CMMC Policy Documentation: The 14 Policies Every Contractor Needs

Policies Are the Foundation of CMMC Compliance

Before a C3PAO assessor looks at a single screenshot or configuration, they review your policies and procedures. Policies demonstrate that your organization has a formal, documented approach to cybersecurity — not just ad-hoc practices.

NIST SP 800-171A assessment objectives frequently begin with "Determine if the organization defines..." — this means documented policies.

The 14 Required Policy Areas

Each NIST SP 800-171 control family should have a corresponding policy. Here's what each must cover:

1. Access Control Policy (AC)

Must address:

• User access provisioning and deprovisioning procedures
• Least privilege and need-to-know principles
• Remote access authorization and monitoring
• Wireless access restrictions
• Mobile device access controls
• Session lock and termination settings

2. Awareness & Training Policy (AT)

Must address:

• Security awareness training requirements and frequency
• Role-based training for privileged users
• CUI handling training
• Insider threat awareness program
• New hire training timeline
• Training record retention

3. Audit & Accountability Policy (AU)

Must address:

• Auditable events definition (login, logout, file access, privilege changes)
• Log retention periods (minimum 90 days)
• Log protection and integrity measures
• Log review frequency and responsibilities
• Incident correlation procedures
• Time synchronization requirements

4. Configuration Management Policy (CM)

Must address:

• Baseline configuration standards
• Change management process
• Security impact analysis for changes
• Software whitelist/blacklist approach
• Configuration monitoring
• Unauthorized change response

5. Identification & Authentication Policy (IA)

Must address:

• User identification requirements
• Multifactor authentication policy
• Password complexity and lifecycle requirements
• Account lockout thresholds
• Service account management
• Authenticator management (tokens, certificates)

6. Incident Response Policy (IR)

Must address:

• IR team composition and roles
• Incident categories and severity levels
• Detection and reporting procedures
• Containment and eradication steps
• Recovery procedures
• Lessons learned process
• Annual testing requirements

7. Maintenance Policy (MA)

Must address:

• Scheduled maintenance procedures
• Remote maintenance authorization and monitoring
• Maintenance personnel authorization
• Maintenance tool controls
• Equipment sanitization before external maintenance

8. Media Protection Policy (MP)

Must address:

• Media marking requirements (CUI designation)
• Media storage protections
• Media transport controls
• Media sanitization and destruction per NIST 800-88
• Removable media restrictions

9. Personnel Security Policy (PS)

Must address:

• Background screening requirements
• CUI access authorization process
• Personnel termination procedures (access revocation timeline)
• Personnel transfer procedures
• Visitor management

10. Physical Protection Policy (PE)

Must address:

• Physical access authorization
• Visitor escort and monitoring
• Physical access logs
• Alternative work site security
• Equipment and media disposal

11. Risk Assessment Policy (RA)

Must address:

• Risk assessment methodology and frequency
• Vulnerability scanning requirements and frequency
• Risk response strategies
• Risk acceptance criteria and authority

12. Security Assessment Policy (CA)

Must address:

• Control assessment methodology and frequency
• Plan of action and milestones (POA&M) management
• Continuous monitoring strategy
• System authorization boundaries

13. System & Communications Protection Policy (SC)

Must address:

• Network boundary protection
• CUI transmission encryption requirements
• CUI storage encryption requirements
• Network segmentation approach
• Collaborative computing restrictions
• Public-facing system restrictions

14. System & Information Integrity Policy (SI)

Must address:

• Flaw remediation and patching timeline
• Malicious code protection requirements
• Security alert monitoring
• System monitoring approach
• Spam protection

What Every Policy Must Include

Regardless of the control family, every policy document should contain:

1. Purpose statement: Why this policy exists
2. Scope: Who and what it applies to
3. Roles and responsibilities: Who enforces and who follows
4. Policy statements: The actual requirements
5. Procedures: How to implement the policy
6. Exceptions process: How to request and document exceptions
7. Violations and enforcement: Consequences of non-compliance
8. Review cycle: Annual review date and process
9. Version history: Track changes over time
10. Approval signatures: Management endorsement

Policy Maintenance

Policies aren't "set and forget." Assessors check:

• Review dates: Has the policy been reviewed in the last 12 months?
• Version history: Has it been updated to reflect changes?
• Acknowledgments: Have all relevant personnel signed?
• Consistency: Does the policy match actual practice?

Common Policy Mistakes

1. Copy-paste without customization: Assessors spot generic policies immediately
2. Overly complex language: Policies should be readable by all staff
3. Disconnected from practice: Your policy says one thing, but your systems do another
4. Missing acknowledgments: No proof that staff have read and accepted the policy
5. Stale documents: Last reviewed 3 years ago — assessors will flag this

Using Policy Templates

Starting from templates is smart — but customize them:

• Replace generic placeholders with your organization's specifics
• Align technology references to your actual tools
• Ensure role names match your org chart
• Set realistic review cycles you'll actually follow

CMMC Command includes 20 policy templates mapped to NIST control families, with AI-assisted drafting for Professional tier users and team acknowledgment tracking.

Generate your first policy — 5 policy templates included free with Starter plan.