Temporary Passwords
Allow temporary password use for system logons with an immediate change to a permanent password.
What gets scored, the objectives
IA.L2-3.5.9 is met only when every one of these 1 objectives, from NIST SP 800-171A, is satisfied. A single missed objective makes the whole requirement not met.
- a.an immediate change to a permanent password is required when a temporary password is used for system logon
How this is assessed
NIST SP 800-171A defines three assessment methods. For IA.L2-3.5.9, whoever assesses it, including your own team in a self assessment, uses these:
Identification and authentication policy; password policy; procedures addressing authenticator management; system security plan; system configuration settings and associated documentation; system design documentation; password configurations and associated documentation; other relevant documents or records
Personnel with authenticator management responsibilities; personnel with information security responsibilities; system or network administrators; system developers
Mechanisms supporting or implementing password-based authenticator management capability
What it means, in context
Changing temporary passwords to permanent passwords immediately after system logon ensures that the necessary strength of the authentication mechanism is implemented at the earliest opportunity, reducing the susceptibility to authenticator compromises.
Users must change their temporary passwords the first time they log in. Temporary passwords often follow a consistent style within an organization and can be more easily guessed than passwords created by the unique user. This approach to temporary passwords should be avoided. Example One of your duties as a systems administrator is to create accounts for new users. You configure all systems with user accounts to require users to change a temporary password upon initial login to a permanent password [a]. When a user logs on for the first tim e, they are prompted to create a unique password that meets all of the defined complexity rules.
What passing evidence looks like
The first logon flow: temporary passwords force an immediate change to a permanent one, shown from the setting or a walkthrough of the new user process.
Common ways contractors fail IA.L2-3.5.9
- !The objective is that temporary passwords cannot become permanent. The user must change at first sign in checkbox is the whole control, show it checked in your onboarding runbook.
The step by step walkthrough for Microsoft 365 GCC High, Google Workspace, and on premises setups, plus the exact evidence to capture, lives inside the CMMC Level 2 plan.
Prove IA.L2-3.5.9, and the other 109
The Level 2 workspace walks your team through all 110 requirements at the objective level, drafts your SSP section by section from your own record for your team to read and accept, gives a prime or your own internal auditor a read only seat on the same record, and a credentialed officer reviews every step.
Book a free advisory callNo credit card, and Level 1 and Level 2 are both open, so sign up for the level your contracts call for. Self assessed and self attested: you score yourself in SPRS on a three year cycle and your senior official affirms it every year. As of September 3, 2026 a class deviation directs contracting officers to remove third party assessment from contracts. The program rule still provides for it, so your solicitation sets the track. Your team builds the same evidence either way. DFARS 252.204-7012 is unaffected, and the NIST SP 800-171 Rev 2 baseline is unchanged.
IA.L2-3.5.9 questions, answered
How many points is CMMC requirement IA.L2-3.5.9 worth?+
IA.L2-3.5.9 is worth 1 point in the CMMC Level 2 score under 32 CFR 170.24. If it is not met, you lose 1 from your total of 110.
Can IA.L2-3.5.9 be placed on a POA&M?+
Yes. A gap on IA.L2-3.5.9 can be deferred to a Plan of Action and Milestones, provided your overall score is 88 or better and the item closes within 180 days.
What family does IA.L2-3.5.9 belong to?+
IA.L2-3.5.9 is in the Identification & Authentication (IA) family, one of the 14 families of NIST SP 800-171 that make up CMMC Level 2.
- NIST SP 800-171 Rev. 2 3.5.9