CMMC Level 2 Practice 3.5.9: Allow temporary password use for system logons with an immediate change to a permanent

CMMC Level 2 Practice 3.5.9 requires you to issue temporary passwords only in a way that forces an immediate change to a user-chosen permanent password at first logon. To operationalize it, configure identity systems to require “change password at next sign-in,” prohibit shared/default passwords, and retain evidence that the setting is enforced across all in-scope accounts and platforms. ¹

Key takeaways:

• Enforce “temporary password + forced change at first logon” across all interactive logons in the CUI environment. ¹
• Treat account provisioning and password resets as the main workflows to control and audit. ¹
• Assessors will look for technical enforcement plus repeatable evidence, not policy statements. ²

You meet the cmmc level 2 practice 3.5.9: allow temporary password use for system logons with an immediate change to a permanent requirement by engineering your account lifecycle so temporary credentials exist only long enough to complete first sign-in and are unusable after that moment. This is not a “password policy complexity” control; it is a control over the transition from admin-issued credentials (or reset credentials) to user-controlled credentials, with technical enforcement.

For a Compliance Officer, CCO, or GRC lead, the fastest path is to anchor 3.5.9 to two operational events: (1) new account provisioning and (2) password resets/unlocks. If your IT team can demonstrate that every temporary password is issued with “must change at next logon” (or equivalent) enforced by the identity provider, and you can produce records showing it happened, you are most of the way to an assessment-ready posture. ¹

The practical risk is straightforward: temporary passwords that remain valid after first use behave like shared secrets that admins (or service desks) can reuse, intercept, or mishandle. CMMC expects you to prevent that class of failure through configuration, not training alone. ²

Regulatory text

Requirement (mapped): “Allow temporary password use for system logons with an immediate change to a permanent.” This CMMC Level 2 practice maps to NIST SP 800-171 Rev. 2 requirement 3.5.9. ¹

Operator interpretation: You may issue a temporary password (for example, during onboarding or after a reset), but the system must force the user to change it immediately upon logon. The control is satisfied when the enforcement is technical and applies consistently to in-scope systems supporting CUI. ¹

Primary sources to cite in your SSP/control narrative:

• CMMC program context: 32 CFR Part 170 ³
• Program guidance and assessment expectations: ²
• Control definition: ¹

Plain-English interpretation (what 3.5.9 really means)

Temporary passwords are allowed, but they are “single-transition” credentials. They exist to get a user into the system once, then they must be replaced immediately with a password the user controls. ¹

What counts as “immediate” in practice:

• The platform forces a password change as part of the first interactive sign-in flow.
• The user cannot proceed to normal system use without completing the change.
• The old temporary password cannot be used again after the change (because the password has been updated and the temporary value is no longer valid). ¹

What this control is not:

• It is not the same as password complexity, reuse, or expiration rules (those map to other 3.5 controls).
• It is not satisfied by a helpdesk script that “tells users” to change their password later. Assessors will expect technical enforcement. ²

Who it applies to (entity and operational context)

Entities: Defense contractors and other federal contractors handling CUI that are targeting or required to maintain CMMC Level 2 alignment. ³

Operational scope: Any system logon mechanism within the assessed environment where human users authenticate with passwords (directly or via an identity provider). Common in-scope areas include:

• Corporate directory/IdP accounts used to access CUI systems
• Workstations and servers that accept interactive logons
• VPN/remote access portals that accept password-based login
• SaaS applications in the CUI boundary that use password authentication (or rely on federated identity with password-backed accounts) ¹

Third parties: If a third party (for example, a managed service provider) provisions accounts or performs password resets for your environment, their process becomes part of your evidence chain. You still need proof the enforcement exists and is used. ²

What you actually need to do (step-by-step)

Use this as a requirement-level runbook for implementation and assessment readiness.

1) Define the control statement and boundary

• Identify the systems in your CUI boundary that accept password-based interactive logons.
• Document the authoritative identity source(s) (for example, a directory service, IdP, or application-local accounts where unavoidable).
• Write a short control statement: “Temporary passwords are issued only with forced change at next sign-in for all in-scope user accounts.” ¹

2) Standardize the onboarding workflow (new accounts)

For each identity platform in scope:

• Configure provisioning so accounts are created with either:
  • a one-time temporary password plus “change at next logon,” or
  • an onboarding mechanism that requires the user to set a new password at first sign-in. ¹
• Prohibit sending temporary passwords over insecure channels in your procedure (even though 3.5.9 is about forced change, weak delivery methods create predictable audit questions).
• Ensure the person creating the account cannot complete the password change on the user’s behalf unless your process explicitly supports delegated administration with documented authorization and logging. ²

3) Standardize the password reset workflow (service desk / IT ops)

• Require that all resets set a temporary password flag that forces change at next sign-in.
• Block “set password and do not require change” except for tightly controlled break-glass or non-person accounts that are documented and justified.
• Ensure your ticketing workflow captures who performed the reset, for which account, on what system, and when. ²

4) Close common exceptions: local accounts, appliances, and “default admin”

• Inventory local accounts on endpoints/servers that can be used to log on interactively.
• For devices or applications that ship with default passwords, require immediate change during deployment, and document the build checklist.
• Where “force change at next logon” is not technically available (common in some appliances), document an alternate method that creates the same outcome: the temporary password cannot persist beyond first access. Example: first-login wizard that forces password set before granting access. Tie the exception to a compensating control and record the rationale. ¹

