CPCSC Level 2 Control

Last updated June 25, 2026

03.12.02Security assessment and monitoring

CPCSC Level 2 03.12.02: Plan of Action and Milestones

Apply plan of action and milestones to assess controls, track remediation, monitor effectiveness, and manage information exchanges for CPCSC Level 2 readiness. This guide separates the official ITSP.10.171 control language from practical implementation, evidence, auditor questions, and related controls.

Formal Control Language

Official ITSP.10.171 wording for 03.12.02. Use the Cyber Centre publication and contract requirements as the source of truth for certification, assessment, or procurement submissions.

  • Develop a plan of action and milestones (POAMs) for the system to: document the planned remediation actions to correct weaknesses or deficiencies noted during security assessments
  • reduce or eliminate known system vulnerabilities
  • Update the existing POAM s based on the findings from: security assessments
  • audits or reviews
  • continuous monitoring activities

Contains information sourced from Government of Canada material used under the Open Government Licence - Canada.

What This Means In Plain English

Plan of Action and Milestones is part of the CPCSC Level 2 Security assessment and monitoring family. This is about proving controls are assessed, gaps are tracked, monitoring continues between assessments, and information exchanges are governed.

For a founder, CISO, engineer, or compliance owner, the practical question is whether plan of action and milestones is visible in real operating evidence: a setting, workflow, ticket, log, approval, review, or exception record that can survive an external assessment.

Level 2 is different from Level 1 because the evidence has to survive an external assessment. A policy statement helps, but the stronger answer is a record that shows who did the work, when it ran, what system setting or workflow enforced it, and how exceptions were handled.

How To Implement It

1

Define the in-scope systems, owners, users, vendors, and data flows affected by plan of action and milestones.

2

Maintain an assessment plan, test controls, track POA&M items, monitor control health, and document exchange agreements for specified information.

3

Translate the formal requirement into one or two operating procedures: who performs it, how often, where it is recorded, and who approves exceptions.

4

Configure the relevant systems so the control is enforced by identity, endpoint, cloud, network, ticketing, monitoring, vendor, or documentation workflows rather than memory.

5

Keep evidence in a consistent folder, GRC system, ticket queue, or audit workspace so an assessor can trace the control from requirement to implementation to review.

Evidence Normally Gathered

Plan of Action and Milestones: assessment plan.

Plan of Action and Milestones: control test records.

Plan of Action and Milestones: POA&M.

Plan of Action and Milestones: continuous monitoring reports.

Plan of Action and Milestones: information exchange agreements.

Plan of Action and Milestones: remediation status reports.

Plan of Action and Milestones: owner assignment and review cadence.

Plan of Action and Milestones: exception, remediation, or POA&M records when the control is not fully implemented.

Common Auditor Questions

Where is plan of action and milestones implemented in the in-scope environment?

Who owns plan of action and milestones, and how do they know it is operating?

Show the evidence that proves plan of action and milestones ran during the assessment period.

What happens when plan of action and milestones fails, is bypassed, or has an exception?

How does this control connect to the system security plan, risk register, POA&M, and related CPCSC controls?

Sources

Source and attribution.

Formal control language is sourced from the Canadian Centre for Cyber Security ITSP.10.171 publication. CPCSC Level 2 assessment context references the Government of Canada CPCSC program overview and ITSP.10.171-01 assessment guidance.

CPCSC Program OverviewITSP.10.171ITSP.10.171-01Open Government Licence - Canada