3.5.7
IA.L2-3.5.7 · Level 2
Enforce a minimum password complexity and change of characters when new passwords are created.
NIST SP 800-171 Rev 2 · §3.5.7
Enforce a minimum password complexity and change of characters when new passwords are created.
Assessment objectives
From NIST SP 800-171A · 4 objectives must be met to satisfy this control
Examine
[SELECT FROM: Identification and authentication policy; password policy; procedures addressing authenticator management; security plan; system design documentation; system configuration settings and associated documentation; password configurations and associated documentation; other relevant documents or records].
Interview
[SELECT FROM: Personnel with authenticator management responsibilities; personnel with information security responsibilities; system or network administrators; system developers].
Test
[SELECT FROM: Mechanisms supporting or implementing password-based authenticator management capability].
Examine
[SELECT FROM: Identification and authentication policy; password policy; procedures addressing authenticator management; security plan; system design documentation; system configuration settings and associated documentation; password configurations and associated documentation; other relevant documents or records].
Interview
[SELECT FROM: Personnel with authenticator management responsibilities; personnel with information security responsibilities; system or network administrators; system developers].
Test
[SELECT FROM: Mechanisms supporting or implementing password-based authenticator management capability].
Examine
[SELECT FROM: Identification and authentication policy; password policy; procedures addressing authenticator management; security plan; system design documentation; system configuration settings and associated documentation; password configurations and associated documentation; other relevant documents or records].
Interview
[SELECT FROM: Personnel with authenticator management responsibilities; personnel with information security responsibilities; system or network administrators; system developers].
Test
[SELECT FROM: Mechanisms supporting or implementing password-based authenticator management capability].
Examine
[SELECT FROM: Identification and authentication policy; password policy; procedures addressing authenticator management; security plan; system design documentation; system configuration settings and associated documentation; password configurations and associated documentation; other relevant documents or records].
Interview
[SELECT FROM: Personnel with authenticator management responsibilities; personnel with information security responsibilities; system or network administrators; system developers].
Test
[SELECT FROM: Mechanisms supporting or implementing password-based authenticator management capability].
What we look for in practice
The following are placeholder notes that should be refined based on practice experience.
What assessors look for in practice. Documented evidence that this control is implemented across all CUI-handling systems within scope. Specific artifacts vary, but expect requests for written procedures, system configurations, and operational records demonstrating the control is active.
Common failure patterns. Typical issues include incomplete documentation, inconsistent implementation across systems, and missing periodic review records. Refine this section as your practice accumulates direct assessment experience.
Strong evidence looks like. Formal policy referencing this control, technical configurations demonstrating enforcement, periodic review logs with sign-off, and procedures for handling exceptions.
Scoring and POA&M context. 1-point control under the DoD Assessment Methodology. Lower scoring impact, but still required for full compliance. POA&M-eligible — deferral up to 180 days is allowed under conditional certification per 32 CFR 170.21.