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

3.3.9 Limit audit management to privileged users

Limit management of audit logging functionality to a subset of privileged users.
SPRS weight
1
1 point 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 3.3.9 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 a subset of privileged users granted access to manage audit logging functionality is defined.
  2. [b]Determine if management of audit logging functionality is limited to the defined subset of privileged users.
Examine
[SELECT FROM: Audit and accountability policy; access control policy and procedures; procedures addressing protection of audit information; security plan; system design documentation; system configuration settings and associated documentation; access authorizations; system-generated list of privileged users with access to management of audit logging functionality; access control list; system audit logs and records; other relevant documents or records].
Interview
[SELECT FROM: Personnel with audit and accountability responsibilities; personnel with information security responsibilities; system or network administrators; system developers].
Test
[SELECT FROM: Mechanisms managing access to audit logging functionality].

If it is open: POA&M eligibility

May be carried on a Level 2 POA&M · 1 point deducted

A 1-point requirement outside the six named exclusions - eligible to carry, and NOT MET until a closeout assessment confirms it.

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 3.3.9 maps

NIST SP 800-53 Rev 5

No direct mapping.

NIST CSF 2.0

  • Audit log records are implemented

SOC 2

No direct mapping.

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 3.3.9
get_assessment_objectives 3.3.9
generate_poam_entries ["3.3.9"]

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From MacZine

Working notes on Audit & Accountability

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