Introduction
As cybersecurity threats continue to evolve, organizations working with the U.S. Department of Defense (DoD) must ensure they have strong security practices in place. The Cybersecurity Maturity Model Certification (CMMC) 2.0 framework establishes strict security requirements for defense contractors handling Controlled Unclassified Information (CUI). A key component of CMMC 2.0 compliance is configuration management controls, which help protect systems from unauthorized changes, vulnerabilities, and misconfigurations.
Configuration management ensures that an organization’s IT systems, software, and security settings remain in a known, secure state at all times. This includes monitoring and enforcing security settings, restricting access to system changes, and eliminating unnecessary system functionalities that could introduce security risks.
This article provides an in-depth overview of configuration management controls for CMMC 2.0 compliance, breaking down each control, explaining how to implement them, and offering best practices to help organizations achieve compliance.
Configuration Management in CMMC 2.0
Definition of Configuration Management
Configuration management (CM) is the process of establishing, maintaining, and monitoring secure system configurations throughout an organization's IT infrastructure. It ensures that systems are properly configured to reduce vulnerabilities, prevent unauthorized changes, and comply with cybersecurity regulations like CMMC 2.0.
Why is Configuration Management Important for CMMC 2.0 Compliance?
In cybersecurity, misconfigurations are among the most common causes of data breaches. Without strong configuration management controls, organizations risk unauthorized changes that weaken security settings, increased attack surfaces due to unnecessary system functions, security vulnerabilities caused by outdated software or misconfigurations, and inconsistent security enforcement across different systems.
To mitigate these risks, CMMC 2.0 Level 2 introduces nine configuration management controls that companies must implement. These controls are aligned with NIST SP 800-171, a framework outlining best practices for protecting Controlled Unclassified Information (CUI).
The Role of NIST SP 800-171 in Configuration Management
CMMC 2.0 Level 2 is based on NIST SP 800-171, which outlines cybersecurity requirements for organizations handling CUI. The configuration management family in NIST SP 800-171 includes controls that define baseline system configurations, enforce secure security settings, ensure proper change management, restrict unauthorized system modifications, and limit nonessential functionalities.
By implementing these controls, organizations strengthen their security posture and reduce the risk of cyberattacks targeting their IT infrastructure.
Who Needs to Comply with CMMC 2.0 Configuration Management Controls?
Organizations that process, store, or transmit Controlled Unclassified Information (CUI) must comply with CMMC 2.0 Level 2. This includes prime contractors working directly with the DoD, subcontractors handling CUI within the defense supply chain, small and medium-sized enterprises supporting DoD contracts, and manufacturers, IT service providers, and consulting firms dealing with defense data.
Failure to comply with CMMC 2.0 configuration management requirements can result in loss of DoD contracts, fines, or reputational damage. To avoid these risks, refer to our CMMC Compliance Checklist.
Key Configuration Management Controls for CMMC 2.0 Compliance
CMMC 2.0 Level 2 requires organizations to implement nine specific configuration management controls that maintain a secure IT environment by ensuring only authorized changes occur, unnecessary functionalities are removed, and security configurations are consistently enforced.
System Baselining (CM.L2-3.4.1)
System baselining establishes and maintains secure configurations for all systems within an organization, serving as a reference point for approved operating system settings, software versions, and security configurations.
To implement effective system baselining, identify all systems processing or storing controlled unclassified information, develop standardized security configurations, use configuration management tools to enforce settings, and regularly review baseline configurations. Consider utilizing automated tools like Microsoft Group Policy or Ansible, maintain version-controlled repositories of baselines, and conduct periodic compliance audits.
Security Configuration Enforcement (CM.L2-3.4.2)
This control ensures systems adhere to defined security baselines through monitoring, detecting, and remediating configuration deviations.
Implementation requires deploying security configuration management tools for continuous compliance checking, establishing alerts for unauthorized changes, and using automated scripts to revert systems to approved settings. Best practices include using tools like Microsoft Defender for Endpoint, requiring multi-factor authentication for administrators, and preventing users from altering security settings without approval. For additional insights on authentication, read Identification and Authentication for CMMC 2.0.
