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CIS Controls: How to Implement v8.1 to Set CMMC Level 2 Foundation [+ Checklist]

  • April 08, 2026
Author

Anna Fitzgerald

Senior Content Marketing Manager

Reviewer

Marc Rubbinaccio

Head of Cybersecurity & Compliance

Organizations today face a variety of threats, which can make cybersecurity seem daunting. How can they protect against so many types of cyber attacks with limited resources?

The CIS Critical Security Controls® (CIS Controls®) are meant to help organizations address this specific challenge by offering a prioritized set of actions that organizations can take to help defend against common cyber attack vectors.

Let’s take a closer look at what these controls are, why your organization should implement them (especially if also pursuing CMMC), and how.

At a Glance:

  • What: 18 prioritized cybersecurity controls with 153 Safeguards
  • Who: Organizations of all sizes, from SMBs to enterprises
  • Why: Defense against ~86% of common cyber attacks and solid foundation for cybersecurity compliance program
  • How: Controls map to dozens of frameworks, including ATT&CK, CMMC, ISO 27001
  • Latest version: v8.1 (released June 2024)

What are the CIS Controls?

CIS Critical Security Controls are a set of best practices for cybersecurity developed by the Center for Internet Security (CIS). These controls aim to help organizations identify, manage, and mitigate the most prevalent cyber threats against systems and networks. They are designed  to be comprehensive enough to protect and defend cybersecurity programs for any size enterprise but also prescriptive enough to ease implementation. 

Each CIS Control is broken down into Safeguards, or measurable actions. Each Safeguard describes an action that organizations can take to help defend against common cyber attacks, including but not limited to:

  • Malware
  • Ransomware
  • Web application hacking
  • Insider privilege and misuse
  • Targeted intrusions

How effective are these controls at defending against the most prevalent types of attacks? CIS created the Community Defense Model 2.0 using the MITRE Adversarial Tactics, Techniques, and Common Knowledge (ATT&CK) framework and industry threat data to identify attack patterns and then map the Safeguards that defend against those techniques. According to their analysis, the CIS Controls are effective at defending against 86% of the ATT&CK (sub-)techniques found in the ATT&CK framework if all Safeguards are implemented. That number jumps to 91% if looking at the top five attack types above.

CIS Controls are continuously updated as part of CIS's ongoing commitment to ensuring that organizations remain resilient against rapidly changing cyber threats. Let’s take a look at the latest iteration below.

Recommended reading

Cybersecurity Explained: What It Is & 13 Reasons Cybersecurity is Important

CIS Controls v8.1

CIS Controls v8.1 represents the latest evolution in cybersecurity standards to improve an enterprise's cybersecurity posture. Released in June 2024, this latest iteration includes updates to align with evolving industry standards, like NIST CSF 2.0, and address the increasing complexities and vulnerabilities in today's cyber landscape.

CIS Controls v8.1 is an iterative update to version 8.0. Rather than a complete overhaul, it refines and enhances the controls to better address current cybersecurity challenges.

Below are the key aspects and improvements introduced in CIS Controls v8.1:

  • Updated alignment to NIST CSF 2.0: Since they were first released, the CIS Controls have continuously been updated to align with evolving industry standards and frameworks. The recent release of NIST CSF 2.0 helped orchestrate this latest version of the Controls, which includes updated mappings and safeguards that align with changes made in NIST CSF 2.0.
  • The addition of the “Governance” security function: In v8.1, Governance is added as a security function, bringing the total to six. (The other five are: Identify, Protect, Detect, Respond, Recover.) In this latest revision, governance topics are specifically identified as recommendations that can be implemented to enhance the governance of a cybersecurity program. This will help organizations better identify the governing pieces of the program in order to steer it towards achieving their enterprise goals and equip organizations with the evidence needed to demonstrate compliance. 
  • Revised asset classes and CIS Safeguard descriptions: Version 8.1 adds Documentation as an asset class, bringing the total to six. These six (Devices, Software, Data, User, Network, Documentation) better match the specific domains of an enterprise's environment that CIS Controls apply to. As a result of this addition and other minor revisions to the asset classes, some Safeguard descriptions were also updated for greater detail, practicality, and/or clarity.
  • Included new and expanded glossary definitions for certain terms used throughout the Controls: As a result of the new and revised asset classes and Safeguard descriptions, there are several new or updated glossary definitions for terms like API, data, documentation, Internet of Things (IoT), network, plan, and sensitive data. 

Recommended reading

NIST vs CIS: How to Decide Which Cybersecurity Framework Is Right for You

Why organizations implement CIS Controls

The CIS Controls aim to streamline the process of designing, implementing, measuring, and managing enterprise security. 

This is more important than ever in 2026, when organizations are expected to combat rising threats across cyber, physical, and information domains with fewer resources. This is especially true for public-sector organizations since federal support for U.S. State, Local, Tribal, and Territorial (SLTT) cybersecurity programs came to an end, according to CIS’s year in review blog.

Below are seven key reasons that organizations implement CIS Controls:  

1. To enhance their cybersecurity posture

CIS Controls provide a comprehensive framework for protecting against a wide range of cyber threats. By following these best practices, organizations can strengthen their defenses, reduce vulnerabilities, and enhance their overall security posture. The controls cover essential areas such as data protection, access control management, and incident response, ensuring a holistic but simplified approach to cybersecurity.

