Doors, locks, cameras—those might sound like basics, but they’re a key part of passing CMMC Level 1 validation. Physical security controls don’t just sit in the background; they’re a hands-on part of how organizations protect Federal Contract Information. C3PAOs are trained to look closely, ask specific questions, and document the physical protections in place to ensure they match what the CMMC compliance requirements expect.
Audit of Entry-Point Authentication Mechanisms
Access starts at the door, and that’s where C3PAOs begin. They look at how people physically get into buildings or restricted areas. Do they need a badge? Is there a keypad, a biometric scanner, or maybe just a good old-fashioned lock and key? The validation process checks that whatever system is in place actually restricts access to only those who are authorized. It’s not enough to install the hardware—C3PAOs want to see that it works consistently, is monitored, and ties into access control policies documented under CMMC level 1 requirements.
Authentication methods should align with your internal controls and match employee roles. Temporary badges, deactivated access for former employees, and visitor procedures are all evaluated. If the C3PAO sees that former staff still have working key cards or that visitors are allowed in without being logged, that’s a problem. For those moving toward CMMC level 2 requirements, ensuring multi-factor physical access is also a smart step for future audits.
Verification of Secure Workstation Placement
Physical workstation placement might not seem like a security issue—until it is. If sensitive information is visible through a window or accessible by unauthorized foot traffic, it’s a vulnerability. C3PAOs walk through the facility and observe how workstations are arranged. They check for screen visibility, locked offices, and whether anyone could gain easy access to workstations containing Federal Contract Information.
Part of meeting CMMC compliance requirements includes limiting access based on physical layout. Workstations used for FCI should be placed in secured or controlled environments—not in common areas where anyone can drop by. Inspectors might also ask about screen locks, idle timeouts, or cable locks on laptops, especially in smaller setups. Even in Level 1, these physical controls matter.
Assessing Compliance via Secure Facility Diagrams
Facility diagrams help C3PAOs map how security controls are implemented across physical spaces. These aren’t just fire escape maps—they need to outline controlled zones, entry points, storage locations for FCI, and access restrictions. C3PAOs review these layouts to confirm that what’s on paper matches reality. If a diagram shows a badge-restricted server room, they’ll check that it actually exists and is protected as claimed.
These diagrams give assessors a reference point for verifying how physical spaces are used and secured. For businesses working with a CMMC RPO, it’s smart to review and update diagrams before a formal C3PAO assessment. Facilities grow, layouts change, and security diagrams need to reflect that to avoid confusion during validation.
Evaluating Inventory Logs for Removable Media Management
USB drives, external hard drives, even burned discs—all of these fall under removable media. If they carry Federal Contract Information, C3PAOs will check how they’re managed. CMMC level 1 requirements don’t call for encryption or detailed tracking of digital movement, but they do require awareness and control of physical items.
Inventory logs should note what devices exist, who uses them, and where they’re stored. If there’s no inventory process, it can raise concerns about the organization’s ability to track or control FCI. A solid removable media policy that’s enforced and documented is a key sign of security maturity, even at a basic level.
Confirming Adequate Surveillance Equipment Coverage
If surveillance systems are installed, C3PAOs will examine how well they cover sensitive areas—especially entrances, exits, and storage rooms. They don’t just want to see cameras on the wall; they want to know they work, the footage is recorded, and there are processes for reviewing that footage if something goes wrong.
Auditors may ask who has access to the recordings, how long they’re kept, and whether employees are trained on camera placement protocols. While not required under CMMC Level 1, properly documented surveillance systems can boost confidence in your compliance posture and show readiness for CMMC level 2 compliance later on.
Reviewing Physical Security Incident Response Procedures
What happens if a lock is broken, a door is left open, or someone enters without authorization? C3PAOs want to see that there’s a response plan in place. These procedures should outline who investigates incidents, how they’re documented, and how future risks are reduced. It’s not about perfection—it’s about showing that you know what to do and that you actually follow your own rules.
Incident response policies should be realistic, regularly reviewed, and taught to staff. A solid plan shows maturity and awareness—two major factors that weigh heavily in any CMMC assessment. CMMC RPOs often recommend incident drills or tabletop exercises to prepare clients for this validation step.
Inspection of Disposal Processes for Sensitive Physical Records
Paper records containing FCI must be disposed of securely. C3PAOs check whether shredding, locked bins, or third-party disposal services are in place. Leaving printed documents in open bins, recycle piles, or personal drawers without control opens the door to unauthorized access.
The audit looks for consistency. If the disposal policy says records are shredded weekly, assessors may ask to see the schedule, bins, or shredding logs. For small businesses, even a basic locked console and regular checks go a long way toward showing physical control. These details make a strong impression in CMMC level 1 requirements—and build habits that support future CMMC level 2 compliance.