Pitfall #2 – Access Control & Identity Gaps

Access Control (AC) and Identification & Authentication (IA) represent a significant portion of the 110 practices in the Cybersecurity Maturity Model Certification (CMMC) framework. Yet this is precisely where many organizations discover they are less prepared than they assumed.

Common Stumbling Points

Through our work with companies preparing for CMMC assessment, we consistently see the same gaps:

• No quarterly access reviews — Permissions accumulate over time without systematic cleanup
• Weak privileged account monitoring — Admin accounts operate without adequate oversight or logging
• Multi-Factor Authentication (MFA) deployed inconsistently — Some systems protected, others exposed
• No documented least-privilege model — Access decisions are ad hoc rather than principle-driven

What Assessors Actually Ask

Assessors do not simply ask, “Is Multi-Factor Authentication (MFA) installed?”

They ask: “Show me the evidence and governance.”

This distinction matters. Having the tool is not the same as having a controlled, documented, and consistently applied process.

A Simple Maturity Model

One way we evaluate access governance with clients is through a straightforward maturity model:

🟢 Green – Mature

• Access policies documented and approved
• Quarterly access reviews performed with records
• Multi-Factor Authentication (MFA) consistently enforced across all systems
• Privileged accounts actively monitored
• Role-based access control (RBAC) clearly defined

🟡 Yellow – Inconsistent

• Tools deployed but governance remains informal
• Access reviews happen occasionally, not systematically
• MFA applied to some systems but not others
• Privileged accounts tracked poorly or not at all

🔴 Red – Exposed

• No access governance framework exists
• Shared admin credentials in common use
• MFA missing or optional
• No monitoring of privileged activity

The Strategic Reality

Access governance is not merely an IT problem—it is an organizational discipline. Without executive sponsorship and clear operational ownership, access controls degrade over time, regardless of what tools you have purchased.

This explains why many organizations appear compliant during initial tool deployment yet fall short during formal CMMC assessments. The tools were there, but the governance was not.

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If your organization is preparing for CMMC assessment and needs to strengthen access control governance, contact N2CON to discuss how we can help you close the gap before an assessor shows up.

For a deeper dive on CMMC requirements, see our CMMC Guide.

For practical guidance on MFA implementation, see our MFA Guide.

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Next: Logging & Incident Response — the silent assessment killer.