System Change Management (CM.L2-3.4.3)
System change management provides a structured approach for handling IT system modifications to prevent introducing security vulnerabilities.
Establish a formal process for requesting, reviewing, and approving system changes, maintain a centralized change log, require security impact assessments, and conduct post-change reviews. Consider implementing ticketing systems like Jira or ServiceNow, enforcing separation of duties, and scheduling regular change control board meetings.
Security Impact Analysis (CM.L2-3.4.4)
This control involves assessing potential security risks before making changes to systems, applications, or configurations.
Define a process for conducting security assessments on proposed changes, identify dependencies, use security testing tools, and require security approval before implementing modifications. Best practices include performing penetration testing before major changes, maintaining detailed records of analyses, and utilizing sandbox environments for testing.
Access Restrictions for Change (CM.L2-3.4.5)
Limiting access to configuration settings reduces the risk of unauthorized modifications.
Implement role-based access control to restrict who can make system changes, require administrator privileges for modifying configurations, and use privileged access management tools. Consider implementing just-in-time access controls, regularly reviewing access logs, and requiring multi-person approval for critical modifications.
Least Functionality (CM.L2-3.4.6)
This principle requires systems to operate with only essential software, services, and features necessary for their purpose.
Conduct an inventory of installed applications, disable non-essential software and services, and use group policies to enforce restrictions. Periodically review configurations to remove unnecessary features, use endpoint protection tools to prevent unauthorized installations, and disable unused network ports to reduce attack surface.
Nonessential Functionality (CM.L2-3.4.7)
Organizations must restrict unnecessary system capabilities, including scripts, drivers, and services.
Define policies specifying permitted functionalities, implement application whitelisting, and regularly audit system settings. Use tools like Microsoft AppLocker, disable default administrative shares when unnecessary, and monitor system logs for unauthorized use of nonessential functions.
Application Execution Policy (CM.L2-3.4.8)
This policy defines which software is allowed to run on organizational systems.
Establish a list of approved applications, use application control tools to enforce restrictions, and require administrative approval for new software. Implement an allowlist approach rather than blocklisting, regularly review authorized software, and use endpoint security solutions to block unauthorized applications.
User-Installed Software (CM.L2-3.4.9)
Organizations must restrict users from installing unauthorized software to prevent security risks.
Disable users' ability to install software without authorization, monitor system logs for unauthorized installations, and provide a formal request process for new applications. Use mobile device management solutions to enforce restrictions, educate employees about risks, and require security reviews before approving new software.
How to Implement Configuration Management Controls for CMMC 2.0 Compliance
Achieving compliance with CMMC 2.0 configuration management controls requires a structured approach. Organizations must establish policies, enforce security settings, monitor system changes, and conduct regular audits to ensure compliance. For expert assistance in navigating this process, explore our CMMC Consulting services to streamline your compliance journey.
Below is a step-by-step guide to implementing configuration management controls effectively.
Step-by-Step Guide to Building a CMMC-Compliant Configuration Management Program
1. Conduct a Baseline Security Assessment
Begin by identifying all systems, applications, and network devices that handle controlled unclassified information (CUI). Document current system configurations and security settings, then compare existing configurations with CMMC 2.0 requirements to identify compliance gaps.
2. Develop and Document Secure System Baselines
Establish security baselines for all operating systems, applications, and network devices in your environment. Define approved security settings, access controls, and software configurations. Use configuration management databases (CMDB) to store and track these baselines effectively.
3. Enforce Security Configurations
Implement automated tools to ensure compliance with baseline configurations across your organization. Use group policies and security templates to enforce security settings consistently. Continuously monitor systems for deviations from approved configurations to maintain security posture.
4. Implement a Formal Change Management Process
Require thorough documentation and approval for all system changes before implementation. Conduct security impact assessments prior to implementing modifications to understand potential risks. Maintain a detailed audit log of all approved and rejected changes for accountability.
