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Home The CMMC Guide Part III · Audit and Accountability AU.L2-3.3.1
The CMMC Guide · Audit and Accountability Family

AU.L2-3.3.1  System Audit Logging

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.

Family
Audit and AccountabilityAU, 9 requirements
Point Value
5Highest weight in the methodology
POA&M Eligible
NoCannot remain open at assessment
Objectives
SixPer NIST SP 800-171A

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.

The requirement · NIST SP 800-171 Rev 2, 3.3.1

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.

[a]

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.

MeetsA defined set of event types to log: logons, privilege use, access to CUI, configuration changes, and security-relevant actions.
FailsNo event types are specified, so logging is whatever each system happens to do by default.
[b]

The content of audit records needed to support monitoring, analysis, investigation, and reporting is defined. The organization has decided what each record must contain.

MeetsRecord content is defined to include the user, action, timestamp, source, and outcome, so a record is meaningful on its own.
FailsRecord content is undefined, so logs may omit the user or the outcome and cannot support an investigation.
[c]

Audit records are created. The system actually generates the records for the specified events.

MeetsThe specified events are logged across the systems in scope, so the records exist.
FailsLogging is disabled or absent on systems that handle CUI, so events go unrecorded.
[d]

Audit records, once created, contain the defined content. The records actually carry the content defined in objective [b].

MeetsThe generated records contain the user, action, timestamp, source, and outcome as defined.
FailsRecords are generated but lack the defined fields, so they cannot answer who did what.
[e]

Retention requirements for audit records are defined. The organization has decided how long records must be kept.

MeetsA defined retention period appropriate to investigation needs and any applicable requirements.
FailsNo retention is defined, so logs roll over and disappear at whatever the default happens to be.
[f]

Audit records are retained as defined. The records are actually kept for the defined period.

MeetsRecords are retained for the defined period, often centrally, so they are available when needed.
FailsRecords exist briefly but are overwritten before the defined period, so history is lost.

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.

The common root
This control fails on retention more than on generation. Systems log by default, but the records roll over quickly, and since incidents are usually noticed well after they happen, the records that would explain them are already gone. Defining retention and keeping the logs is what turns momentary logging into usable memory.

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.

RoleResponsibility for this control
IT and system administratorSpecifies 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 leadDefines what logging is needed to detect unauthorized activity and sets the retention period appropriate to investigation needs.
Program leadConfirms logging reaches every system in scope and includes audit coverage in periodic review, retaining the configuration and retention records.
See also: This control is the foundation the rest of the Audit and Accountability family builds on, feeding the traceability of AU.L2-3.3.2, the review of AU.L2-3.3.3, and the protection of records at 3.3.8.

5Tooling

The control is delivered by the logging built into the systems and by central collection that gives the records a retained home.

ObjectivesToolingWhat it provides
[a], [b]Audit policy, Windows advanced audit configurationThe specified event types and defined record content applied consistently across systems.
[c], [d]System and application logging on in-scope hostsGeneration of records carrying the defined content on every system that handles CUI.
[e], [f]Central log collection or SIEM, defined retentionA retained, central home for records that outlasts local rollover and keeps history available.
CoverageInventory-driven logging verificationConfirmation 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.

EvidenceWhat it demonstrates
Audit logging policyObjectives [a], [b], [e]. The specified events, defined content, and retention period.
Sample audit recordsObjectives [c], [d]. Records that exist and carry the defined content.
Central log configurationObjectives [e], [f]. Collection and retention keeping records for the defined period.
Coverage confirmationObjective [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.

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7Sources

  1. NIST Special Publication 800-171 Rev 2, Protecting Controlled Unclassified Information in Nonfederal Systems and Organizations, requirement 3.3.1. csrc.nist.gov
  2. 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
  3. 32 CFR 170.24, CMMC Scoring Methodology, listing AU.L2-3.3.1 among the five-point basic security requirements. ecfr.gov
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About the Author
David W. Koran is a CyberAB Registered Practitioner Advanced and the author of The CMMC Decision, now in its second edition. He works onsite with defense contractors and their counsel, from the first leadership briefing through the pre-assessment review. Reach him at 802-335-2662 or dkoran@davidkoran.com.
Entry AU.L2-3.3.1 · Edition 2026.1 · Last reviewed July 12, 2026