5) Make it assessable: recurring evidence capture

Assessors test implementation, not intentions. Create a lightweight evidence routine:

• Quarterly (or on another consistent cadence you can defend), capture screenshots/exported config showing the “must change at next logon” behavior for:
  • a sample new account
  • a sample reset account
• Retain a small set of completed tickets demonstrating the workflow.
• Keep procedures current so they match the tooling configuration. ²

A practical way to keep this clean is to manage 3.5.9 as a mapped control with recurring evidence tasks in Daydream, so screenshots, tickets, and config exports land in one place with clear ownership and review dates. ²

Required evidence and artifacts to retain

Keep evidence that proves technical enforcement and repeatability:

Policy/procedure artifacts

• Access control or identity management procedure covering onboarding and resets, explicitly stating forced change at next logon for temporary passwords. ¹

Technical configuration evidence

• IdP/directory settings export or screenshots showing “user must change password at next logon” (or equivalent) is enabled and used.
• Application or OS configuration showing first-logon change enforcement where passwords are used locally. ¹

Operational records

• Service desk tickets for password resets showing:
  • requestor identity and authorization path
  • admin performing the reset
  • timestamps and closure notes indicating forced change was set
• New hire provisioning tickets or workflow logs with the same attributes. ²

Assessment-ready mapping

• SSP/control narrative for 3.5.9 with system list, responsible roles, and where evidence is stored. ²

Common exam/audit questions and hangups

Expect these questions from a CMMC assessor and pre-answer them with evidence:

1. “Show me where the system forces the password change.”
   They want a config view and a live demonstration or documented test case. ²

2. “Does this apply to VPN, email, and SaaS too?”
   If they’re in the CUI boundary and password-based authentication exists, yes. Show boundary rationale and identity flow diagrams. ¹

3. “What about local admin accounts?”
   Local accounts are a frequent gap. Show how you control and rotate them, and how first-use temporary credentials are forced to change (or why they’re not used). ¹

4. “What’s your exception process?”
   Have a documented path for systems that cannot technically enforce first-login changes, with compensating controls and risk acceptance approvals. ²

Frequent implementation mistakes (and how to avoid them)

• Mistake: Relying on a written policy only.
  Fix: Capture system configuration proof and a few real tickets each period. ²

• Mistake: Temporary passwords emailed in cleartext with no identity verification.
  Fix: Require identity verification steps in the reset procedure and prefer out-of-band delivery methods supported by your environment. ²

• Mistake: Shared onboarding accounts or default credentials for groups.
  Fix: Individualize accounts and ensure each account is forced to change at first logon. ¹

• Mistake: Ignoring non-SSO apps in the CUI boundary.
  Fix: Build an app inventory, flag apps with local authentication, and implement the same first-logon forced change pattern. ¹

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this specific practice. CMMC assessments still treat 3.5.9 as testable and objective: either temporary passwords require immediate change, or they do not. The practical risk is account compromise through reused or intercepted temporary credentials, especially in service desk-heavy environments and during onboarding surges. ²

A practical 30/60/90-day execution plan

First 30 days (stabilize and define)

• Confirm the CUI boundary systems where password logon exists. ¹
• Document onboarding and reset workflows, including who can issue temporary passwords. ²
• Identify platforms where forced change is not currently enforced (IdP, local accounts, appliances). ¹

Next 60 days (implement and prove)

• Configure “change at next sign-in” (or equivalent) across directories/IdPs and key apps. ¹
• Update service desk scripts and ticket fields so forced-change is a required step and recorded. ²
• Run a tabletop test: create an account, issue a temporary password, confirm forced change, and retain the evidence package. ²

By 90 days (operationalize and make it repeatable)

• Build an exceptions register for systems that cannot enforce first-logon changes; document compensating controls and approvals. ²
• Establish recurring evidence capture and internal review so you always have “fresh” artifacts for assessors. Track it in Daydream to keep tickets, screenshots, and control narrative aligned. ²
• Validate third-party workflows (MSP/helpdesk) with samples of their reset tickets and your configuration settings. ²

Frequently Asked Questions

Does “immediate change” mean the user must change the password at the first login attempt?

Yes. The system should force the change as part of the first successful interactive sign-in flow so the user cannot proceed with a temporary password. ¹

Are password reset links (instead of temporary passwords) acceptable?

They can be, if the workflow results in the user setting a new permanent password before normal access is granted and the temporary secret cannot be reused. Document the workflow and retain evidence. ¹

Does 3.5.9 apply to service accounts?

The practice is focused on “system logons” and temporary password use. If a non-person account uses passwords and is reset with temporary credentials, control the reset so a temporary password does not persist. Document any non-interactive or exception cases. ¹

What evidence is strongest for an assessor: tickets or screenshots?

You need both: screenshots/exports show technical enforcement, and tickets show the process is used in real operations. Pair a few representative tickets with the matching config evidence. ²

We have multiple domains/tenants. Do we need to prove this everywhere?

Yes for all tenants/domains in the CUI boundary that support system logons with temporary passwords. Maintain a system list and show enforcement per environment. ¹

If our IdP enforces MFA, does that reduce the need for forced-change on temporary passwords?

MFA helps, but it does not replace the requirement to force a temporary password to change immediately at logon. Treat MFA as complementary control evidence, not a substitute. ¹

Footnotes

1. NIST SP 800-171 Rev. 2

2. DoD CMMC Program Guidance

3. 32 CFR Part 170