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CMMC · Rev 2.13L3CA · Security Assessment

CA.L3-3.12.1e

Penetration Testing

Requirement

Conduct penetration testing at least annually or when significant security changes are made to the system, leveraging automated scanning tools and ad hoc tests using subject matter experts.

Assessment objectives

An assessor checks each lettered objective separately. The letters in brackets elsewhere on this page, such as [a] or [b,c], refer to these.

Determine if:

  1. aAutomated scanning tools are identified;
  2. bAd hoc tests using subject matter experts are identified; and
  3. cPenetration testing is conducted at least annually or when significant security changes are made to the system, leveraging automated scanning tools and ad hoc tests using subject matter experts.

From the CMMC Level 3 Assessment Guide v2.13 · publisher approved 2026-11-08.

How to implement

Have your CUI environment penetration tested at least once a year and after significant security changes, using both automated scanning tools and hands-on tests by skilled people. Level 2 vulnerability scanning is not enough on its own; Level 3 expects people trying to break in the way an attacker would, then remediating what they find. For almost every contractor this means hiring a qualified outside firm, which is a recurring cost; there is no free option that satisfies it on its own.

  1. 1
    PolicySet the penetration testing policy: at least annually and after significant security changes (new network segment, major cloud migration, new internet-facing service, replacement of a core security tool), with defined scope, rules of engagement, tester qualifications and independence, and how findings are remediated.[c]
  2. 2
    ProcessScope each test to the CUI environment and its supporting systems: external perimeter and internet-facing services, internal network from an assumed-breach position, identity and cloud tenant (Microsoft 365 GCC High or equivalent), wireless, custom web applications, and social engineering if the threat profile warrants it. Base scenarios on the threat-informed risk assessment.[c]
  3. 3
    ProcessEngage qualified testers (an outside firm, or an internal team independent of the system administrators) who combine automated scanning tools with manual, ad hoc testing by subject matter experts. Sign rules of engagement and an authorization letter, and handle the report as sensitive.[a][b][c]
  4. 4
    ProcessRemediate findings by risk, track them in the plan of action (CA.L2-3.12.2), and retest critical and high findings to confirm closure.[c]
  5. 5
    ProcessMaintain the change triggers: when a significant security change is approved through change management, decide and record whether an additional test is required.[c]

Evidence to collect

Artifacts that show the practice is implemented and operating. Tags show which assessment objectives each one supports.

Penetration testing policy[c]

policy · reviewed annually

Policy stating frequency, change triggers, scope, tester requirements and remediation process.

Rules of engagement and authorization[c]

record · for each test in the assessment period

Signed rules of engagement, scope and authorization letter for each test.

Penetration test report[a][b][c]

record · within the last 12 months, and after each significant change

Tester's report describing methodology (automated and manual), scope, findings, evidence and risk ratings.

Remediation and retest evidence[c]

record · current

Plan of action entries for findings and retest letters or reports confirming closure.

Change-triggered test decisions[c]

record · most recent 12 months

Change records noting whether a significant change required a penetration test and the outcome.

How assessors check

Examine
Penetration testing policy, test plans and rules of engagement, test reports, change records, remediation and retest records, tester qualifications.
Interview
The person who manages the testing engagement, the testers if available, and system administrators who remediated findings.
Test
Confirm a test occurred within 12 months and after the most recent significant change; check the report shows both automated tools and manual testing; trace high findings to remediation and retest.

Tools and products

Named options a contractor can adopt, with an honest cost tier. The industry standard is listed even when it is expensive, alongside what is free and acceptable for a very small shop.

Qualified third-party penetration testing firmProfessional servicePaidGood fit for a small shop

The normal way to meet this practice. Price depends on scope; get quotes and look for testers with recognised qualifications (for example OSCP, GPEN, or CREST-accredited firms).

Horizon3.ai NodeZero or PenteraAutomated penetration testingEnterprise pricingWorkable for a small shop

Autonomous internal pentest platforms that can run more often than annual manual tests; they cover the automated part, but the practice still calls for ad hoc testing by experts.

Burp Suite ProfessionalWeb application testingPaidWorkable for a small shop

Industry-standard tool for manual web application testing, relevant if you have custom web apps and in-house testing skills.

Kali Linux and Metasploit FrameworkOpen-source testing toolsFreeWorkable for a small shop

Free tools used by professional testers; useful for an independent internal team, but free tools do not replace qualified people.

CISA Risk and Vulnerability Assessment (RVA)Government assessment serviceFreeWorkable for a small shop

Free penetration testing service for eligible critical infrastructure organizations, but capacity is limited and waits can be long; do not rely on it alone to meet an annual deadline.

Editorial mentions, not endorsements. Pricing and tiers change; confirm with the vendor and check FedRAMP or GCC High availability where CUI is involved.

Common pitfalls

  • Presenting an automated vulnerability scan as a penetration test.
  • Testing only the external IP addresses and not the internal network or cloud tenant.
  • Findings from last year's test still open with no plan of action entry.
  • No retest after a major change such as moving to GCC High or replacing the firewall.
  • Testers given no authorization letter, creating legal and operational risk.

Platform notes

Microsoft 365 (GCC / GCC High)

Microsoft's cloud penetration testing rules of engagement allow customers to test their own tenant without prior approval, within those rules; include identity attacks (password spraying limits, Conditional Access bypass attempts, OAuth consent abuse) in scope.

