CMMC and NIST Password Compliance 101: Are They Different?

Everything You Need to Know About CMMC Password Compliance and How Enzoic Helps

When working with the Department of Defense (DoD), securing user accounts is a strict requirement. The Cybersecurity Maturity Model Certification (CMMC) framework was created to ensure organizations handling Controlled Unclassified Information (CUI) maintain rigorous security standards. CMMC is essentially a unified cybersecurity standard across the Defense Industrial Base, and it was originally built on the requirements of NIST SP 800‑171. In other words, many CMMC practices correspond directly to existing NIST controls and guidance. Below, we’ll cover the basics of CMMC, who needs to comply, what happens if you don’t, how compliance is enforced, and how Enzoic helps address critical CMMC password requirements (drawing on NIST standards).

What Is CMMC?

The Cybersecurity Maturity Model Certification (CMMC) is a DoD program that sets a unified standard for implementing cybersecurity practices across contractors and subcontractors. Its goal is to protect sensitive defense information as it flows through the supply chain. CMMC 2.0 defines three levels of certification, each with progressively stricter cybersecurity practices. An organization must demonstrate compliance with the required practices for the level of CMMC that a given DoD contract demands. Because CMMC 2.0’s controls are largely derived from NIST SP 800-171, achieving CMMC compliance means you’re also meeting key NIST-based security requirements.

Who Needs to Achieve CMMC and NIST Password Compliance?

Any organization that works with the DoD may need to achieve CMMC password compliance (and overall CMMC compliance). This includes:

• Defense Contractors and Subcontractors: If you do business with the DoD as a prime contractor, subcontractor, or supplier in the DoD supply chain, CMMC applies to you.
• Organizations Handling CUI: If you handle Controlled Unclassified Information (CUI) for the DoD, you must meet CMMC requirements.
• Organizations Handling FCI: Even companies that deal only with Federal Contract Information (FCI) (non-public information provided by or generated for the government) may need to comply with at least the basic CMMC level.

This applies regardless of company size. Even small businesses or sub-tier suppliers must adhere to CMMC if they handle FCI or CUI. Ultimately, compliance is mandatory if you want to start – or continue – doing business with the DoD under contracts that include these data types.

Consequences of Failing CMMC Password Compliance

Failing to meet CMMC password compliance (or any CMMC requirement) can have serious repercussions:

• Losing DoD Contracts: Failure to meet CMMC requirements can result in losing your current DoD contracts or being deemed ineligible to bid on new ones. Compliance isn’t just a checkbox; it’s often a condition of doing business.
• Audits and Investigations: If it’s discovered that an organization misrepresented its compliance level, the DoD can initiate external audits or formal investigations. This scrutiny can be both time-consuming and damaging.
• Financial Penalties and Legal Action: In severe cases, organizations might face fines for violating contract terms or even lawsuits. For example, knowingly misreporting CMMC compliance could trigger False Claims Act violations with significant penalties.
• Reputational Damage: Beyond immediate financial and legal impacts, non-compliance can tarnish your reputation. Being publicly removed from DoD opportunities or flagged for poor security can make it harder to secure future business, even outside of government work.

How Is CMMC Password Compliance Enforced?

CMMC compliance is enforced through a combination of certification requirements and oversight mechanisms:

1. Mandatory Certification: When bidding on a DoD contract, you must prove your CMMC certification level. The required level is specified by the DoD based on the sensitivity of information you’ll handle. No certification means no contract.
2. Third-Party Assessments: For CMMC Level 2 (and above), organizations undergo assessments by Certified Third-Party Assessment Organizations. These independent assessors verify that you have all the required cybersecurity practices and processes in place.
3. DoD Oversight: The DoD reserves the right to review assessments, investigate complaints, and audit organizations if discrepancies or security incidents arise. In practice, this means even after certification, you must continuously enforce the controls (including password policies) to remain in compliance.

Spotlight on a Key CMMC Password Compliance Requirement: IA.L2‑3.5.9

Within CMMC’s Identification and Authentication (IA) domain lies one of the most critical controls to combat data breaches. In CMMC 2.0 Level 2, control IA.L2‑3.5.9 focuses on enforcing strong password policies. CMMC documentation describes this requirement as follows:

CMMC IA.L2‑3.5.9: “Enforce password parameters to include preventing the use of dictionary words, repetitive or sequential characters, and prohibit the use of compromised passwords.”

In plain language, this means your organization must have password policies in place that do the following:

1. Block Weak or Common Passwords: Prevent users from choosing simple, easily guessable passwords (e.g., dictionary words or obvious sequences like “abcdef” or “12345”).
2. **Block Known Compromised Passwords: Ensure that passwords known to have been exposed in data breaches (which attackers often try in credential stuffing attacks) cannot be used.
3. Enforce Ongoing Compliance: Continuously monitor and scan for weak or compromised passwords in use, and enforce prompt remediation (for example, flagging or resetting passwords that become compromised).

