CMMC Level 2 Practice 3.3.2: Ensure that the actions of individual system users can be uniquely traced to those users, so

CMMC Level 2 Practice 3.3.2 requires you to make every security-relevant action attributable to one specific person (or approved system identity) through unique user IDs, tightly controlled shared/privileged access, and audit logs that connect actions to identities. To operationalize it fast, standardize identity sources, enforce unique accounts, centralize logging, and retain recurring evidence that proves traceability. ¹

Key takeaways:

• Unique identity is the control objective; logging is the proof mechanism. ¹
• Shared accounts, unmanaged admin access, and incomplete logs are the fastest paths to assessment findings. ¹
• Treat evidence as a recurring workflow: configuration screenshots/exports, sample logs, and access governance records. ²

If you handle CUI and must meet CMMC Level 2, you need a defensible answer to a simple assessor question: “Show me that a specific user action can be traced back to a specific user.” Practice 3.3.2 is the accountability backbone for incident response, insider threat investigations, and basic security hygiene. The requirement is mapped to NIST SP 800-171 Rev. 2 control 3.3.2 and is assessed in the context of the CMMC Program rule and guidance. ^{1 3 2}

Operationally, this is less about writing a policy and more about how identities, endpoints, servers, cloud services, and network devices generate logs, how those logs are protected, and how your team proves the control works on demand. Most teams stall because they implement pieces (like an SIEM) without closing identity gaps (shared accounts, local admins, service accounts without ownership). This page gives requirement-level, step-by-step guidance so you can implement traceability across your CUI boundary and keep evidence continuously ready for a CMMC Level 2 assessment. ²

Requirement: cmmc level 2 practice 3.3.2: ensure that the actions of individual system users can be uniquely traced to those users, so requirement

CMMC Level 2 Practice 3.3.2 expects you to (1) assign unique identities, (2) record actions in audit logs tied to those identities, and (3) operate the control so you can demonstrate traceability during assessment. The practice is mapped to NIST SP 800-171 Rev. 2 requirement 3.3.2. ^{1 2}

Regulatory text

Provided excerpt: “CMMC Level 2 practice mapped to NIST SP 800-171 Rev. 2 requirement 3.3.2 (Ensure that the actions of individual system users can be uniquely traced to those users, so).” ^{1 2}

Operator meaning: You must implement technical and administrative controls so that user actions on in-scope systems produce audit records that identify who performed the action. If you cannot link an event to a unique identity (because of shared accounts, missing logs, or poor identity hygiene), you have not met the practice. ¹

Plain-English interpretation

• Goal: Accountability. Every meaningful action in the CUI environment has an attributable actor. ¹
• Mechanism: Unique user accounts and audit logging that captures the user ID (and, where applicable, the source host, time, and action). ¹
• Assessment standard: You must demonstrate the control, not only describe it, under the CMMC Program. ^{3 2}

Who it applies to

Entities: Defense contractors and other federal contractors handling CUI who are pursuing or maintaining CMMC Level 2. ^{3 2}

Operational context (scope):

• Systems that store, process, or transmit CUI, plus supporting services that provide identity, access, administration, and logging for those systems. ¹
• Typical in-scope components: identity provider/directory, endpoints, servers, network devices, cloud control planes, remote access gateways, and security tooling that collects logs. ¹

What you actually need to do (step-by-step)

Step 1: Define “in-scope identity” and authoritative sources

1. Name the authoritative identity system for the CUI environment (for example, a directory service or cloud IdP) and document what is in scope. ¹
2. Inventory identity types you will see in logs:
   • Human users (employees, contractors)
   • Privileged administrators
   • Service accounts / workload identities
   • Break-glass accounts (if you allow them)
   • Third-party support identities (if permitted) ¹

Deliverable: an “Identity & Account Types” standard that defines naming conventions, ownership, and intended use. ²

Step 2: Enforce unique user identification (no ambiguity)

