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Requirements 3.3

3.3 Audit and Accountability: the NIST SP 800-171 requirements

The 9 requirements of family 3.3, Audit and Accountability, in NIST SP 800-171 Rev 2, worth 19 points of a SPRS score under 32 CFR 170.24. For each: NIST's text, what it costs when not met, the objectives an assessor determines under NIST SP 800-171A, and how to meet it. To mark each one and work out your score, use the free calculator.

3.3.1 System Auditing

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.

Points: 5 points.

Assessment objectives (NIST SP 800-171A)

  • [a]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.
  • [b]The content of audit records needed to support monitoring, analysis, investigation, and reporting of unlawful or unauthorized system activity is defined.
  • [c]Audit records are created (generated).
  • [d]Audit records, once created, contain the defined content.
  • [e]Retention requirements for audit records are defined.
  • [f]Audit records are retained as defined.
How to meet it

Enable audit logging on domain controllers, servers, firewalls, VPN, and cloud tenants (Microsoft 365 unified audit log is often off by default: turn it on today), and ship logs to central storage with retention of at least 90 days online and one year archived. A low-cost SIEM or log platform (Microsoft Sentinel, Wazuh, Graylog) fits small-contractor budgets. Document which event types you log and why. Evidence: the logging standard, retention configuration, and a sample query pulling events across sources.

3.3.2 User Accountability

Ensure that the actions of individual system users can be uniquely traced to those users so they can be held accountable for their actions.

Points: 3 points.

Assessment objectives (NIST SP 800-171A)

  • [a]The content of the audit records needed to support the ability to uniquely trace users to their actions is defined.
  • [b]Audit records, once created, contain the defined content.
How to meet it

Eliminate shared and generic logons so every action traces to a person: give each user and each admin a uniquely named account, and where shared service accounts are unavoidable, restrict them to non-interactive use. Verify your logs actually capture username on key events. Evidence: account listing showing no shared interactive accounts and sample log entries tied to named individuals.

3.3.3 Audit Review and Reporting

Review and update logged events.

Points: 1 point.

Assessment objectives (NIST SP 800-171A)

  • [a]A process for determining when to review logged events is defined.
  • [b]Event types being logged are reviewed in accordance with the defined review process.
  • [c]Event types being logged are updated based on the review.
How to meet it

Schedule a periodic (at least annual) review of which event types you log, adjusting for new systems, new threats, and gaps found during incidents, and record the outcome even when the conclusion is "no change." This is a lightweight documented process, not a tool purchase. Evidence: the review procedure and dated meeting notes or tickets showing the reviews occurred.

3.3.4 Audit Failure Alerting

Alert in the event of an audit logging process failure.

Points: 1 point.

Assessment objectives (NIST SP 800-171A)

  • [a]Personnel or roles to be alerted in the event of an audit logging process failure are identified.
  • [b]Types of audit logging process failures for which alert will be generated are defined.
  • [c]Identified personnel or roles are alerted in the event of an audit logging process failure.
How to meet it

Configure alerts for logging failures: SIEM heartbeat/agent-offline alerts, disk-space thresholds on log volumes, and notifications when a log source goes silent. Define in writing who receives the alert and what they do. Most SIEMs can do this with a built-in rule, making it a same-day fix once central logging exists. Evidence: the alert rule configuration and a test alert with the response documented.

3.3.5 Audit Correlation

Correlate audit record review, analysis, and reporting processes for investigation and response to indications of unlawful, unauthorized, suspicious, or unusual activity.

Points: 5 points.

Assessment objectives (NIST SP 800-171A)

  • [a]Audit record review, analysis, and reporting processes for investigation and response to indications of unlawful, unauthorized, suspicious, or unusual activity are defined.
  • [b]Defined audit record review, analysis, and reporting processes are correlated.
How to meet it

Bring your key log sources into one place where they can be reviewed together: a SIEM correlating firewall, identity, and endpoint events, or at minimum a documented weekly review that examines them side by side. Enable built-in correlation/analytics rules (impossible travel, brute force followed by success) as quick wins. Evidence: the SIEM data source list, enabled correlation rules, and dated review notes.

3.3.6 Audit Reduction

Provide audit record reduction and report generation to support on-demand analysis and reporting.

Points: 1 point.

Assessment objectives (NIST SP 800-171A)

  • [a]An audit record reduction capability that supports on-demand analysis is provided.
  • [b]A report generation capability that supports on-demand reporting is provided.
How to meet it

Provide the ability to filter and summarize audit data on demand: saved SIEM queries, dashboards, or scheduled reports that reduce raw logs to reviewable summaries (failed logons by user, admin actions by system). Build a handful of saved searches for your most common investigation questions. Evidence: screenshots of the saved queries/dashboards and a sample generated report.

3.3.7 Time Stamps

Provide a system capability that compares and synchronizes internal system clocks with an authoritative source to generate time stamps for audit records.

Points: 1 point.

Assessment objectives (NIST SP 800-171A)

  • [a]Internal system clocks are used to generate time stamps for audit records.
  • [b]An authoritative source with which to compare and synchronize internal system clocks is specified.
  • [c]Internal system clocks used to generate time stamps for audit records are compared to and synchronized with the specified authoritative time source.
How to meet it

Point all systems at an authoritative time source: domain-joined machines sync to the domain controller, which syncs to NTP (e.g., NIST or pool servers); configure network gear and standalone hosts to the same source. Spot-check clock drift across systems as verification. This is usually a one-hour configuration task. Evidence: NTP configuration on the DC and network devices, and log samples showing consistent timestamps.

3.3.8 Audit Record Protection

Protect audit information and audit logging tools from unauthorized access, modification, and deletion.

Points: 1 point.

Assessment objectives (NIST SP 800-171A)

  • [a]Audit information is protected from unauthorized access.
  • [b]Audit information is protected from unauthorized modification.
  • [c]Audit information is protected from unauthorized deletion.
  • [d]Audit logging tools are protected from unauthorized access.
  • [e]Audit logging tools are protected from unauthorized modification.
  • [f]Audit logging tools are protected from unauthorized deletion.
How to meet it

Restrict access to log storage and SIEM consoles to a named security/admin group, make collected logs append-only or forward them off-host so a compromised system's attacker cannot erase their tracks, and enable immutability or retention locks where your platform supports them. Evidence: ACLs on log repositories, SIEM role assignments, and retention/immutability settings.

3.3.9 Audit Management

Limit management of audit logging functionality to a subset of privileged users.

Points: 1 point.

Assessment objectives (NIST SP 800-171A)

  • [a]A subset of privileged users granted access to manage audit logging functionality is defined.
  • [b]Management of audit logging functionality is limited to the defined subset of privileged users.
How to meet it

Limit who can change audit policy, clear logs, or administer the SIEM to a small named subset of your privileged users: ideally different people than those being audited, or with alerting on audit-config changes as a compensating measure in tiny teams. Evidence: the SIEM admin role membership list and GPO/permission settings restricting audit policy changes.

Sources

The requirement text and the assessment objectives are NIST's, a work of the U.S. government. The titles and "how to meet it" are Edwards Consulting Group's. None of it is legal advice: the clauses in your contract decide what applies to you.