implement Regular Access Reviews & Anomaly Detection. Use analytics to monitor login patterns (unusual login times/locations/devices) and respond automatically. 
• Adopt Just-In-Time (JIT) or Privileged Access Management (PAM) for highly sensitive accounts – limit elevated privileges to only when needed, with revocation automatically when no longer required. 
• Use Adaptive/Multi-Factor Authentication Beyond Password+SMS. Consider hardware tokens, biometrics, device certificates – deploy advanced authentication methods especially for CUI-access. 
• Integrate Identity Logging with SIEM (Security Information & Event Management). Real-time monitoring of authentication events drives proactive detection of identity threats. 
• Continuous Identity Threat Modeling & Red-Team Exercises. Take identity seriously – simulate attacks (phishing, credential stuffing, device spoofing) against your environment and refine controls. 
• Align identity efforts with business workflows. For example… subcontractor/vendor access, joint development environments with primes/partners – build processes that make identity and authentication seamless for business operations. 

These enhancements raise your maturity level, make your identity posture resilient, and allow you to operate confidently – even when the threat landscape gets aggressive. 

The Identity vs Gate analogy 

Think of your business like a gated community of critical infrastructure: The gates are your access doors; the security desk checks everyone who enters. The “Identification & Authentication” control family is that security desk. It isn’t enough to have a gate (password), you need the guard to ask “Who are you?” (identification), check your badge (credentials), verify you’re on the guest list (authorization), make sure your vehicle is registered (device identity), and log your entry and exit (audit). 

If the guard skips any of those steps, someone could sneak in, steal something, and leave without being noticed. That’s what weak IA looks like in the cyber world. 

Takeaway: If you don’t know who’s knocking at your gate and how they got the badge, you don’t have security – you have guesswork.

Helpful Resources

Here are some resources to help you dig deeper and operationalize the IA control family…

Framework & Standards

• DoD CMMC Resources – Official documentation from the DoD covering CMMC Model v2.0.
• NIST SP 800-171 Rev. 2 – Full text from NIST, the source standard that CMMC maps to.
• NIST SP 800-53A — Guide to Computer Security Log Management – Practical guidance for collecting, analyzing, and protecting audit logs.

Free Resources

• CISA MFA Guidance – Clear, government-level guidance on why MFA matters, how it reduces risk, and practical recommendations for implementation.
• Microsoft Learn – Entra Conditional Access & MFA – Step-by-step Microsoft guidance on conditional access policies and requiring MFA… extremely relevant if you use Azure AD/Office365.
• Okta – Practical vendor guide for small IT teams – helps you choose acceptable MFA options without over-engineering

Paid Resources

• SailPoint – Focus on access governance, entitlement reviews, and provisioning automation… useful for deeper IA/IGA maturity. *SailPoint is widely used by larger DIB contractors
• CYYNC – A centralized system to plan and track evidence collection, conduct and document self-assessments, manage POA&M items through remediation, and maintain a continuous audit trail.
• CyberArk – Industry leader for controlling privileged accounts, session isolation, and audit of admin actions—common expectation for sensitive environments.
• Elastik (ELK) – Cost-effective logging + detection platform many SMBs use to centralize authentication logs and detection.

CyberNEX Resources

• CMMC Decoded: Identification & Authentication Reference Sheet – A concise one-page guide for defense contractors that outlines the CA control family, explains why it matters, highlights examples of evidence auditors might expect, provides quick-win actions to get started, and includes links to available resources.
• CyberNEX Blog Archive – Explore all 14 CMMC control families with in-depth explainers, practical recommendations, and actionable insights tailored to defense contractors.

Take the NEXt Step

Compliance is never the finish line—it’s the foundation. The real advantage comes when your business uses CMMC practices to strengthen operations, protect revenue, and earn the trust of your partners and the DoD. Whether you’re trying to pass an assessment or build a truly resilient cybersecurity program, CyberNEX helps you move from “checking the box” to owning your security posture.

Our team has guided dozens of SMBs through CMMC readiness, helping them translate complex requirements into simple, actionable steps. We know where most businesses struggle, and we know how to make progress visible – fast.

👉 Get clarity on your IA gaps and a clear plan forward. Book a Discovery Session with our experts today.

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FAQs

1. What exactly does the IA control family require under CMMC 2.0 Level 2? 
It requires you to ensure that any entity (user, device, process) interacting with your systems that store or process CUI is identified and authenticated prior to access. This includes managing device identity, user credentials, authenticating users (preferably with MFA), and revoking access when no longer needed. It’s mapped to the IA domain in the 14 control families.

2. Does this mean I have to replace my current login system or buy a big identity platform?
Not necessarily. You need to ensure you meet the control objectives (identify, authenticate, restrict access). If your existing system supports MFA, device registration, access revocation, logging, and you have documented policies and procedures, you may already be compliant. The key is that you can prove it to an assessor. Enhancements (IGA, PAM, zero-trust) are nice to have – but they are “NEX Level” not strictly required for minimal compliance. 

3. If I’m a small subcontractor and only handle a small amount of CUI, do I still need to follow all the IA controls?
Yes – if your contract brings you under CMMC 2.0 Level 2 requirements (i.e., you handle CUI). The 110 controls including IA apply to Level 2. If you only handle FCI (Federal Contract Information) then you may be under Level 1, which is simpler – but you’ll still see IA requirements there at the simpler level (e.g., identify users, authenticate before access).

4. How often do I need to review or re-verify user identities/devices under IA?
Best practice: you should perform periodic reviews to ensure users still require access (access recertification), verify devices remain trusted (device posture), and disable inactive accounts. For assessment purposes you must show evidence of your process, and audit logs should reflect ongoing monitoring. While CMMC doesn’t prescribe a fixed frequency for every review, a common standard is quarterly or semi-annual for user-access reviews, and device posture should be continuously monitored via endpoint tools. 

5. If I implement “just enough” IA for compliance, am I safe? 
“Just enough” may get you over the next audit milestone, but it won’t necessarily build resilience or protect you from evolving threats. Attackers increasingly target identity and device credentials and exploit weak access controls – so adopting the NEX Level practices gives you a real business advantage: stronger security, fewer incidents, lower insurance costs, and differentiator status with customers.