Part of a Series
Securing Physical Access in CMMC: Mastering the Physical Protection Domain
Key Takeaways
The Physical Protection domain ensures only authorized individuals can access sensitive systems and data by implementing physical security controls like locks, badges, and visitor escorts.
This domain contains six practices, starting with basic access limits at Level 1 and expanding to monitoring, logging, and securing alternate sites at Level 2.
Effective compliance requires documented policies, access logs, regular audits, and physical inspections, often supported by specialized compliance tools for streamlined management.
Introduction
Physical security remains a critical yet sometimes overlooked pillar in cybersecurity compliance frameworks such as the Cybersecurity Maturity Model Certification (CMMC).
The Physical Protection domain, Domain 11 of 14 in CMMC, zeroes in on safeguarding physical access to systems and data crucial to national defense and government contracts.
In this blog post, we will explore why controlling physical access is fundamental to securing Federal Contract Information (FCI) and Controlled Unclassified Information (CUI), outline the specific requirements and controls in this domain, and provide practical guidance for achieving and maintaining compliance.
Understanding the Physical Protection Domain in CMMC
What Does the Physical Protection Domain Cover?
At its core, the Physical Protection (PE) domain mandates that physical access to systems, including hardware, devices, and facilities where FCI or CUI is stored or processed, must be tightly controlled. This domain draws guidance from 32 CFR Part 170 and key publications from the National Institute of Standards and Technology (NIST), notably NIST SP 800-171.
Prevent unauthorized individuals from entering sensitive premises.
Protect critical hardware from tampering or theft.
Ensure visitors or temporary personnel cannot access sensitive areas unsupervised.
Why Physical Protection Matters in Cybersecurity Compliance
One cannot overstate the importance of physical controls. As a trusted expert once noted,
“Even the most sophisticated cybersecurity systems can be undermined by a simple breach of physical security.”
Without controlled physical access, attackers could install rogue devices, copy sensitive data directly, or sabotage systems, rendering sophisticated cyber defenses moot.
Who Must Comply?
The Physical Protection domain applies primarily to organizations aiming to meet Level 1 and Level 2 CMMC certification. Level 1 introduces basic access restriction; Level 2 builds on this with enhanced monitoring, auditing, and protection measures aligned with stricter NIST SP 800-171 standards.
Breakdown of Physical Protection Controls
How Many Controls Are There?
| Level | Number of Practices | Focus |
|---|---|---|
| 1 | 1 | Limit physical access |
| 2 | 5 (in addition to L1) | Enhanced monitoring, visitor escort, audit logging, device access control, alternative site security |
Summary of Physical Protection Practices
| Practice Code | Title | Level | Description |
|---|---|---|---|
| PE.L1-3.10.1 | Limit Physical Access | 1 | Ensure only authorized personnel can physically access systems |
| PE.L2-3.10.2 | Protect and Monitor Access | 2 | Use locks, security systems, or guards to prevent unauthorized access |
| PE.L2-3.10.3 | Escort Visitors and Monitor | 2 | Visitors are escorted and their activities documented |
| PE.L2-3.10.4 | Maintain Audit Logs | 2 | Keep regular, reviewable records of physical access |
| PE.L2-3.10.5 | Control Access to Devices | 2 | Limit physical access to hardware and devices |
| PE.L2-3.10.6 | Secure Alternate Work Sites | 2 | Extend physical protections to off-site locations housing CUI |
What Compliance Looks Like
Evidence Gathered for Assessment
Access control logs, digital badge swipes or written sign-in sheets.
Security camera footage confirming the absence of unauthorized intrusions.
Policies and procedures outlining how visitors are managed and escorted.
Configuration records of physical security setups such as locks and server cabinets.
Regularly maintained and reviewed audit logs.
Common Pitfalls to Avoid
Misunderstanding is a frequent barrier. Organizations often confuse logical access controls (like passwords) with the necessary physical controls (such as locked doors). Another common mistake is neglecting visitor logging or assuming remote workspaces do not require physical security measures.
Practical Steps for Smooth Compliance
Conduct detailed walkthroughs to identify all physical access points requiring control.
Train security and front desk personnel thoroughly on visitor management.
Extend physical protections to home offices or other alternative workspaces handling CUI.
Tools and Resources to Support Physical Protection Compliance
Leveraging templates and management platforms can simplify compliance. Useful resources include:
Department of Defense’s CMMC assessment guides for policy reference.
Standardized visitor log templates, either as Excel spreadsheets or digital solutions.
Scoping tools based on facility floor plans for mapping protected zones.
Sample visitor escort and physical security policy templates inspired by NIST SP 800-171A.
Frequently Asked Questions
Does Physical Protection Apply to Remote Workers?
Yes, if remote employees work with CUI, their home office must have physical controls such as locks or restricted access areas.
Is Badge Reader Data Valid Compliance Evidence?
Absolutely. Badge logs that record who accessed what and when provide strong verification for physical access practice compliance.
How Long Should Visitor Logs Be Retained?
While CMMC does not specify, best practices recommend retention for six to twelve months, adjusted to contract or organizational policy.
Conclusion
Physical Protection is a fundamental domain in the CMMC framework, addressing critical vulnerabilities that purely digital controls cannot cover. Properly limiting and monitoring physical access to sensitive information systems safeguards the integrity of cybersecurity defenses as a whole.
By reviewing the Physical Protection practices, mapping existing controls, and utilizing dedicated tools to manage evidence and policies, organizations stand well-prepared to meet CMMC requirements efficiently.
Ready to simplify your compliance process? Explore how our CMMC compliance dashboard can help you manage physical protection controls and more — streamlining preparation for your certification journey.
“Organizations must limit physical access to information systems, equipment, and their respective operating environments to authorized individuals.” — NIST SP 800-171 Rev 2, Requirement 3.10.1
For a comprehensive overview, see our CMMC Domains Overview to understand where Physical Protection fits within the full compliance landscape.