What evidence do auditors commonly ask for on SC.L2-3.13.10 Key Management?

Key management procedure covering generation, distribution, storage, rotation and destruction; Key inventory and custodian assignments; Evidence of key rotation and secure storage.

What is the most common gap auditors find on SC.L2-3.13.10?

Keys generated and then never rotated or inventoried

CMMC 2.0 · System and Communications Protection

`SC.L2-3.13.10` Key Management

Establish and manage the cryptographic keys used by cryptography employed in organizational systems, across their life cycle.

Source: CMMC 2.0, SC.L2-3.13.10. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open CMMC 2.0 in the compliance library.

artefacts

held by a system

at each review

hard

to go live

Policy repository / GRC workspace

where the evidence lives

teal = a system already holds it · olive = produced at each review. To go live: easy when half or more of the artefacts are already held by a system, moderate from a quarter to a half, hard below a quarter.

These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.

system holds itEvidence a system already holds

none for this control

periodic reviewEvidence produced at each review

Evidence of key rotation and secure storage · Key management / PKI

governing documentDocuments that govern the control

Key management procedure covering generation, distribution, storage, rotation and destruction · Policy repository / GRC workspace
Key inventory and custodian assignments · Policy repository / GRC workspace

First move

No system holds this evidence for you: it is people and documents. Reminders and routing to the owner still save time. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date.

Common gaps auditors find

Keys generated and then never rotated or inventoried
Private keys stored alongside the data they protect
Key custodianship undefined so departures leave keys orphaned

Do this for your whole sheet

Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.

Build my evidence sheet

SC.L2-3.13.9 Connections Termination · SC.L2-3.13.11 CUI Encryption