1. Disable or prohibit shared human accounts for normal operations. If a shared account is unavoidable for a business process, document the exception, add compensating controls, and ensure actions are still attributable (for example, mediated access through a jump host that logs the individual user). ¹
2. Prevent account re-use in a way that would confuse attribution (for example, reassigning an old username to a new hire without preserving identity history). Document your rule. ¹
3. Tie privileged access to named individuals via separate admin accounts or role-based access that still preserves individual attribution in logs. ¹

Deliverable: an account management procedure that explicitly states “one person, one account,” plus how exceptions work. ²

Step 3: Make sure audit logs actually capture the identity

1. Identify your “minimum traceability events.” Pick events an assessor will reasonably ask for: authentication events, privilege escalation, account management actions, remote access sessions, and access to key CUI repositories. ¹
2. Configure systems to log those events with the user identifier, timestamp, system name, and action result where available. Confirm that logs include the identity claim you expect (UPN/username, SID, cloud principal, etc.). ¹
3. Centralize log collection for in-scope systems so you can produce evidence quickly and reduce the risk of local log loss. ¹

Practical example (what “good” looks like): You can pick a user, show their login to the VPN/SSO, show their access to a CUI file share or repository, and show any admin actions performed through a privileged access path, all tied to the same unique identity. ¹

Step 4: Control privileged and third-party access paths

1. Route admin activity through controlled paths (jump server, privileged access management workflow, or tightly governed admin consoles) that preserve user attribution. ¹
2. For third-party support, require named accounts and log their sessions; avoid generic “vendoradmin” accounts. If the third party cannot support unique IDs, treat it as a security risk and redesign access. ¹

Step 5: Operationalize evidence capture (make it recurring)

1. Create a control narrative mapping Practice 3.3.2 to your identity and logging design. Keep it simple: systems in scope, what is logged, where logs go, who reviews, and how you respond to gaps. ²
2. Run a recurring traceability test: select a small set of recent events and demonstrate end-to-end attribution from log source to centralized storage. Record the test output as evidence. ²

Where Daydream fits naturally: teams often implement the tech but fail the assessment because evidence is inconsistent across systems. Daydream can track the Practice 3.3.2 control narrative, schedule recurring evidence pulls (exports/screenshots/log samples), and keep an assessor-ready package tied to the requirement language. ²

Required evidence and artifacts to retain

Keep evidence that proves both design (how it should work) and operation (it does work).

Core artifacts

• System Security Plan (SSP) statements describing how user actions are traced to unique identities for in-scope systems. ¹
• Account management standards/procedures: unique account rule, admin account rule, service account governance, third-party access approach. ¹
• Configuration evidence (screenshots/exports) showing:
  • Unique user account settings and directory integration
  • Logging settings enabled for key systems
  • Centralized logging/forwarding configuration ¹
• Sample audit logs that show user attribution for representative events (logon, admin action, access event). ¹
• Exception register for any shared accounts or legacy constraints, with compensating controls and an owner. ²

Common exam/audit questions and hangups

Assessors tend to probe for gaps where attribution breaks.

Questions you should be ready for

• “Show me an example of a user action and the log record that proves who did it.” ¹
• “Do you have any shared accounts in the CUI environment? If yes, how do you attribute actions?” ¹
• “How do you trace privileged actions back to a named administrator?” ¹
• “How do you handle service accounts? Who owns them, and how do you monitor use?” ¹
• “Can you produce logs if the endpoint is offline or compromised?” (Centralization and retention posture.) ¹

Hangups that cause findings

• Logs exist but are not searchable/exportable during the assessment window. ²
• Cloud activity logs are not enabled for key services, so control-plane actions are unattributed. ¹
• Admin actions occur via local accounts on endpoints/servers with inconsistent naming and no centralized correlation. ¹

