13 Jul 2026CMMC Phase II suspended: no C3PAO assessments can be designated. DFARS 7012 and Rev 2 still apply.What changed, and what did not

NIST SP 800-171 Rev 2 · 3.3 Audit & Accountability

3.3.1 System audit logs

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.
SPRS weight
5
5 points deducted from 110 when not implemented.
CMMC level
L2
Level 2 only; not among the 17 Level 1 practices.
Assessment objectives
6
From NIST SP 800-171A, each one a “determine if” an assessor answers.

What an assessor checks

NIST SP 800-171A breaks 3.3.1 into 6 objectives. Every one has to be met for the requirement to be met; a partial answer scores as not implemented.

  1. [a]Determine if audit logs needed (i.e., event types to be logged) to enable the monitoring, analysis, investigation, and reporting of unlawful or unauthorized system activity are specified.
  2. [b]Determine if the content of audit records needed to support monitoring, analysis, investigation, and reporting of unlawful or unauthorized system activity is defined.
  3. [c]Determine if audit records are created (generated).
  4. [d]Determine if audit records, once created, contain the defined content.
  5. [e]Determine if retention requirements for audit records are defined.
  6. [f]Determine if audit records are retained as defined.
Examine
[SELECT FROM: Audit and accountability policy; procedures addressing auditable events; security plan; system design documentation; system configuration settings and associated documentation; system audit logs and records; system auditable events; system incident reports; other relevant documents or records].
Interview
[SELECT FROM: Personnel with audit and accountability responsibilities; personnel with information security responsibilities; system or network administrators].
Test
[SELECT FROM: Mechanisms implementing system audit logging].

If it is open: POA&M eligibility

Not POA&M-eligible: above the 1-point ceiling · 5 points deducted

Worth 5 points. No requirement over 1 point may appear on a Level 2 POA&M, so this has to be closed before the assessment.

A POA&M is only permitted at a score of 88 or above, and closes in one 180-day window. Check a full gap list or compute your score.

Where 3.3.1 maps

NIST SP 800-53 Rev 5

  • AU-1 Audit and Accountability Policy
  • AU-2 Audit Events
  • AU-3 Content of Audit Records
  • AU-4 Audit Storage Capacity
  • AU-11 Audit Record Retention
  • AU-12 Audit Generation
  • AU-14 Session Audit

NIST CSF 2.0

  • Audit log records are determined and documented Audit Logging
  • Audit log records are implemented

SOC 2

  • CC4 Monitoring Activities - Ongoing and separate evaluations

Query it from your own tools

This page and the MacTech CMMC MCP server render the same dataset. Ask your assistant and it will answer from the methodology, not from memory.

lookup_control 3.3.1
get_assessment_objectives 3.3.1
generate_poam_entries ["3.3.1"]

Install the MCP server, free, no account.

From MacZine

Working notes on Audit & Accountability

The full run →