Administration & Regulatory Compliance

Affirmation. Engineered.

Under 32 CFR Part 117, organizations handling CUI must affirm annually that their CMMC compliance posture remains accurate, and the affirmation must be made by a named senior official. 1TEN tracks the obligation, documents the attestation, and surfaces the renewal deadline before it lapses.

Annual Affirmation cycle tracked
Named Senior official on record
32 CFR Part 117 compliance
Capability

What the Affirmation Requires

The annual affirmation is a formal attestation by a C-suite or senior official confirming that the organization's security posture continues to meet the requirements documented in the SSP, and that no material changes have occurred that would affect CMMC compliance status. It must be made by a named individual with authority to bind the organization, not a compliance officer acting alone.

The affirmation is tied to the organization's SPRS score: submitting it confirms that the self-assessed score posted to the SPRS portal remains accurate. If posture has changed materially (new systems added to scope, controls degraded, POA&M items unresolved beyond the accepted window), the posture must be updated before the affirmation is made.

Evidence

Attestation Record and Audit Trail

1TEN captures the affirming official's name and title, the date of affirmation, the SPRS score in effect at the time, and the SSP version the affirmation covers. This creates an auditable record of each annual cycle, demonstrating continuous compliance rather than a single certification event, and providing the documentation a contracting officer or auditor would request.

The module tracks your last affirmation date and surfaces renewal reminders in the Compliance Calendar as the annual deadline approaches. Missing the affirmation deadline is a compliance gap under 32 CFR Part 117, and 1TEN makes sure it does not happen by accident.

Inside the Module

What You See Inside

Affirming official record
Name, title, and organizational role of the senior official making the attestation.
Date and score captured
Exact affirmation date, logged and immutable, plus the SPRS score the affirmation certifies as accurate.
SSP version reference
The version of the System Security Plan in effect at the time of affirmation.
Affirmation history
A complete record of all prior affirmations with dates, officials, and scores.
Renewal reminders
Surface in the Compliance Calendar 60 and 30 days before the annual deadline.
Pre-affirmation checklist and export
Verifies open POA&M items, evidence gaps, and SPRS score are current before signing, and produces a printable attestation record for contract files or audit response.
The problem this solves

The annual affirmation is a legal attestation by a senior official that the organization's compliance posture is accurately represented in its SPRS self-assessment score, and false affirmations carry liability under the False Claims Act. An organization that misses the annual cycle, uses the wrong level of official, or cannot produce an attestation record when asked faces both a compliance gap and a legal exposure. No more affirmations made verbally or by email with no record, no more signing without verifying the SPRS score and SSP are current, no more annual deadlines passing unnoticed.

Reference

Affirmation Requirements Under 32 CFR Part 117

Who must affirm
A senior company official, typically C-suite (CEO, COO, CTO, CISO) or equivalent with authority to bind the organization.
What is affirmed
That the SPRS self-assessment score accurately reflects the organization's current security posture.
Frequency
Annually, within 12 months of the prior affirmation.
Where it is submitted
The SPRS portal (supplier.dcsa.mil), the same system where the SPRS score is posted.
Legal exposure
False affirmations are subject to liability under the False Claims Act, 31 U.S.C. 3729 to 3733.
Trigger for early re-affirmation
Material changes to security posture, scope, or SPRS score require an updated affirmation before the annual cycle.
Practices

Requirements Satisfied

RequirementDescription
32 CFR Part 117 Annual affirmation requirement. Senior official attestation that the organization's SPRS score and security posture remain accurate.
CA.L2-3.12.4 System security plan maintenance. Affirmation records reference the SSP version in effect, supporting the currency and update history required under this practice.
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All 110. Tracked.

1TEN is an air-gapped, on-premises GRC platform engineered for defense contractors handling CUI.

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