5. Restrict Unauthorized Changes and Access
Implement role-based access control (RBAC) to limit who can modify system settings based on job responsibilities. Require administrative approval for critical system changes that could impact security. Use privileged access management (PAM) tools to monitor and control administrative actions.
6. Regularly Audit System Configurations
Conduct periodic security audits to ensure ongoing compliance with CMMC 2.0 requirements. Use configuration scanning tools to detect unauthorized or dangerous changes to systems. Address any identified security gaps through prompt remediation efforts.
7. Monitor and Remove Nonessential Functionality
Perform regular reviews of installed software and system services to identify unnecessary components. Disable or remove applications, features, and network ports that are not required for business operations. Implement application whitelisting to control what software can run on systems.
8. Enforce a Secure Application Execution Policy
Define and enforce a list of approved applications that may run on organizational systems. Restrict users from installing unauthorized software that could introduce security risks. Use endpoint protection tools to monitor application activity and block unapproved software.
9. Educate Employees on Configuration Management Policies
Provide comprehensive training on security best practices and compliance requirements for all staff. Clearly communicate policies for system changes, application installations, and configuration updates. Ensure employees understand the importance of maintaining secure system configurations and their role in compliance.
Best Tools for Configuration Management Compliance
Implementing and maintaining configuration management controls for CMMC 2.0 compliance can be challenging without the right tools. Below are some of the most effective solutions:
These tools help automate configuration management, enforce security policies, and maintain compliance with CMMC 2.0.
Common Challenges in Configuration Management for CMMC 2.0 Compliance
Implementing configuration management controls for CMMC 2.0 compliance comes with several challenges. Organizations often struggle with maintaining secure configurations, enforcing change management processes, and ensuring compliance without disrupting business operations. Below are some of the most common challenges and strategies to overcome them.
FAQs About Configuration Management Controls for CMMC 2.0
Many organizations seeking CMMC 2.0 compliance have questions about how to effectively implement configuration management controls. Below are some of the most commonly asked questions, along with clear and actionable answers.
What Happens if a Company Doesn't Comply with CMMC 2.0 Configuration Management Controls?
Companies that fail to comply risk losing eligibility for DoD contracts, increased vulnerability to data breaches, potential legal and financial penalties, and significant reputational damage among partners and clients in the defense industry. To mitigate these risks, explore our CMMC Consulting services or read How a Consultant Can Guide Your CMMC Compliance Journey.
How Often Should System Baselines Be Updated?
System baselines should be reviewed quarterly, updated after major software or hardware changes, verified during annual compliance audits, and immediately updated when critical vulnerabilities are discovered.
What Are the Best Tools for Enforcing Security Configurations?
Several tools help organizations enforce security configurations and maintain compliance with CMMC 2.0. The following table provides an overview of recommended tools:
Using a combination of these tools helps organizations maintain strong security controls while ensuring compliance with CMMC 2.0.
How Can Small Businesses Implement These Controls Without High Costs?
Small businesses can leverage open-source security tools like OpenSCAP and OSSEC, use built-in security features in operating systems, implement role-based access control, conduct periodic manual audits instead of automated scanning, and explore government resources like the CMMC Small Business Readiness Pilot for guidance and assistance.
Can Automation Help with CMMC 2.0 Compliance?
Yes, automation is essential for CMMC 2.0 compliance. It reduces human error and ensures consistency through automated patch management, configuration enforcement tools like Ansible or Chef, continuous monitoring with SIEM systems, access control enforcement, and incident response automation. Organizations that invest in automation improve security while making compliance more manageable.
Conclusion & Next Steps
CMMC 2.0 configuration management controls are essential for securing Controlled Unclassified Information (CUI) and maintaining DoD contract eligibility. To get started, assess your systems, implement the nine controls, and document your progress.
Need help? Encompass Consultants offers expert CMMC Consulting to guide you through compliance with ease. Book a free call with us today at Book-a-Call to secure your systems and contracts now.
Disclaimer: The information and recommendations provided in this article are for general informational purposes only. They are not intended as legal, compliance, or professional advice. Organizations should consult with their own legal, cybersecurity, and compliance professionals before implementing any strategies or recommendations discussed herein.