2. To tailor their approach to cybersecurity

CIS Controls are designed to be scalable and flexible, making them suitable for organizations of all sizes and industries. Version 8.1 contains 18 controls and 153 safeguards, which are categorized into three Implementation Groups (IGs). IGs are self-assessed categories based on the organization's risk profile and available resources. This categorization allows organizations to adopt a tailored approach, implementing controls that are appropriate for their specific needs and capabilities rather than requiring them to implement all 18 controls and 153 safeguards at once.

3. To allocate their resources efficiently

The CIS Controls are designed to prioritize the most critical security actions, making it easier for organizations to focus their efforts where they matter most. This prioritization helps in allocating resources efficiently, addressing the most significant risks first, and achieving meaningful security improvements without overwhelming the organization with too many simultaneous tasks.

4. To manage security cost-effectively

By addressing the most critical vulnerabilities and improving incident response capabilities, CIS Controls can help organizations minimize the likelihood and financial and operational impact of cyber attacks. Additionally, the prioritized nature of CIS Controls ensures that resources are used efficiently, providing maximum security benefits with optimal investment.

5. To demonstrate a reasonable level of security

In the United States, there is no national, statutory, cross-sector minimum standard for information security. Instead, multiple U.S. states require federal agencies and other government entities to implement a “reasonable” level of security. While there are multiple ways to do this, several of these state laws and regulations specifically mention the CIS Controls as a way of demonstrating a reasonable level of security. 

6. To continuously improve over time

CIS Controls emphasize continuous monitoring, measurement, and improvement of security practices. By regularly assessing the effectiveness of the controls you implement and updating them as needed, organizations can stay ahead of emerging threats and maintain a robust cybersecurity posture over time. This proactive approach helps in adapting to the evolving cyber threat landscape and ensures long-term resilience.

7. To simplify multi-framework compliance

Since the CIS Controls include foundational security measures that any organization can use to achieve essential cyber hygiene and protect themselves against a cyber attack, these controls

are mapped to and referenced by multiple legal, regulatory, and policy frameworks, including CMMC, PCI DSS, NIST CSF, NIST 800-171, NIST 800-53, HIPAA, GDPR, and ISO 27001. Implementing these controls can help organizations achieve compliance with these standards and regulations, reducing duplicate work.

Recommended reading

Understanding Security Frameworks: 15 Frameworks & The Sector, Data, or Threats They Align With

CIS Controls list

Below is a high-level overview of the 18 CIS Controls in version 8.1., with emphasis on where common practices like firewalls, MFA, user device protections, and CIS Benchmarks play a role:

Title Description
Inventory and Control of Enterprise Assets Actively manage all enterprise assets connected to the infrastructure physically, virtually, remotely, and those within cloud environments, to accurately know the totality of assets that need to be monitored and protected within the enterprise.
Inventory and Control of Software Assets Actively manage all software on the network so that only authorized software is installed and can execute, and that unauthorized and unmanaged software is found and prevented from installation or execution.
Data Protection Develop processes and technical controls to identify, classify, securely handle, retain, and dispose of data.
Secure Configuration of Enterprise Assets and Software Establish and maintain the secure configuration of enterprise assets and software.
Account Management Use processes and tools to assign and manage authorization to credentials for user accounts, including administrator accounts, as well as service accounts, to enterprise assets and software.
Access Control Management Use processes and tools to create, assign, manage, and revoke access credentials and privileges for user, administrator, and service accounts for enterprise assets and software.
Continuous Vulnerability Management Develop a plan to continuously assess and track vulnerabilities on all enterprise assets within the enterprise’s infrastructure, in order to remediate, and minimize, the window of opportunity for attackers. Monitor public and private industry sources for new threat and vulnerability information.
Audit Log Management Collect, alert, review, and retain audit logs of events that could help detect, understand, or recover from an attack.
Email and Web Browser Protections Improve protections and detections of threats from email and web vectors, as these are opportunities for attackers to manipulate human behavior through direct engagement.
Malware Defenses Prevent or control the installation, spread, and execution of malicious applications, code, or scripts on enterprise assets.
Data Recovery Establish and maintain data recovery practices sufficient to restore in-scope enterprise assets to a pre-incident and trusted state.
Network Infrastructure Management Establish, implement, and actively manage network devices, in order to prevent attackers from exploiting vulnerable network services and access points.
Network Monitoring and Defense Operate processes and tooling to establish and maintain comprehensive network monitoring and defense against security threats across the enterprise’s network infrastructure and user base.
Security Awareness and Skills Training Establish and maintain a security awareness program to influence behavior among the workforce to be security conscious and properly skilled to reduce cybersecurity risks to the enterprise.
Service Provider Management Develop a process to evaluate service providers who hold sensitive data, or are responsible for an enterprise’s critical IT platforms or processes, to ensure these providers are protecting those platforms and data appropriately.
Application Software Security Manage the security life cycle of in-house developed, hosted, or acquired software to prevent, detect, and remediate security weaknesses before they can impact the enterprise.
Incident Response Management Establish a program to develop and maintain an incident response plan (e.g., policies, procedures, defined roles, training, and communications) to prepare, detect, and quickly respond to an attack.
Penetration Testing Test the effectiveness and resiliency of enterprise assets through identifying and exploiting weaknesses in controls and simulating the objectives and actions of an attacker.

CIS Controls framework: A detailed look at the Controls and Safeguards

For a more detailed overview of the controls and the safeguards, asset types, and security functions within each control, download the v8.1 from the CIS website

Control 1: Inventory and Control of Enterprise Assets

You can't protect what you don't know exists. Unknown assets are common entry points for attackers. This control is all about knowing which assets need to be protected and actively managing them. 