This practice closely aligns with updated NIST guidance on password security. NIST’s latest standards (such as NIST SP 800-63B) specifically advise organizations to screen new passwords against a “blocklist” of unacceptable passwords, including those that are commonly used or have been compromised. In fact, NIST recommends that whenever a user creates or changes a password, the system should check it against a list of passwords known to be weak, predictable, or compromised. Both CMMC and NIST are effectively requiring the same thing: don’t let users choose passwords that attackers are likely to guess or that have already been exposed.

To illustrate how CMMC is built on NIST standards, the table below compares a few key password requirements from CMMC 2.0 (Level 2) with their counterparts in NIST guidelines:

As shown above, CMMC explicitly requires both traditional password hygiene (complexity rules and preventing reuse of recent passwords) and modern best practices like blocking compromised or common passwords. These requirements are grounded in NIST standards. For example, NIST SP 800-171 Rev. 3 includes nearly identical provisions for maintaining a list of common or compromised passwords and verifying new passwords are not on that list. Likewise, NIST’s guidelines acknowledge that overly complex composition rules have limited benefit, focusing instead on minimum length and screening against known bad passwords. The bottom line: CMMC’s password compliance measures are built on the foundation of NIST’s research and recommendations.

How Enzoic Helps Achieve CMMC and NIST Password Compliance (IA.L2‑3.5.9)

Enzoic provides solutions that specifically focus on password security—helping organizations meet CMMC requirements like IA.L2‑3.5.9 by keeping compromised or weak credentials out of your environment. Here’s how Enzoic can help your security team satisfy these controls in a practical way:

1. Real-Time Breach Data Checks: Enzoic continuously aggregates data from thousands of known data breaches. Whenever a user creates or updates a password, Enzoic automatically checks if that password (or a variation of it) has appeared in any known breach. If the password is found to be compromised, the user is immediately prompted to choose a more secure one. This real-time check stops users from unknowingly using breached passwords.
2. Dictionary & Common Password Detection: Beyond breach data, Enzoic’s service flags passwords that are commonly used, too simple, or based on dictionary words – even if they haven’t shown up in a breach yet. This ensures you’re not just meeting basic complexity rules, but also proactively blocking the predictable, easy passwords that hackers might guess (e.g. “Password123” or slight variations like “P@ssword123”).
3. Integration with Active Directory: For organizations using Microsoft Active Directory, Enzoic for Active Directory integrates seamlessly with your on-premises environment. It monitors password changes in real time and enforces your password policy (including the “no compromised passwords” rule) without adding any burden on your IT staff or requiring users to follow extra steps. The integration makes implementation straightforward, so you can get these controls in place quickly.
4. Flexible API for Other Systems: If you have custom applications or non-Windows systems, Enzoic offers APIs that make it easy to extend the same password security checks to any platform. This programmatic approach means you can enforce CMMC-aligned password policies consistently across your entire IT ecosystem – not just Active Directory.
5. Automated Policy Enforcement and Reporting: Once Enzoic is installed or integrated, it runs continuously in the background, scanning new or updated passwords against the latest compromised password data. This automation not only increases security, but also makes it easier to demonstrate compliance during audits. Auditors can readily verify that you have a systematic, continuous control in place to prevent the use of compromised passwords (which fulfills CMMC IA.L2‑3.5.9). Enzoic’s logging and reports can serve as evidence that you are enforcing the required password controls on an ongoing basis.

Why This Matters for CMMC and NIST Password Compliance

Passwords remain a primary attack vector for adversaries. In fact, most data breaches start with compromised credentials. The DoD understands this risk – hence the explicit requirement to “prohibit the use of compromised passwords.” By using Enzoic, organizations can automatically maintain compliance with IA.L2‑3.5.9. Enzoic ensures every password is thoroughly vetted against up-to-date breach data and other security checks, so weak or known-compromised passwords are caught before they cause a problem.

Implementing these measures has several benefits:

• Reduced Risk of Breach: Eliminating known compromised passwords and obvious weak passwords drastically cuts the likelihood of an account being easily hacked. This reduces your organization’s overall risk of a data breach or account takeover.
• Fewer Audit Headaches: Automated controls (with documented results) make it simple to show auditors that you are continuously enforcing strong password policies. Instead of scrambling to gather evidence, you’ll have reports at the ready to prove compliance.
• Future-Proof Security: As new data breaches occur and attackers evolve their tactics, Enzoic’s threat intelligence is continually updated. Your password defenses automatically adapt to the latest threat data without additional effort on your part. This helps you stay one step ahead of attackers and maintain compliance.

Final Thoughts

Complying with CMMC is non-negotiable if you plan to work with the DoD or handle CUI. While the consequences of non-compliance can be severe (lost contracts, audits, fines, and lawsuits), meeting these requirements doesn’t need to be daunting. By leveraging tools like Enzoic for Active Directory or Enzoic’s APIs to detect compromised passwords in real time, you can significantly strengthen your security posture and satisfy one of the most critical CMMC controls (IA.L2‑3.5.9) without heavy overhead. In short, smart technology can make CMMC password compliance both achievable and sustainable.

Ready to improve your password security and simplify CMMC compliance? Contact Enzoic today to learn how our solutions can help you meet – and even exceed – your CMMC requirements. Strengthening your password defenses now will not only help you pass audits, but also protect your organization from the real-world threats behind those compliance rules.