NIST SP 800-171 Rev. 3·Requirement 3.3.1·high·Component: Audit and Accountability

What this control requires

This control specifies the types of events to be logged within the system, ensuring that all security-relevant events, such as password changes, failed logins, and privileged function execution, are captured. It also requires regular reviews and updates of the event types selected for logging to ensure that they remain relevant to the system's security requirements. This control supports the Event Logging Configuration capability within the Audit and Accountability (3.3) family.
— NIST SP 800-171 Rev. 3, Requirement 3.3.1

In plain English

This control specifies the types of events to be logged within the system, ensuring that all security-relevant events, such as password changes, failed logins, and privileged function execution, are captured. In practice, this means you can prove you access management-level controls on a defined cadence.

Why it matters

DoD contractors and their subcontractors must implement all 100 SP 800-171 requirements to keep CUI handling contracts. Gaps are scored against the SPRS scoring methodology; below a 110-point starting score, each unmet requirement deducts points and a below-threshold score can disqualify a bid.

This control is rated high. Auditors expect a named owner, a remediation SLA, and a tooling artefact that evidences continuous operation.

What an auditor looks for

A C3PAO conducting a CMMC Level 2 assessment uses NIST SP 800-171A objectives. They expect a System Security Plan (SSP), Plan of Action & Milestones (POA&M) for any gaps, and objective evidence (configurations, ticket records, training records) for every requirement.

Within Audit and Accountability, the assessor will trace your implementation back to the catalogue reference (Requirement 3.3.1) and look for objective evidence on the latest two assessment cycles.

How to implement

Logging Monitoring

AWS. Org-trail CloudTrail to a central log archive account, GuardDuty in every region, and Security Hub for cross-source correlation.

Azure. Pipe every diagnostic setting into a central Log Analytics workspace; onboard Microsoft Sentinel for SIEM/SOAR.

GCP. Aggregate audit logs in a dedicated logging project with sink to BigQuery; enable Security Command Center Premium and route findings to Chronicle SIEM.

Operational checklist

  • Access. Document the trigger, the owner and the cadence.
  • Event. Document the trigger, the owner and the cadence.
  • Configuration. Document the trigger, the owner and the cadence.
  • System. Document the trigger, the owner and the cadence.
  • Password. Document the trigger, the owner and the cadence.
  • Scope: management, configuration, password changes, security.

Evidence to collect

  • Identity Scan. IAM / IdP exports — Entra ID, Okta, IAM Identity Center, Workspace directory — showing accounts, roles, MFA state and last sign-in.

Identity analytics (Okta, SailPoint, Access Analyzer) demonstrates least-privilege. Focus: Event Logging.

Common pitfalls

  • Per-account logging that nobody stitches together at the org level — incidents that cross accounts go undetected for days.

How it maps to other frameworks

Computed from shared tags, control component and key-operation subjects — handy when you are reconciling controls across an audit.

Related controls in NIST SP 800-171 Rev. 3

References

Topics: identity accesslogging monitoringprivileged accessidentity managementaccess review