Key Safeguards:

  • Maintain an accurate, up-to-date inventory of all devices
  • Use automated asset discovery tools
  • Document device ownership and business purpose
  • Remove unauthorized assets from the network

Control 2: Inventory and Control of Software Assets

Unauthorized software is a leading cause of data breaches and often introduces unpatched vulnerabilities.This control focuses on actively managing all software on the network so that only authorized software is installed and can execute.

Key Safeguards:

  • Maintain a whitelist of authorized software
  • Use application control technologies to prevent unauthorized software execution
  • Regularly scan for unauthorized software
  • Remove or quarantine unauthorized applications

Control 3: Data Protection

Not all data requires the same level of protection. It’s essential that organizations take inventory of their data, determine its sensitivity level, and set permissions, retention periods, disposal processes, and more based on risk. This control ensures you have processes and technical controls in place to identify, classify, securely handle, retain, and dispose of data.

Key Safeguards:

  • Establish and maintain a data management process
  • Classify data based on sensitivity
  • Implement data retention policies
  • Securely dispose of data when no longer needed
  • Encrypt sensitive data at rest and in transit

Control 4: Secure Configuration of Enterprise Assets and Software

Default configurations are optimized for usability, not security. Attackers exploit known default settings. Implementing this control requires you to establish and maintain secure configurations for all enterprise assets and software.

Key Safeguards:

  • Establish secure configuration standards
  • Use hardening guides (CIS Benchmarks, DISA STIGs)
  • Implement configuration management tools
  • Regularly review and update configurations

Control 5: Account Management

Credential abuse remains the most common vector of data breaches, accounting for 22%. Proper account management limits damage from compromised accounts. This control focuses on implementing processes and tools to ensure all accounts are authorized and active. 

Key Safeguards:

  • Establish and maintain an inventory of accounts
  • Use unique credentials for each user
  • Disable dormant accounts within 45 days
  • Restrict administrator privileges to dedicated accounts
  • Establish and maintain a service account management process

Control 6: Access Control Management

While account management focuses on controlling who the users are, access control focuses on controlling what they can do.

Excessive privileges provide attackers with lateral movement opportunities once they gain initial access. This control ensures there are processes and tools in place to create, assign, manage, and revoke access credentials and privileges.

Key Safeguards:

  • Implement least privilege access
  • Require multi-factor authentication (MFA)
  • Implement role-based access control (RBAC)
  • Centralize access control management
  • Regularly review and adjust access privileges

Control 7: Continuous Vulnerability Management

Data breaches involving the exploitation of vulnerabilities surged 34% in 2025, accounting for 1 in 5 breaches. Organizations that identify and patch faster than attackers exploit can significantly lower their breach rates. 

This control focuses on implementing a plan to continuously assess and track vulnerabilities on all enterprise assets in order to remediate proactively and minimize the window of opportunity for attackers to exploit. 

Key Safeguards:

  • Perform automated vulnerability scans
  • Remediate detected vulnerabilities based on risk
  • Establish a patching cadence
  • Monitor for zero-day exploits relevant to your environment

Control 8: Audit Log Management

Without logs, you're blind to attacks in progress and unable to investigate after the fact. This control ensures you collect, alert, review, and retain audit logs of events that could help you detect, understand, or recover from an attack in the future.

Key Safeguards:

  • Establish and maintain audit log management processes
  • Collect logs from all enterprise assets
  • Protect log data from unauthorized access
  • Retain logs for adequate time periods
  • Conduct log reviews

Control 9: Email and Web Browser Protections

Email remains a top attack vector, accounting for over 90% of successful cyber attacks according to CISA. To reduce this risk, this control consists of best practices to improve protections and detections of threats from email and web vectors.

Key Safeguards:

  • Implement email security solutions (anti-phishing, anti-malware)
  • Block known malicious domains
  • Use sandboxing for suspicious attachments
  • Implement browser security extensions
  • Disable unnecessary browser plugins

Control 10: Malware Defenses

Malware, including ransomware, remains one of the most common and costly attack types. For example, ransomware attacks accounted for an average $5.08 million in breach costs in 2025 compared to the global average breach cost of $4.44 million, according to IBM

Implementing this CIS control helps prevent or control the installation, spread, and execution of malicious applications, code, or scripts on enterprise assets.

Key Safeguards:

  • Deploy anti-malware software on all assets
  • Configure automatic signature updates
  • Enable anti-exploitation features
  • Centrally manage malware defenses
  • Block execution of unauthorized software

Control 11: Data Recovery

87% of organizations experienced SaaS data loss in the past 12 months, with malicious deletions as the leading cause. A significant portion (35%) require days or even weeks to recover this lost data, which can significantly impede business continuity and skyrocket costs.

This control is all about establishing and maintaining data recovery practices to more efficiently restore in-scope enterprise assets to a pre-incident and trusted state.

Key Safeguards:

  • Establish and maintain a data recovery process
  • Perform automated backups
  • Protect recovery data with equivalent controls to source data
  • Test data recovery processes regularly
  • Maintain offline, immutable backups

Control 12: Network Infrastructure Management

Network devices are high-value targets that, when compromised, provide attackers with visibility and access to entire network segments.

Establishing, implementing, and actively managing network devices is critical to prevent attackers from exploiting vulnerable network services and access points.

