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

3.3.2 User accountability in audit records

Ensure that the actions of individual system users can be uniquely traced to those users so they can be held accountable for their actions.
SPRS weight
3
3 points deducted from 110 when not implemented.
CMMC level
L2
Level 2 only; not among the 17 Level 1 practices.
Assessment objectives
2
From NIST SP 800-171A, each one a “determine if” an assessor answers.

What an assessor checks

NIST SP 800-171A breaks 3.3.2 into 2 objectives. Every one has to be met for the requirement to be met; a partial answer scores as not implemented.

  1. [a]Determine if the content of the audit records needed to support the ability to uniquely trace users to their actions is defined.
  2. [b]Determine if audit records, once created, contain the defined content.
Examine
[SELECT FROM: Audit and accountability policy; procedures addressing audit records and event types; security plan; system design documentation; system configuration settings and associated documentation; system audit logs and records; system 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 · 3 points deducted

Worth 3 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 3.3.2 maps

NIST SP 800-53 Rev 5

  • AU-1 Audit and Accountability Policy
  • AU-2 Audit Events
  • AU-3 Content of Audit Records
  • AU-10 Non-Repudiation
  • AU-12 Audit Generation
  • AU-14 Session Audit
  • AU-16 Cross-Organizational Auditing

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 3.3.2
get_assessment_objectives 3.3.2
generate_poam_entries ["3.3.2"]

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From MacZine

Working notes on Audit & Accountability

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