3.3.4·high·Component: Audit and AccountabilityWhat this control requires
This control requires the organization to alert personnel within a defined time period if an audit logging process failure occurs. It also mandates additional response actions based on the nature of the failure, such as overwriting the oldest logs, shutting down the system, or stopping audit log generation. These actions ensure that audit logging continues or is appropriately managed during failures. This control supports the Audit Logging Failure Response System capability within the Audit and Accountability (3.3) family.
In plain English
This control requires the organization to alert personnel within a defined time period if an audit logging process failure occurs. In practice, this means you can prove you response 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 3.3.4) 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
- Response. 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.
- Personnel. Document the trigger, the owner and the cadence.
- Risk. Document the trigger, the owner and the cadence.
- Scope: management, time, generation, personnel, response.
Evidence to collect
- Policy Document. A signed and version-controlled policy / standard / procedure document.
Signed policy or standard documents the safeguard. Focus: Response to Audit Logging Process Failures.
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-5(2) — Real-Time Alerts
- ISO/IEC 27001:2022 A.8.15 — Logging
- BSI C5:2020 COM-02 — Policy for planning and conducting audits
- CIS Controls v8 8.2 — Collect Audit Logs
- SOC 2 (2017 TSC) CC2.3 — External Communication on Internal Control Matters
Related controls in NIST SP 800-171 Rev. 3
- Requirement 3.3.7 — Time Stamps
- Requirement 3.3.3 — Audit Record Generation
- Requirement 3.3.5 — Audit Record Review, Analysis, and Reporting
- Requirement 3.3.6 — Audit Record Reduction and Report Generation
- Requirement 3.11.4 — Risk Response
- Requirement 3.13.10 — Cryptographic Key Establishment and Management
References
- NIST Computer Security Resource Center — NIST SP 800-171 Rev. 3
- Catalogue identifier:
Requirement 3.3.4
Topics: governance risklogging monitoringpolicy management