Key Safeguards:

  • Establish and maintain a secure network architecture
  • Securely manage network infrastructure
  • Document network segments
  • Disable unnecessary network services and protocols
  • Establish and maintain dedicated infrastructure for network management

Control 13: Network Monitoring and Defense

Once inside networks, attackers often remain undetected for six months (181 days) on average, according to IBM. This control focuses on implementing processes and tools to improve detection capabilities across your entire network infrastructure and user base to limit how much damage attackers can do.

Key Safeguards:

  • Centralize security event alerting
  • Deploy network intrusion detection/prevention systems
  • Monitor network traffic for anomalies
  • Perform traffic filtering between network segments
  • Manage access control for remote assets

Control 14: Security Awareness and Skills Training

60% of breaches in 2025 involved the human element (social engineering, error, or misuse). Trained users are your last line of defense so establishing and maintaining a security awareness program is critical to reduce cybersecurity risks to the enterprise.

Key Safeguards:

  • Establish security awareness training program
  • Train workforce on recognizing social engineering attacks
  • Conduct phishing simulations
  • Train workforce on authentication best practices
  • Train on data handling requirements

Control 15: Service Provider Management

Third-party breaches are increasing rapidly, with Verizon’s DBIR 2025 report showing they doubled to 30%

Your security is only as strong as your vendors' security so it’s essential to have a process in place to evaluate service providers who manage sensitive data, or are responsible for an enterprise's critical IT platforms or processes.

Key Safeguards:

  • Establish and maintain an inventory of service providers
  • Assess security posture of suppliers and service providers
  • Classify and inventory assets handled by third parties
  • Include security requirements in vendor contracts
  • Monitor service providers' security performance

Control 16: Application Software Security

The exploitation of public-facing applications is the leading initial access vector, accounting for 40% of all incidents (a 44% increase) in the IBM X-Force Threat Intelligence Index 2026.

Managing the security lifecycle of software (whether developed in-house, hosted, or acquired) helps prevent, detect, and remediate security weaknesses before they can impact the enterprise or become very costly to fix post-deployment.

Key Safeguards:

  • Establish and maintain secure application development practices
  • Establish secure coding practices
  • Perform application security testing
  • Remediate discovered application vulnerabilities
  • Manage application security updates

Control 17: Incident Response Management

In today’s threat landscape, it’s not if, but when, your organization will face an incident. This control focuses on developing and maintaining an incident response capability (e.g., policies, plans, procedures, defined roles, training, and communications) to prepare, detect, and quickly respond to an attack to limit damage. 

Key Safeguards:

  • Designate incident response personnel
  • Establish and document an incident response process 
  • Define incident severity and response procedures
  • Conduct incident response exercises
  • Document lessons learned from incidents

Control 18: Penetration Testing

It’s not enough to put controls in place. You have to validate whether your controls actually work against real-world attack techniques.

This control is all about identifying and exploiting weaknesses in controls, and simulating the objectives and actions of an attacker in order to test the effectiveness and resiliency of enterprise assets.

Key Safeguards:

  • Establish penetration testing program
  • Conduct regular penetration tests
  • Test security controls under real-world conditions
  • Validate remediation of findings

Recommended reading

110+ of the Latest Data Breach Statistics to Know for 2026 & Beyond

CIS Implementation Groups 

First introduced in CIS v7.1, Implementation Groups (IGs) are designed to help organizations with varying resources and risk exposure to implement CIS Controls and create and manage an effective cyber defense program. 

Each IG identifies which of the 18 CIS Controls and 153 Safeguards are reasonable to implement for an organization with a similar risk profile and resources. These are self-assessed categories. Meaning, organizations classify themselves in order to better focus their cybersecurity resources and expertise when implementing the CIS Controls. 

The groups are detailed below.

Implementation Group 1

Suitable for organizations with limited IT and cybersecurity expertise, this IG focuses on essential cyber hygiene practices to protect against common threats.

Consisting of 15 controls and 56 Safeguards, this set represents the minimum standard of information security for all enterprises. Since every enterprise should start with IG1 to guard against the most common types of cyber attacks, this group is considered the “on-ramp” to the CIS Controls. 

Who should implement IG1?

IG1 enterprises will likely:

  • Store and process low-sensitivity data, like employee and financial information
  • Be an SMB with limited resources dedicated to protecting IT assets and personnel
  • Have small or home office commercial off-the-shelf (COTS) hardware and software to defend against attacks
  • Need to thwart general, non-targeted attacks
  • Be primarily concerned with preventing downtime

Real-world example: A 25-person accounting firm with one part-time IT person. No regulatory requirements but need general data protection since processing client tax returns and financial data.

Implementation Group 2

Suitable for organizations with increased operational complexity, this IG includes all the controls and Safeguards identified in IG1 as well as 3 additional controls and 74 additional Safeguards that address a wider range of threats and vulnerabilities.

Who should implement IG2?

IG2 enterprises will likely:

  • Store and process sensitive client or enterprise information
  • Have dedicated individuals who are responsible for managing and protecting IT infrastructure
  • Need enterprise-grade technology and specialized expertise to properly install and configure some of the Safeguards
  • Support multiple departments with different risk profiles and regulatory compliance burdens
  • Be primarily concerned with preventing a data breach that could result in a loss of public confidence

In total, IG2 comprises all 18 controls and 130 Safeguards. 

Real-world example: A 200-person manufacturing company with a 3-person IT team, handling customer PII and proprietary designs, subject to CMMC Level 2 requirements for defense contracts.

Implementation Group 3

Designed for large enterprises with sophisticated IT environments and advanced cybersecurity capabilities, this IG comprises all controls and Safeguards identified in IG1 and IG2 as well as 23 additional Safeguards that provide comprehensive protection against advanced persistent threats (APTs) and other high-level risks.