Google Workspace

Google permits customers to test their own configuration within its acceptable use policy; focus on account takeover, sharing settings and third-party app access.

On-premises or MSP-managed

Tell the MSP and MSSP before the test so alerts are handled correctly, and include MSP remote access paths in scope; the MSP should not be the tester for systems it administers.

Related practices: CA.L2-3.12.1, RA.L2-3.11.2, RA.L3-3.11.5e, CA.L2-3.12.2, CM.L2-3.4.4

Editorial implementation guidance published November 8, 2026. It is not part of the official requirement and does not replace the assessment guide.

The NIST requirements this practice is built on, what NIST made of each in the newer edition, and the SP 800-53 controls behind them, each from an official NIST or DoD table. Open any one to read it and see every CMMC practice it supports.

NIST SP 800-172 (Feb 2021)

3.12.1e

SP 800-172 Rev 3

03.12.01E

—

SP 800-53 Rev 5

CA-8CSSR-6(1)C
How these were reached
  • CA-8 · Penetration Testing
    • S source control of the SP 800-171 Rev 3 or SP 800-172 Rev 3 requirement (NIST OSCAL) · via 800-172 Rev 3 03.12.01E → 800-53 Rev 5 CA-8
    • C SP 800-172 (Feb 2021) Appendix C
  • SR-6(1) · Supplier Assessments and Reviews | Testing and Analysis
    • C SP 800-172 (Feb 2021) Appendix C

Rev 5 paths: D SP 800-171 Rev 2 Appendix D → SP 800-53 Rev 4 control → NIST's Rev 4 → Rev 5 comparison; S source control of the SP 800-171 Rev 3 or SP 800-172 Rev 3 requirement (NIST OSCAL); C SP 800-172 (Feb 2021) Appendix C. NIST also names this Rev 3 requirement as the successor of other withdrawn requirements: open “How these were reached” under the Rev 5 controls for which, in NIST's words.

Where each link comes from (5 links from 4 official documents)

32 CFR 170.14 Office of the Federal Register / GPO

NIST SP 800-172 → Rev 3 change analysis NIST

  • 3.12.1e → 03.12.01E“Minor Change; New or Changed ODP”sheet "Change Analysis SP 800-172-R3" row 69

NIST SP 800-172 Rev 3 (OSCAL) NIST

  • 03.12.01E → CA-8“Source control”control 03.12.01E link rel=external_reference (CA-08)

NIST SP 800-172 (Feb 2021) NIST

Trace notes

Notes marked NIST state what the owners' own files say. Notes marked Expert CMMC note are our reading of the links, not official guidance. Neither is a crosswalk link.

About this practice

Further discussion

It is important that the organization has a repeatable penetration testing capability, regardless of who performs the penetration testing. This requirement entails performing tests against components of the organization’s architecture to identify cyber weaknesses and vulnerabilities. It does not mean everything in the architecture requires penetration testing. This requirement provides findings and mitigation strategies that benefit the organization and help create a stronger environment against adversary efforts. It may be beneficial for the organization to define the scope of penetration testing. The organization’s approach may involve hiring an expert penetration testing team to perform testing on behalf of the organization. When an organization has penetration testing performed, either by an internal team or external firm, they should establish rules of engagement and impose limits on what can be performed by the penetration test team(s). Ensuring the objectivity of the test team is important as well. Potential conflicts of interest, such as having internal testers report directly or indirectly to network defenders or an external test team contracted by network defense leadership, must be carefully managed by organizational leadership. Reports on the findings should be used by the organization to determine where to focus funding, staffing, training, or technical improvements for future mitigation strategies. Example You are responsible for information security in your organization. Leveraging a contract managed by the CIO, you hire an external expert penetration team annually to test the security of the organization’s enclave that stores and processes CUI [a,c]. You hire the same firm annually or on an ad hoc basis when significant changes are made to the architecture or components that affect security [b,c]. Potential Assessment Considerations • Does the organization have internal team members who possess the proper level of expertise to perform a valued penetration testing effort [b]? • If the penetration testing is performed by an internal team, are the individuals performing the testing objectively [b]? • Is a penetration testing final report provided to the internal team responsible for organizational defense? • If previous penetration tests have been conducted, can the organization provide samples of penetration test plans, findings reports, and mitigation guidance based on the findings [a,b,c]?

Practice guide notes

Implementation guidance

Editorial examples to help you plan. Adapt them to your environment; the official requirement and objectives remain authoritative.

In plain language

Have penetration tests done at least yearly and after significant security changes, using automated scanning plus manual testing by experts.

Implementation example

Example from the source assessment guide (not a mandatory implementation): You are responsible for information security in your organization. Leveraging a contract managed by the CIO, you hire an external expert penetration team annually to test the security of the organization’s enclave that stores and processes CUI [a,c]. You hire the same firm annually or on an ad hoc basis when significant changes are made to the architecture or components that affect security [b,c].

Evidence examples

Examples suggested by the source guide (not an exhaustive or mandatory checklist): Security assessment policy; procedures addressing penetration testing; security plan; security assessment plan; penetration test report; security assessment report; security assessment evidence; other relevant documents or records

Common mistakes

Treating an automated vulnerability scan as a penetration test.

Track this in a workspace

The compliance workspace tracks each objective, its evidence and the tasks to close gaps. It is open to invited contractors while in pilot: request access below.

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Source: DoD CIO · https://dodcio.defense.gov/CMMC/