NIST SP 800-171 Rev. 3·Requirement 3.3.2·high·Component: Audit and Accountability

What this control requires

This control requires the inclusion of specific content in audit records, such as the event type, time, location, source, outcome, and associated identities of individuals or entities. It also allows for the inclusion of additional details to support the auditing function, such as event success or failure indicators and detailed descriptions of privileged commands or user identities. This control supports the Audit Record Configuration capability within the Audit and Accountability (3.3) family.
— NIST SP 800-171 Rev. 3, Requirement 3.3.2

In plain English

This control requires the inclusion of specific content in audit records, such as the event type, time, location, source, outcome, and associated identities of individuals or entities. 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 3.3.2) 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.
  • Audit Record. Document the trigger, the owner and the cadence.
  • Time. Document the trigger, the owner and the cadence.
  • Configuration. Document the trigger, the owner and the cadence.
  • Scope: management, configuration, content, event type, time, location, source, outcome.

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: Audit Record Content.

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: privileged accessidentity managementaccess reviewlogging monitoring