In total, IG3 comprises all 18 controls and 153 Safeguards.

Who should implement IG3?

IG3 enterprises will likely:

  • Store and process highly sensitive data that, if its confidentiality, integrity, and/or availability were comprised, would cause significant harm to public welfare
  • Employ experts that specialize in different facets of cybersecurity, like risk management, penetration testing, and application security
  • Contain sensitive information or functions that are subject to regulatory and compliance frameworks
  • Need to mitigate targeted and sophisticated attacks and reduce the impact of zero-day attacks
  • Be primarily concerned with protecting the availability of services and the confidentiality and integrity of sensitive data in order to protect public welfare

Real-world example: A critical infrastructure provider (energy, healthcare, finance) with dedicated security operations center, threat intelligence team, and responsibility for protecting national interests.

Recommended reading

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How to implement the CIS Controls

Implementing CIS Controls can significantly enhance an organization’s cybersecurity posture. Here’s a detailed step-by-step guide on how to implement these controls effectively.

1. Assess your current security posture

Before implementing CIS Controls, conduct a thorough assessment to understand your current security posture and identify any gaps or weaknesses. This includes the following activities:

  • Asset inventory: Document all hardware and software assets within the organization.
  • Risk assessment: Identify potential vulnerabilities and threats to these assets.
  • Gap analysis: Compare your current security measures against the CIS Controls to identify gaps.

2. Select your Implementation Group

As mentioned above, CIS Controls v8.1 categorizes controls into three Implementation Groups (IGs). These groups provide a scalable and flexible approach to implementing the controls based on the organization’s risk profile and available resources.

Use the table below to determine which IG best matches your organization’s risk profile and available resources.

Implementation Group Suitable for Data sensitivity Primary aim Comprised of
IG 1 All organizations, particularly SMBs with limited IT and cybersecurity expertise Low Thwart general, non-targeted attacks to prevent downtime 15 CIS Controls and 56 Safeguards
IG 2 Organizations with increased operational complexity and a dedicated IT team Medium Defend IT infrastructure against a larger variety of threats to prevent breaches that would result in loss of public confidence 18 CIS Controls and 130 Safeguards
IG 3 Organizations with high risk exposure and a team of specialized cybersecurity experts High Mitigate targeted attacks from a sophisticated adversary and reduce the impact of zero-day attacks in order to protect public welfare 18 CIS Controls and 153 Safeguards

3. Prioritize implementing the most critical controls

Focus on implementing the most critical Controls in your IG first based on your risk profile. Prioritization can be guided by the following two factors:

  • Business impact: Controls that protect high-value assets or critical business functions should be prioritized
  • Threat landscape: Implement Controls that address the most relevant and current threats to your organization

4. Develop an implementation plan

Create a detailed plan that outlines the steps, resources, and timeline for implementing all the Controls identified in your IG. This plan should include:

  • Roles, responsibilities, and assigned tasks
  • Tools, technologies, and training needed
  • Realistic milestones and deadlines for each stage of implementation

5. Implement the controls

Now it’s time to execute your implementation plan. This involves:

  • Configuring systems, installing tools, and applying security settings as per the CIS Controls
  • Updating policies and procedures to align with the Controls
  • Educating staff about the new Controls and their roles in maintaining cybersecurity
  • Defining roles and procedures for handling incidents and returning operations to normal as quickly as possible
  • Performing penetration tests to test the strength of your company’s defenses

6. Monitor and measure your progress

Continuously monitor the implementation process and measure the effectiveness of the Controls. This can be done through:

  • Regular assessments: Conducting periodic reviews to ensure the Controls are in place and functioning correctly
  • KPIs: Using key performance indicators (KPIs) to track progress and identify areas for improvement
  • Incident tracking: Monitoring security incidents to evaluate the impact of implemented Controls
  • Penetration testing: Simulate cyber attacks on your operating systems to discover areas your organization can improve its information security

CIS Controls implementation checklist

This checklist provides a structured approach to begin implementing all 18 Controls in CIS Controls v8.1, ensuring that your organization covers essential areas of cybersecurity. Depending on your Implementation Group, you may not need to implement them all.

CIS Controls Implementation Checklist

Follow this structured approach to begin implementing all 18 Controls in CIS Controls v8.1, ensuring that your organization covers essential areas of cybersecurity.

How the CIS Controls fit into a cybersecurity program

Since the CIS Controls include foundational security measures for strengthening an organization’s cybersecurity posture, they can be a great starting point for any cybersecurity program.

Many of these foundational security measures can also help you meet requirements in other cybersecurity frameworks, helping to reduce duplicate work and speed up time-to-compliance for multiple frameworks.

Using the CIS Critical Security Controls Navigator, you can see how the CIS Controls are mapped to and referenced by multiple legal, regulatory, and policy frameworks, including but not limited to:

When using a compliance automation platform like Secureframe, this mapping is done automatically in-platform once you add another framework to your instance. This not only saves time and reduces the potential for human error. It also provides immediate visibility into how far along in the compliance process you already are with any additional frameworks and exactly  what gaps you need to fill to become compliant. 

A managed service provider can also help integrate the CIS Controls into a broader security program or framework when necessary.

Recommended reading

Control Mapping: What It Is & How It Can Help Simplify Your Compliance Efforts

CIS Controls and CMMC Level 2 Mapping and Analysis

As an example, we performed an analysis of the CIS Navigator to identify the overlap between CIS Controls and CMMC Level 2 requirements for you.

