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The Framework4 min read

CMMC Level 1: Foundational

17 basic safeguarding practices covering Federal Contract Information. Annual self-assessment with senior official affirmation, no third-party C3PAO required.

CMMC Level 1 is the entry-level certification, covering only Federal Contract Information (FCI) — information not intended for public release that is provided or generated in the performance of a federal contract. Level 1 does not cover CUI. If your DoD contract involves CUI, you need Level 2.

17 Level 1 practices

The 17 Level 1 practices are drawn directly from FAR 52.204-21 (Basic Safeguarding of Covered Contractor Information Systems). They cover fundamental cyber hygiene practices:

  • Limit system access to authorized users and the types of transactions they can perform
  • Identify information system users and authenticate their identity before granting access
  • Sanitize or destroy media containing FCI before disposal or reuse
  • Limit physical access to organizational systems to authorized individuals
  • Escort visitors and monitor visitor activity
  • Maintain audit logs of system activity
  • Identify, report, and correct information and information system flaws in a timely manner
  • Scan for malicious code and update detection mechanisms
  • Update malicious code protection mechanisms when new releases are available
  • Perform periodic scans of information systems and real-time scans of files from external sources

Assessment and affirmation

Level 1 requires an annual self-assessment — no C3PAO or third-party assessor is needed. The organization self-scores against the 17 practices, posts the score to the Supplier Performance Risk System (SPRS), and a senior official must affirm the accuracy of the score. False affirmations can result in False Claims Act liability.

Who this affects most

Contractors who only hold contracts involving FCI with no CUI — such as some IT support contracts, facilities services, and general logistics — will typically only need Level 1. If you are unsure whether your contracts involve CUI, check your contract for DFARS 252.204-7012 or ask your contracting officer.

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