Top 10 Non-Conformities in China's MLPS 2.0 Level-3 Assessments

Across 100+ MLPS 2.0 Level-3 engagements, Halocent finds that 80% of non-conformities cluster into a small number of areas. This article collects the top ten and pairs each with a concrete remediation.

Top 10 findings

1) No periodic account/permission review (§8.1.4.1)

Typical: shared admin accounts, offboarded accounts still active, privileged accounts not reviewed in 90 days.

Fix: named account owners, quarterly audit reports, HR-triggered auto-disable via IAM/AD.

2) Critical operations without MFA (§8.1.4.2)

Typical: SSH / RDP / DB clients password-only; single-factor VPN.

Fix: at minimum MFA on ops channels, bastion, and critical business back-office. Prefer TOTP / FIDO2.

3) Logs retained less than 6 months (§8.1.4.3)

Fix: centralise logs in SIEM, retention ≥ 180d (critical systems ≥ 1y), full-text searchable.

4) Malware protection not covering servers (§8.1.4.4)

Fix: deploy lightweight HIDS/EDR on Linux servers (osquery + wazuh, or a commercial product), policies refreshed quarterly.

5) Sensitive data transmitted in cleartext (§8.1.4.5)

Fix: TLS 1.2+ everywhere; internal CA-issued certs; forced SSL for DB connections.

6) Backups not off-site or never tested (§8.1.4.6)

Fix: off-site or multi-AZ backup, quarterly restore drills, published RTO/RPO reports.

7) Incident-response plan on paper only (§8.1.4.7)

Fix: named IC/forensics/comms roles, tabletop exercise every 6 months with records.

8) Loose supply-chain access (§8.1.10)

Fix: temporary account + bastion + full audit for vendor engineers; standard security clauses in every contract.

9) Change management without security review (§8.1.9)

Fix: every production change is ticketed, Security is a mandatory approver, major changes require pre-launch scan.

10) Data classification incomplete (§8.1.6)

Fix: at least four tiers plus field-level identification (national ID, phone, bank card), backed by real technical controls.

Halocent stat: covering these ten items lifts first-time Level-3 pass-rate from 62% to 91%.

Suggested project cadence

  1. T-8 weeks: gap analysis (Halocent offers a free lightweight version).
  2. T-6 weeks: named remediation owners + budget, weekly plan.
  3. T-3 weeks: core remediation shipped and change-freeze begins.
  4. T-1 week: internal mock assessment covering common sample requests.
  5. During assessment: dedicated liaison ensures assessors receive materials within 24 hours.

Preparing your first Level-3? Contact us — Halocent offers a 2-hour free gap-analysis call.

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