In total, CIS Controls v8.1 can be mapped to 73 of 110 CMMC Level 2 requirements. This represents approximately 66% foundational coverage of CMMC Level 2 practices.

However, it's important to understand that these mappings don't mean there are 73 CIS Controls and Safeguards directly equivalent to 73 CMMC requirements. In fact, many of these mappings indicate that the CIS Control or Safeguard is only partially or mostly related to the CMMC requirement. Meaning that implementing it will contribute to meeting the CMMC requirement, but not fully implement it on its own.

Why the partial alignment and not equivalency? CMMC was built with a more specific purpose and audience in mind than CIS Controls. CMMC Level 2 compliance requires organizations to fully implement the 110 requirements and 320 assessment objectives of NIST SP 800-171 Revision 2, with specific focus on protecting Controlled Unclassified Information (CUI) in defense supply chains.

Despite this nuance, CIS Controls provide strong foundational coverage for up to two-thirds of CMMC Level 2 requirements. While fully achieving CMMC compliance will require additional implementation beyond CIS Controls, they provide an excellent starting point for defense contractors building their cybersecurity programs.

For CMMC Level 2 contractors interested in using CIS to lay the foundation of their cybersecurity program, or for organizations that have already implemented CIS and are now adding CMMC to their roadmap, understanding which CIS Controls provide the most overlap can help them prioritize their efforts and allocate resources effectively. 

The table below shows the mapping between each CIS Control and the CMMC Level 2 practices.

Notes: Some of these CMMC requirements (also referred to as practices) can be addressed by multiple CIS Controls. For example, CM.L2-3.4.1 System Baselining is addressed by CIS Controls 1, 2, 4, and 12.

Also, the CIS Navigator uses a previous naming convention from an earlier draft of the DoD's CMMC Level 2 Assessment Guide, version 2.0 published in December 2021, in which any shared practice with Level 1 used "L1" in its name. We’ve referred to the CMMC practices below using the naming convention of the final version of CMMC and the latest version 2.14 of the DoD's Assessment Guide, which clearly differentiate levels. That means we refer to AC.L2-3.1.1 instead of AC.L1-3.1.1, etc.

CIS Control Title No. of Safeguards No. of Equivalent CMMC Practices CMMC Practices
1 Inventory and Control of Enterprise Assets 5 4 practices
  • AC.L2-3.1.1
  • AC.L2-3.1.2
  • CA.L2-3.12.4
  • CM.L2-3.4.1
2 Inventory and Control of Software Assets 7 5 practices
  • CM.L2-3.4.1
  • CM.L2-3.4.6
  • CM.L2-3.4.7
  • CM.L2-3.4.8
  • CM.L2-3.4.9
3 Data Protection 14 26 practices
  • AC.L2-3.1.1
  • AC.L2-3.1.2
  • AC.L2-3.1.3
  • AC.L2-3.1.5
  • AC.L2-3.1.7
  • AC.L2-3.1.13
  • AC.L2-3.1.17
  • AC.L2-3.1.19
  • AC.L2-3.1.22
  • CA.L2-3.12.4
  • IA.L2-3.5.10
  • MP.L2-3.8.2
  • MP.L2-3.8.3
  • MP.L2-3.8.7
  • MP.L2-3.8.6
  • MP.L2-3.8.1
  • SC.L2-3.13.1
  • SC.L2-3.13.5
  • SC.L2-3.13.6
  • SC.L2-3.13.8
  • SC.L2-3.13.10
  • SC.L2-3.13.11
  • SC.L2-3.13.15
  • SC.L2-3.13.16
  • SI.L2-3.14.6
4 Secure Configuration of Enterprise Assets and Software 12 18 practices
  • AC.L2-3.1.1
  • AC.L2-3.1.2
  • AC.L2-3.1.20
  • AC.L2-3.1.8
  • AC.L2-3.1.10
  • AC.L2-3.1.11
  • AC.L2-3.1.18
  • AC.L2-3.1.19
  • CM.L2-3.4.1
  • CM.L2-3.4.2
  • CM.L2-3.4.3
  • CM.L2-3.4.6
  • CM.L2-3.4.7
  • CM.L2-3.4.8
  • SC.L2-3.13.1
  • SC.L2-3.13.6
  • SC.L2-3.13.9
  • SC.L2-3.13.15
5 Account Management 6 6 practices
  • AC.L2-3.1.5
  • AC.L2-3.1.6
  • AC.L2-3.1.7
  • IA.L2-3.5.7
  • IA.L2-3.5.6
  • SC.L2-3.13.3
6 Access Control Management 8 10 practices
  • AC.L2-3.1.1
  • AC.L2-3.1.2
  • AC.L2-3.1.4
  • AC.L2-3.1.5
  • AC.L2-3.1.12
  • AC.L2-3.1.15
  • IA.L2-3.5.2
  • IA.L2-3.5.3
  • MA.L2-3.7.5
  • SC.L2-3.13.3
7 Continuous Vulnerability Management 7 6 practices
  • CA.L2-3.12.2
  • CA.L2-3.12.3
  • RA.L2-3.11.2
  • RA.L2-3.11.3
  • SI.L2-3.14.1
  • SI.L2-3.14.5
8 Audit Log Management 12 3 practices
  • AU.L2-3.3.1
  • AU.L2-3.3.5
  • AU.L2-3.3.7
9 Email and Web Browser Protections 7 7 practices
  • CM.L2-3.4.2
  • CM.L2-3.4.7
  • CM.L2-3.4.8
  • CM.L2-3.4.9
  • SC.L2-3.13.6
  • SC.L2-3.13.13
  • SI.L2-3.14.2
10 Malware Defenses 7 5 practices
  • MP.L2-3.8.7
  • SC.L2-3.13.13
  • SI.L2-3.14.2
  • SI.L2-3.14.4
  • SI.L2-3.14.5
11 Data Recovery 5 1 practice
  • MP.L2-3.8.9
12 Network Infrastructure Management 8 22 practices
  • AC.L2-3.1.2
  • AC.L2-3.1.13
  • AC.L2-3.1.17
  • AC.L2-3.1.20
  • AC.L2-3.1.22
  • AC.L2-3.1.3
  • AC.L2-3.1.12
  • AC.L2-3.1.14
  • AC.L2-3.1.16
  • CA.L2-3.12.4
  • CM.L2-3.4.1
  • CM.L2-3.4.6
  • IA.L2-3.5.2
  • IA.L2-3.5.3
  • MA.L2-3.7.5
  • SC.L2-3.13.1
  • SC.L2-3.13.2
  • SC.L2-3.13.3
  • SC.L2-3.13.5
  • SC.L2-3.13.15
13 Network Monitoring and Defense 11 15 practices
  • AC.L2-3.1.20
  • AC.L2-3.1.3
  • AC.L2-3.1.12
  • AC.L2-3.1.13
  • AC.L2-3.1.14
  • AC.L2-3.1.15
  • AC.L2-3.1.18
  • AU.L2-3.3.5
  • AU.L2-3.3.6
  • CM.L2-3.4.7
  • SC.L2-3.13.1
  • SC.L2-3.13.6
  • SI.L2-3.14.3
  • SI.L2-3.14.6
  • SI.L2-3.14.7
14 Security Awareness and Skills Training 9 5 practices
  • AC.L2-3.1.22
  • AT.L2-3.2.1
  • AT.L2-3.2.2
  • AT.L2-3.2.3
  • IR.L2-3.6.2
15 Service Provider Management 7 1 practice
  • CA.L2-3.12.4
16 Application Software Security 14 4 practices
  • AT.L2-3.2.2
  • CM.L2-3.4.2
  • SC.L2-3.13.2
  • SI.L2-3.14.1
17 Incident Response Management 9 5 practices
  • IR.L2-3.6.1
  • IR.L2-3.6.2
  • IR.L2-3.6.3
  • SI.L2-3.14.1
18 Penetration Testing 5 0 practices
  • N/A

