TroutTrout
Back to Glossary
CMMC enduring exceptionCMMC complianceOT legacy systems

CMMC Enduring Exception

1 min read

A CMMC Enduring Exception is, in the words of 32 CFR 170.4, "a special circumstance or system where remediation and full compliance with CMMC security requirements is not feasible", such as a PLC or CNC controller whose firmware cannot do MFA or write an audit log. It must be documented in the System Security Plan, and unlike a temporary deficiency tracked in a POA&M, it lasts for the life of the machine. It is not a waiver: each exception needs a compensating control that is running and produces evidence, as set out in the guide to CMMC exceptions and compensating controls for OT.