3.3.6·high·Component: Audit and AccountabilityWhat this control requires
This control mandates the implementation of an audit record reduction and report generation capability to support audit record review, analysis, and after-the-fact incident investigations. It ensures the preservation of the original content and time ordering of audit records while enabling meaningful summaries and customizable reports for analysts. This control supports the Audit Record Reduction and Reporting capability within the Audit and Accountability (3.3) family.
In plain English
This control mandates the implementation of an audit record reduction and report generation capability to support audit record review, analysis, and after-the-fact incident investigations. In practice, this means you can prove you audit record 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 3.3.6) and look for objective evidence on the latest two assessment cycles.
How to implement
Incident Response
Runbook. Maintain a runbook keyed by incident type with named roles (IC, comms, scribe), an out-of-band comms channel, and a 72-hour timeline for external notification.
Tabletop. Run a quarterly tabletop exercise (ransomware, insider, supply-chain) and feed gaps back into the runbook.
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
- Audit Record. Document the trigger, the owner and the cadence.
- Response. Document the trigger, the owner and the cadence.
- Time. Document the trigger, the owner and the cadence.
- Incident. Document the trigger, the owner and the cadence.
- Risk. Document the trigger, the owner and the cadence.
- Scope: management, content, time, generation, analysis, response.
Evidence to collect
- Ticketing Workflow.
ticketing_workflowevidence
Workflow metrics (ServiceNow, Jira) show approvals and remediation. Focus: Audit Record Reduction and Report Generation.
Common pitfalls
- Runbooks that name a role but no person, or list a paging channel that no longer exists.
- 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.
- SOC 2 (2017 TSC) CC7.4 — Incident Response
- NIST SP 800-53 Rev. 5 AU-2 — Event Logging
- BSI C5:2020 OPS-21 — Involvement of Cloud customers in the event of incidents
- CIS Controls v8 17.4 — Establish and Maintain an Incident Response Process
- ISO/IEC 27001:2022 A.5.8 — Information security in project management
Related controls in NIST SP 800-171 Rev. 3
- Requirement 3.3.3 — Audit Record Generation
- Requirement 3.3.4 — Response to Audit Logging Process Failures
- Requirement 3.6.4 — Incident Response Training
- Requirement 3.3.5 — Audit Record Review, Analysis, and Reporting
- Requirement 3.6.2 — Incident Monitoring, Reporting, and Response Assistance
- Requirement 3.3.7 — Time Stamps
References
- NIST Computer Security Resource Center — NIST SP 800-171 Rev. 3
- Catalogue identifier:
Requirement 3.3.6
Topics: governance riskincident responsechange managementlogging monitoring