Frequent implementation mistakes and how to avoid them

Mistake	Why it fails 3.3.2	Fix
Shared human accounts (“shopfloor”, “engineering”)	Actions cannot be uniquely attributed	Replace with named accounts; if impossible, mediate access through a system that logs the individual user. 1
Generic admin accounts	Privileged actions lack accountability	Separate admin identities per person or use role elevation that still records the individual. 1
Service accounts treated like humans	Ownership and expected behavior unclear	Assign an owner, define purpose, restrict where it can authenticate, and log use centrally. 1
Local logs only	Logs can be lost or tampered with	Forward to central logging and validate ingestion with test events. 1
Evidence collected once	Assessors evaluate current operation	Establish recurring evidence capture and keep it organized by requirement. 2

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so treat enforcement risk here as programmatic and contractual rather than case-driven. Under the CMMC Program rule and guidance, failure to demonstrate required practices can affect your ability to achieve or maintain the certification level required for contracts that involve CUI. ^{3 2}

Operational risk is straightforward: if you cannot trace actions to individuals, you slow investigations, weaken deterrence, and increase the chance that unauthorized access goes unresolved or unprovable. ¹

Practical execution plan (30/60/90-day)

Time-bound plans help, but the exact pace depends on your environment and contract timelines. Use these phases as a template, then map tasks into your change calendar. ²

First 30 days (Immediate stabilization)

• Identify the CUI boundary and in-scope systems for identity and logging. ¹
• Inventory all human, admin, shared, and service accounts in scope; flag shared accounts and unclear owners. ¹
• Confirm logging is enabled for identity/authentication sources and key repositories; start central collection where feasible. ¹
• Draft the control narrative and evidence checklist for 3.3.2. ²

By 60 days (Close attribution gaps)

• Eliminate shared human accounts or implement compensating controls that restore individual attribution. ¹
• Standardize privileged access (separate admin IDs, controlled admin paths, and consistent logging). ¹
• Implement service account governance: ownership, purpose, and monitoring expectations documented. ¹
• Run a traceability tabletop: pick several recent events and show end-to-end attribution from system to central logs. Save outputs as evidence. ²

By 90 days (Assessment-ready operation)

• Expand logging coverage to remaining in-scope systems and validate ingestion/field mapping (user identity present and consistent). ¹
• Operationalize recurring evidence capture (config exports + log samples + exception register updates) and assign owners. ²
• Conduct an internal mock interview for 3.3.2: have an operator produce proof live, using only documented procedures. ²

Frequently Asked Questions

Do shared accounts automatically fail CMMC Level 2 Practice 3.3.2?

Shared accounts create an attribution gap because actions are not uniquely tied to a person. If you keep an exception, you need compensating controls that restore traceability to an individual user. ¹

Do service accounts have to be “unique” too?

Yes, you must be able to trace actions to a specific identity, and service accounts are identities that act in systems. Assign ownership, define purpose, and ensure their actions are logged and reviewable. ¹

What logs should I show an assessor to prove traceability?

Provide representative authentication logs and activity logs that clearly include a unique user identifier tied to the action on an in-scope system. Pair that with configuration evidence showing logging is enabled and forwarded centrally. ¹

We use a third party for IT support. Can they use one generic admin login?

Generic admin logins undermine unique attribution. Require named third-party accounts and ensure their sessions/actions are logged so you can trace activity to an individual. ¹

Is central logging required for 3.3.2?

The requirement focuses on traceability, but central collection is a common way to prove logs are retained and accessible during assessment. If logs stay local, you still need a reliable method to produce them and protect their integrity. ¹

How do we operationalize evidence collection so it’s not a one-time scramble?

Treat 3.3.2 evidence as a recurring workflow: keep a control narrative, collect periodic config exports, store sample log queries, and maintain an exception register. Tools like Daydream can track owners and keep an assessor-ready evidence set per requirement. ²

Footnotes

1. NIST SP 800-171 Rev. 2

2. DoD CMMC Program Guidance

3. 32 CFR Part 170