CMMC 2.0 Compliant CRM Checklist: 15 Controls You Must Verify

Before your C3PAO assessment, you need to verify your CRM meets CMMC 2.0 requirements. This isn't about whether your vendor has certifications—it's about whether your specific implementation satisfies the controls.

This checklist accompanies our comprehensive CUI-Safe CRM guide. Use it as a practical verification tool during your compliance review.

Access Control Verification (AC)

These controls ensure only authorized users can access CUI in your CRM.

1. AC.L2-3.1.1 - Authorized Access: Can you restrict CRM access to only users who need it for their job function? Verify role-based access controls are configured and enforced.
2. AC.L2-3.1.2 - Transaction Control: Can you limit what actions users can perform on CUI records? Verify you can restrict view/edit/delete/export permissions per record type.
3. AC.L2-3.1.3 - CUI Flow Control: Can you control how CUI moves through the system? Verify email sync rules, export restrictions, and integration permissions.
4. AC.L2-3.1.5 - Least Privilege: Are users granted minimum necessary access? Verify no blanket 'admin' or 'full access' roles for general users.

Audit & Accountability (AU)

These controls ensure you can demonstrate who did what with CUI.

1. AU.L2-3.3.1 - System Auditing: Does your CRM log all access to CUI-containing records? Verify logs capture user, timestamp, action, and record ID.
2. AU.L2-3.3.2 - User Accountability: Can you trace every CUI access to a specific user? Verify no shared accounts or generic logins are used.
3. AU.L2-3.3.4 - Audit Failure Alerting: Are you alerted if audit logging fails? Verify monitoring is configured for log system health.

Media Protection (MP)

These controls protect CUI when it's stored or exported from your CRM.