SC.L2-3.13.10 · NIST SP 800-171 3.13.10

Key Management

Establish and manage cryptographic keys for cryptography employed in organizational systems.

1 point if not metPOA&M eligible2 assessment objectives

What an assessor scores, the objectives

SC.L2-3.13.10 is met only when every one of these 2 objectives, from NIST SP 800-171A, is satisfied. A single missed objective makes the whole requirement not met.

  • a.cryptographic keys are established whenever cryptography is employed
  • b.cryptographic keys are managed whenever cryptography is employed

How a C3PAO checks it

NIST SP 800-171A defines three assessment methods. For SC.L2-3.13.10, an assessor uses these:

Examine

System and communications protection policy; procedures addressing cryptographic key establishment and management; system security plan; system design documentation; cryptographic mechanisms; system configuration settings and associated documentation; system audit logs and records; other relevant documents or records

Interview

System or network administrators; personnel with information security responsibilities; personnel with responsibilities for cryptographic key establishment and management

Test

Mechanisms supporting or implementing cryptographic key establishment and management

What it means, in context

Cryptographic key management and establishment can be performed using manual procedures or mechanisms supported by manual procedures . Organizations define key management requirements in accordance with applicable federal laws, Executive Orders, policies, directives, regulations, and standards specifying appropriate options, levels, and parameters. NIST SP 800-56A and NIST SP 800-57-1 provide guidance on cryptographic key management and key establishment.

Develop processes and technical mechanisms to protect the cryptographic keys ’ confidentiality, authenticity, and authorized use in accordance with industry standards and regulations. Key management system s provide oversight, assurance, and the capability to demonstrate the cryptographic keys are created in a secure manner and protected from loss or misuse throughout their life cycle (e.g., active, expired, revoked ). For a small number of keys, this can be accomplished with manual procedures and mechanisms. As the number of keys and cryptographic units increase, automation and tool support will be required. The first intent of this requirement is to ensure cryptographic keys are properly created in a secure manner that prevents them from being reproduced by an advers ary. The second intent of this requirement is to ensure cryptographic keys are managed in a secure manner that prevents them from being stolen by an adversary. Key establishment involves the creation of keys and coordination among parties that will use the keys of the methodology for generating the final keying material . This is discussed in detail in SP 800-56A, B, and C. Key management involves protecting keys when they are distributed, when they are stored, when they are being used, and when they are being recovered. Key establishment best practices are identified in NIST SP 800 -56A, B, and C. Key management best practices are identified in NIST SP 800-57 Parts 1, 2, and 3. This requirement, SC.L2 -3.13.10, complements AC.L2 -3.1.19 by specifying that any cryptographic keys in use must be protected. Example 1 You are a system administrator responsible for providing key management. You have generated a public -private key pair to exchange CUI [a]. You require all system administrators to read the key management policy before you allow them to install the private key on their machines [b]. No one else is allowed to know or have a copy of the private key per the policy. You provide the public key to the other parties who will be sending you CUI and test the Public Key Infrastructure (PKI) to ensure the encryption is working [a]. You set a revocation period of one year on all your certificates per organizational policy [b]. Example 2 You encrypt all of your company’s computers using the disk encryption utility built into the operating system. As you configure encryption on each device, it generates a cryptographic key. You associate each key with the correct computer in your inventory spreadsheet and restrict access to the spreadsheet to the system administ rators whose work role requires them to manage the computers [b]. Potential Assessment Considerations • Are cryptographic keys established whenever cryptography is employed (e.g., digital signatures, authentication, authorization, transport, or other cryptographic mechanisms) [a]? • Are cryptographic keys maintained whenever cryptography is employed (e.g., key storage, backup, recovery, revocation, destruction, etc.) [b]?

What passing evidence looks like

Where cryptographic keys live and how they are managed: BitLocker recovery keys escrowed, certificates tracked with expiries, Wi-Fi secrets rotated, in one key management note.

Common ways contractors fail SC.L2-3.13.10

  • !Small shop key management is a half page: BitLocker keys escrow to Entra, the wildcard certificate renews via the host, the Wi-Fi key rotates on departure. Write that page; unmanaged keys nobody can produce is the finding.

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Prove SC.L2-3.13.10, and the other 109

The Level 2 Accelerator walks all 110 requirements with you, generates your SSP, POA&M, and Audit Room from real evidence, includes the full Level 1 platform, and puts a credentialed officer alongside you for 180 days. Filed in 180 days, or we work free until you are.

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SC.L2-3.13.10 questions, answered

How many points is CMMC requirement SC.L2-3.13.10 worth?+

SC.L2-3.13.10 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 SC.L2-3.13.10 be placed on a POA&M?+

Yes. A gap on SC.L2-3.13.10 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 SC.L2-3.13.10 belong to?+

SC.L2-3.13.10 is in the System & Communications Protection (SC) family, one of the 14 families of NIST SP 800-171 that make up CMMC Level 2.

Key references
  • NIST SP 800-171 Rev. 2 3.13.10