Which CIS Controls matter most for CMMC?

Not all CIS Controls are equal when it comes to CMMC compliance. There are five in particular that address the highest number of CMMC practices and can help set the strongest foundation for CMMC Level 2.

These are:

  • CIS Control 3: Data Protection (26 CMMC practices): CUI protection is the entire purpose of CMMC. This control directly addresses encryption requirements, data classification, access restrictions, and secure disposal.
  • CIS Control 4: Secure Configuration (18 CMMC practices): Configuration Management is one of the largest CMMC domains.
  • CIS Control 6: Access Control Management (10 CMMC practices): MFA requirements, least privilege, and privileged access management are all heavily scrutinized by CMMC assessors.
  • CIS Control 12: Network Infrastructure Management (22 CMMC practices): Boundary protection and network segmentation are foundational requirements. This control addresses how you isolate and protect CUI environments.
  • CIS Control 13: Network Monitoring and Defense (15 CMMC practices): Detection capabilities are essential for incident response and demonstrating continuous monitoring, which are pillars of the CMMC program.

These top 5 controls alone map to 51 unique CMMC practices, representing approximately 70% of the practices covered at least partially by CIS Controls.

How Secureframe can simplify CIS Controls implementation and compliance with other frameworks

As a CIS SecureSuite® Product Vendor Member, we’ve integrated the CIS Controls content into our platform to further empower organizations and service partners to enhance their security posture and build comprehensive security programs for themselves and/or their customers.

Whether your organization is implementing the CIS Controls itself or working with a managed service provider, Secureframe can help simplify and speed up the process. 

With Secureframe, you can:

  • Automate evidence collection to eliminate manual tasks like taking screenshots and organizing documentation 
  • Continuously monitor your tech stack and cloud services to ensure compliance and flag nonconformities 
  • Deliver and track employee training
  • Simplify vendor and personnel management
  • Use auditor-approved policy templates to save time spent on policy creation 
  • Stay current with the latest version of the CIS Controls and other frameworks
  • Map Controls and tests you put in place for CIS compliance to other frameworks to speed up time-to-compliance and reduce duplicate work

If you’re a managed service provider, you can use Secureframe’s powerful automation and AI capabilities to revolutionize how you manage security and compliance for your clients. 

To see why 97% of users reported strengthening their organization's security and compliance posture with Secureframe, request a demo today. Or if you’re looking to become a Secureframe partner, sign up here.  

FAQs

What are the CIS Controls?

The CIS Controls are a set of 18 best practices for cybersecurity developed by the Center for Internet Security (CIS) to help organizations of all sizes mitigate the most common cyber threats.

What does CIS Controls stand for?

CIS Controls stands for the Center for Internet Security Critical Security Controls.

How many CIS Controls are there?

As of CIS Controls v8.1, there are 18 Controls.

How many CIS Safeguards are there?

There are 153 Safeguards in CIS Controls v8.1.

Why do organizations implement the CIS Controls?

