3.3.3·high·Component: Audit and AccountabilityWhat this control requires
This control ensures the generation of audit records for the selected event types and content specified in previous controls. It also mandates the retention of these records for a time period consistent with the organization's records retention policy. The level of abstraction for audit records should be carefully selected to aid in identifying root causes of issues. This control supports the Audit Record Generation System capability within the Audit and Accountability (3.3) family.
In plain English
This control ensures the generation of audit records for the selected event types and content specified in previous controls. 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 3.3.3) 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.
Policy Management
Docs. Keep each policy in version-controlled Markdown alongside the code that implements it; ship a signed PDF snapshot at each annual review and link the SHA into the SoA.
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.
- System. Document the trigger, the owner and the cadence.
- Scope: management, content, time, generation.
Evidence to collect
- Policy Document. A signed and version-controlled policy / standard / procedure document.
- Infra Scan. Continuous infrastructure-posture telemetry — AWS Config, Azure Policy compliance, GCP Organisation Policy, Wiz / Prisma findings.
Signed policy or standard documents the safeguard. Focus: Audit Record Generation.
Common pitfalls
- Per-account logging that nobody stitches together at the org level — incidents that cross accounts go undetected for days.
- Policies that no engineer has read; the version in Confluence drifts from the version that's actually being enforced.
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.
- NIST SP 800-53 Rev. 5 AU-14 — Session Audit
- ISO/IEC 27001:2022 A.8.15 — Logging
- CIS Controls v8 8.1 — Establish and Maintain an Audit Log Management Process
- SOC 2 (2017 TSC) CC2.3 — External Communication on Internal Control Matters
- HIPAA (45 CFR Part 164) 164.528(c) — Provision of the Accounting
Related controls in NIST SP 800-171 Rev. 3
- Requirement 3.3.7 — Time Stamps
- Requirement 3.3.4 — Response to Audit Logging Process Failures
- Requirement 3.3.6 — Audit Record Reduction and Report Generation
- Requirement 3.3.5 — Audit Record Review, Analysis, and Reporting
- Requirement 3.13.10 — Cryptographic Key Establishment and Management
- Requirement 3.3.2 — Audit Record Content
References
- NIST Computer Security Resource Center — NIST SP 800-171 Rev. 3
- Catalogue identifier:
Requirement 3.3.3
Topics: governance risklogging monitoringlogging retentionpolicy managementprivileged access