NIST 800-171 3.5.7 (IA.L2-3.5.7): Password Complexity

Enforce a minimum password complexity and change of characters when new passwords are created.

NIST SP 800-171 Rev. 2, requirement 3.5.7

CMMC Level 2 practice IA.L2-3.5.7Published 2026-11-11

What 3.5.7 means in practice

Passwords meet a defined minimum length and complexity, and a new password differs from the old one by a defined number of characters. Write the rules down and set them wherever passwords are created: the identity provider, local accounts, and applications with their own logins.

SPRS points and the CMMC POA&M

CMMC Level 2 practice: IA.L2-3.5.7
SPRS points: 1 point. When it is not met, the DoD Assessment Methodology subtracts 1 from the score of 110.
CMMC POA&M: Allowed. It is worth 1 point, and 32 CFR 170.21(a)(2)(ii) admits requirements worth 1 point. Conditional status also needs a score of at least 88, and the item must be closed within 180 days.

Sources: NIST SP 800-171 DoD Assessment Methodology, version 1.2.1 (June 24, 2020), Annex A; 32 CFR 170.21, Plan of Action and Milestones requirements.

What an assessor checks for 3.5.7

NIST SP 800-171A gives 4 determination statements for 3.5.7, each found satisfied or other than satisfied. Determine if:

3.5.7[a] password complexity requirements are defined.
3.5.7[b] password change of character requirements are defined.
3.5.7[c] minimum password complexity requirements as defined are enforced when new passwords are created.
3.5.7[d] minimum password change of character requirements as defined are enforced when new passwords are created.

NIST SP 800-171A (June 2018), assessment objectives for 3.5.7

Evidence that shows 3.5.7 is met

The written password rules: length, complexity and number of changed characters.
Identity provider and directory password policy settings.
Password settings for local accounts and for applications with their own credentials.

How PolicyCortex gathers the evidence

PolicyCortex reads this evidence with the collectors below, read only, and grades 3.5.7 from it. Each line says what the product checks.

Okta: Policies. Checks that every active Okta password policy requires at least 14 characters, with lowercase, uppercase, number and symbol characters.
AWS: IAM. Checks the AWS account password policy against a baseline that starts at 14 characters.

Related pages

Calculator: SPRS score calculator: mark 3.5.7 and the other 109 requirements and see the score.
Sample package: Sample package: an SSP, a POA&M and an evidence chain the product generated from demonstration data.
Family: All 11 Identification and Authentication requirements (3.5).
Previous: 3.5.6: Inactive Accounts
Next: 3.5.8: Password Reuse
All requirements: All 110 NIST SP 800-171 requirements, by family.

Related records

Guides and articles describe the work. The evidence that work produces is described in three proof pages, the architecture page, and the two pages on authorization.

proof.state: Proof of State. What the environment was, as of a date someone else picks: point-in-time records, content hashed and chained.
proof.change: Proof of Change. Who or what altered the environment, under what authority, with before and after state hashes.
proof.agency: Proof of Agency. What a machine was permitted to do before it acted, what it did, and what would have stopped it.
architecture: Architecture. How the chain is built and where the evidence is stored in each delivery mode.
authorization: Continuous ATO. How an authorizing official's decision is recorded with its package, and how the authorized system is checked against it every hour.
baseline: NIST SP 800-53. The Low, Moderate and High baselines as evidence, with the SSP, SAR and POA&M generated from one record.