Implementing the CIS Critical Security Controls can greatly strengthen an organization’s cybersecurity posture. By understanding and adopting this set of prescriptive best practices, an organization can build a robust cybersecurity foundation that protects them from common cyber attacks and evolves with the changing digital and threat landscape.

Why do Managed Service Providers implement CIS controls?

The reasons that MSPs choose to implement CIS controls for their clients differ slightly from the reasons that organizations themselves choose this framework. Their top three reasons are:1. 

  • To provide essential security services: By providing a set of safeguards and best practices for securing systems, networks, and software, MSPs can use the CIS Controls to ensure they are using industry standards when providing essential security services to their customers.
  • Meet clients’ industry-specific and other relevant requirements: MSPs can also leverage CIS controls to ensure that they are meeting specific compliance requirements and security standards set forth in industries that their customers operate within. Since the CIS Controls are widely recognized and well mapped, MSPs can use the mappings to demonstrate their clients have the necessary controls in place to meet their industry’s compliance requirements and security standards such as CMMC, HIPAA, PCI DSS, NIST CSF, NIST 800-53, ISO 27001, and SOC 2.
  • Establish a competitive differentiator: The utilization of CIS Controls demonstrates a strong commitment to security standards and provides a key differentiator in the MSP community. Clients are more likely to trust an MSP that follows established and reputable security practices like the CIS Controls. 

How do CIS Controls relate to CMMC Level 2?

CIS Controls v8.1 map to approximately 73 of 110 CMMC Level 2 practices (66% coverage). The top 5 CIS Controls (Data Protection, Network Infrastructure Management, Secure Configuration, Network Monitoring & Defense, and Access Control Management) alone cover 51 unique CMMC practices. However, these mappings are often partial. CIS Controls provide a strong foundation, but organizations will need to address 37 additional CMMC-specific practices that have no mappings as well as all 320 assessment objectives in NIST 800-171 Rev. 2 to achieve full compliance.

Can implementing CIS Controls help me achieve CMMC certification?

Yes, but with important caveats. Implementing CIS Controls provides strong foundational coverage for approximately 66% of CMMC Level 2 requirements. This significantly reduces the work needed for CMMC certification. However, you'll still need to address 37 additional CMMC practices that aren't covered by CIS Controls, primarily in physical security, personnel screening, maintenance procedures, and CMMC-specific documentation requirements. You’ll also likely need to implement additional controls to fully address the 73 CMMC Level 2 requirements that are only partially or somewhat related to the mapped CIS Controls. 

Which framework should I implement first: CIS Controls or CMMC?

For defense contractors, the answer depends on your timeline and current state. Here’s some general criteria:

Implement CIS Controls first if

  • You have a long runway (18+ months) or no upcoming deadline for CMMC certification
  • You have no existing cybersecurity program
  • You want a proven, structured approach to build your foundation
  • You need to demonstrate security maturity to customers beyond DoD

Focus on CMMC directly if:

  • You have less than 12 months until certification is required
  • You already have strong cybersecurity controls in place
  • Your only compliance requirement is CMMC
  • You're using a platform like Secureframe that handles both simultaneously

Best approach: Many organizations implement both in parallel using a compliance platform that maps CIS Controls to CMMC requirements automatically, maximizing efficiency.

What are the CMMC Level practices not covered by CIS Controls?

The 37 unmapped practices fall primarily into these categories:

  • Physical Security (6 practices): Facility access controls, visitor management, physical access logs
  • Identification & Authentication (6 practices): User identification requirements, password complexity rules, authentication feedback
  • Maintenance (5 practices): Maintenance procedures, equipment sanitization, diagnostic media controls
  • Audit & Media (8 practices): Audit protection, CUI marking, media tracking
  • Personnel & Other (12 practices): Background screening, risk assessments, VoIP controls, privacy notices

Most of these are policy and administrative controls rather than complex technical implementations.

Is CIS Controls compliance mandatory like CMMC?

No. CIS Controls are voluntary best practices, not regulatory requirements. However, several U.S. states reference CIS Controls in laws requiring government entities to maintain a "reasonable" level of security. CMMC Level 2, by contrast, will become mandatory for defense contractors handling Controlled Unclassified Information (CUI) under DFARS 252.204-7012 and 7021.

Despite being voluntary, many organizations implement CIS Controls because they:

  • Provide clear, actionable guidance (vs. vague "be secure" requirements)
  • Map to multiple compliance frameworks, reducing duplicate work
  • Are widely recognized by cyber insurance providers
  • Demonstrate due diligence to customers and stakeholders

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Anna Fitzgerald

Senior Content Marketing Manager

Anna Fitzgerald is a digital and product marketing professional with nearly a decade of experience delivering high-quality content across highly regulated and technical industries, including healthcare, web development, and cybersecurity compliance. At Secureframe, she specializes in translating complex regulatory frameworks—such as CMMC, FedRAMP, NIST, and SOC 2—into practical resources that help organizations of all sizes and maturity levels meet evolving compliance requirements and improve their overall risk management strategy.

Marc Rubbinaccio

Head of Cybersecurity & Compliance

Marc Rubbinaccio is an information security leader with over a decade of experience in cybersecurity. As a former auditor and security consultant, Marc performed and managed security and regulatory audits as a lead QSA. At Secureframe, he’s helped hundreds of customers achieve compliance with federal and commercial frameworks, including PCI DSS, SOC 2, ISO 27001, CMMC, and FedRAMP. He also played an integral role in Secureframe’s own CMMC Level 2 assessment and FedRAMP 20x Low authorization.