1Overview
AU.L2-3.3.1 opens the Audit and Accountability family and is one of the most heavily weighted requirements in the framework. It requires that the system create and retain audit logs sufficient to monitor, analyze, investigate, and report unlawful or unauthorized activity. It is a five-point requirement that cannot be deferred on a plan of action, because without records of what happened, none of the later audit controls have anything to work with.
Auditing is the system's memory. When something goes wrong, a compromised account, a file taken, a control bypassed, the audit record is what allows the organization to see that it happened, understand how, and respond. This control is the foundation of that memory: it asks the organization to decide what events must be logged, define what each record must contain, generate those records, and retain them long enough to be useful. The word "sufficient" is doing real work, because logs that capture too little, or are discarded too soon, cannot support the monitoring and investigation the rest of the family depends on.
Create and retain system audit logs and records to the extent needed to enable the monitoring, analysis, investigation, and reporting of unlawful or unauthorized system activity.
The requirement has two connected parts: create and retain. To create is to log the event types that matter, with records that carry enough content, the who, what, when, where, and outcome, to be meaningful. To retain is to keep those records for a defined period so they are available when an investigation needs them. The five-point weight reflects that audit records are the evidence base for the entire family, and an environment that does not generate and keep them is blind to its own history.
2The Assessment Objectives
NIST SP 800-171A decomposes 3.3.1 into six objectives: specify the event types, define the record content, generate the records, confirm they carry the content, define retention, and retain accordingly.
Audit logs needed to enable monitoring, analysis, investigation, and reporting of unlawful or unauthorized activity are specified. The organization has decided which event types must be logged.
The content of audit records needed to support monitoring, analysis, investigation, and reporting is defined. The organization has decided what each record must contain.
Audit records are created. The system actually generates the records for the specified events.
Audit records, once created, contain the defined content. The records actually carry the content defined in objective [b].
Retention requirements for audit records are defined. The organization has decided how long records must be kept.
Audit records are retained as defined. The records are actually kept for the defined period.
The six objectives pair definition with execution across three subjects: what to log, what each record holds, and how long to keep them. The common gap is at objectives [e] and [f], retention, where logs are generated but roll over within days, so by the time an incident is noticed the relevant records are gone. The assessor looks for records that are both sufficiently detailed and retained long enough to matter.
3Failure Patterns
The failures are about logging too little, records that lack content, and retention too short to be useful.
Default logging only
Where nothing has been specified, systems log whatever their defaults capture, which may omit the very events an investigation needs. Objective [a] calls for a deliberate decision about what to log, connected to the ability to detect unauthorized activity, rather than leaving it to product defaults.
Records that cannot answer the question
A log entry that records an event but not the user, the source, or the outcome cannot support an investigation, so it fails the content objectives even though logging is on. Records have to carry enough to reconstruct who did what, when, from where, and with what result.
Logs that roll over too soon
The most common audit failure is short retention: logs that overwrite within days on local systems, so that by the time an incident surfaces the records are gone. Centralizing logs and defining a retention period long enough to cover the gap between an event and its discovery is what resolves this.
Systems left out of logging
Where some systems that handle CUI generate no audit records at all, those systems are blind spots. The specified logging has to reach the systems in scope, not only the ones that were convenient to configure.
4Ownership
This is an IT-owned technical control, and its main demands are deciding what to log and building retention that outlasts the delay between an event and its discovery.
| Role | Responsibility for this control |
|---|---|
| IT and system administrator | Specifies the events to log, configures record content, ensures records are generated on all in-scope systems, and builds retention. Owns the technical evidence. |
| Security or compliance lead | Defines what logging is needed to detect unauthorized activity and sets the retention period appropriate to investigation needs. |
| Program lead | Confirms logging reaches every system in scope and includes audit coverage in periodic review, retaining the configuration and retention records. |
5Tooling
The control is delivered by the logging built into the systems and by central collection that gives the records a retained home.
| Objectives | Tooling | What it provides |
|---|---|---|
| [a], [b] | Audit policy, Windows advanced audit configuration | The specified event types and defined record content applied consistently across systems. |
| [c], [d] | System and application logging on in-scope hosts | Generation of records carrying the defined content on every system that handles CUI. |
| [e], [f] | Central log collection or SIEM, defined retention | A retained, central home for records that outlasts local rollover and keeps history available. |
| Coverage | Inventory-driven logging verification | Confirmation that logging reaches all in-scope systems, closing blind spots. |
The caveat is that logging locally is not the same as retaining usefully. Local logs roll over, so central collection with a defined retention period is usually what actually satisfies objectives [e] and [f]. The assessor examines what is logged, what the records contain, and how long they are kept, so all three have to hold together across the systems in scope.
6Evidence
The satisfied version of 3.3.1 shows specified events, defined and present record content, and retained records across the environment.
| Evidence | What it demonstrates |
|---|---|
| Audit logging policy | Objectives [a], [b], [e]. The specified events, defined content, and retention period. |
| Sample audit records | Objectives [c], [d]. Records that exist and carry the defined content. |
| Central log configuration | Objectives [e], [f]. Collection and retention keeping records for the defined period. |
| Coverage confirmation | Objective [c]. Evidence that logging reaches all in-scope systems. |
The evidence should show that the right events are logged, that the records carry enough to investigate, and that they are kept long enough to be there when needed. Configuration plus sample records plus a central retention setup, spanning the systems in scope, is the clearest demonstration, and because this control cannot sit on a plan of action, the logging has to be real and retained at the time of assessment.
You cannot investigate what you did not record
Auditing is a five-point control because it is the evidence base for detecting and responding to everything else, and the usual gap is retention: logs that roll over before an incident is even noticed. Deciding what to log, capturing enough in each record, and keeping the records long enough to matter is part of the onsite readiness work this practice does, and it is one of the controls that must be met rather than deferred.
Start CMMC Readiness or call 802-335-26627Sources
- NIST Special Publication 800-171 Rev 2, Protecting Controlled Unclassified Information in Nonfederal Systems and Organizations, requirement 3.3.1. csrc.nist.gov
- NIST Special Publication 800-171A, Assessing Security Requirements for Controlled Unclassified Information, assessment objectives 3.3.1[a] through 3.3.1[f]. csrc.nist.gov
- 32 CFR 170.24, CMMC Scoring Methodology, listing AU.L2-3.3.1 among the five-point basic security requirements. ecfr.gov