CMMC Level 2 Practice 3.3.9: Limit management of audit logging functionality to a subset of privileged users

Audit logs are only trustworthy if the people who can change, disable, or erase them are tightly controlled. CMMC Level 2 Practice 3.3.9: limit management of audit logging functionality to a subset of privileged users requirement is designed to prevent a common failure mode: a broad admin population that can tamper with the very records you rely on for incident response, investigations, and contractual compliance.

For a CCO, GRC lead, or security program owner, the fastest path is to treat this as an access control requirement with clear scoping: identify where audit logs live across your CUI environment, list the functions that count as “managing audit logging,” assign those functions to a small set of roles, and continuously prove that only those roles have the rights. CMMC assessments reward clean, consistent permission models and simple narratives supported by screenshots/exports and change tickets. ¹

This page gives requirement-level implementation guidance you can hand to IT and validate through evidence. It focuses on operational steps, artifacts to retain, and the exam questions that commonly stall teams.

Regulatory text

Requirement (mapped): CMMC Level 2 practice mapped to NIST SP 800-171 Rev. 2 requirement 3.3.9: “Limit management of audit logging functionality to a subset of privileged users.” ²
Program context: CMMC Level 2 assessments measure implementation of NIST SP 800-171 Rev. 2 practices for protecting CUI. ³

Operator meaning: You must (1) define what “management of audit logging functionality” means in your environment, (2) restrict those permissions to a limited set of privileged roles/users, and (3) keep evidence that the restriction is enforced and reviewed. ²

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Plain-English interpretation

“Management of audit logging functionality” is anything that can reduce log completeness, integrity, or availability. In practice, this includes:

• Turning auditing on/off, changing audit policy categories, or changing what events are logged.
• Editing log destinations (local vs centralized), forwarding rules, SIEM connectors/agents.
• Clearing logs, reducing retention, changing rotation settings, or modifying timestamps.
• Changing who can read or export logs if that enables cover-up or data loss.

“Subset of privileged users” means a small, named set of administrative roles with a business need to administer logging, not a broad “IT Admins” bucket and not default global administrators everywhere. ²

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Who it applies to (entity and operational context)

Applies to:

• Defense contractors and federal contractors handling CUI in environments in-scope for CMMC Level 2. ³

Operationally, it applies wherever audit logs are generated or controlled in the CUI boundary, typically:

• Identity platforms (AD/Azure AD/Entra ID), endpoint OS (Windows/Linux), servers, databases.
• Network security devices (firewalls, VPN, IDS/IPS), email/security gateways.
• Cloud control planes (AWS CloudTrail, Azure Activity Logs, M365 audit logging).
• Central logging/SIEM platforms and log collectors/agents.

If a third party operates any of these components for you (managed SOC, MSP, cloud admin), this requirement still applies. You must ensure the third party’s staff access is restricted, justified, and evidenced the same way you would for employees. ¹

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

1) Define “audit log management” actions for your environment

Create a short internal definition that assessors can follow. Keep it concrete, such as:

• “Audit log management includes changing audit policy, log sources, log forwarding, log retention, log deletion/clearing, and access control to audit configuration.” Tie this definition to systems in the CUI boundary. ²

Deliverable: “Audit Logging Management Definition & Scope” (one page is enough).

2) Inventory the systems that control logging

Build a list (spreadsheet is fine) of:

• Log sources (endpoints, servers, firewalls, cloud services).
• Log management/control points (GPO, local policy, EDR console, SIEM, cloud audit services).
• Who administers each today (groups/roles, not just names).

Tip: Focus on the “control planes” first (GPO, SIEM, cloud audit services). That’s where the highest-impact permissions usually live.

3) Design a minimal role model (RBAC) for logging administration

Define a few roles with clean separation:

• Security Logging Administrator: can configure logging, connectors, retention.
• Security Analyst (Read-Only): can search/view logs, create detections, export for investigation.
• System Administrator (No log admin): can administer servers/endpoints but cannot disable auditing or clear logs without escalation.

Keep it simple and defensible. “Subset” is easiest to prove when roles are narrow. ²

4) Implement least privilege in each platform

Apply the role model across your stack:

Windows / AD

• Control audit policy centrally via GPO.
• Restrict rights that allow clearing logs or changing audit policy to the smallest feasible admin groups.

Linux

• Restrict access to audit daemon configuration and log directories.
• Ensure only authorized admin groups can change audit rules and log rotation settings.

SIEM / Central logging

• Separate “platform admins” from “content users.”
• Limit who can disable collectors, delete data, change retention, or stop ingestion.

Cloud (AWS/Azure/M365)

• Use cloud IAM roles to limit who can change audit logging services, retention, or diagnostic settings.
• Avoid assigning broad “Owner/Global Admin” for day-to-day operations when narrower roles exist.

Control objective: A standard sysadmin should not be able to stop auditing or delete/alter audit records without being in the logging admin subset. ²

5) Add change control for audit logging configuration

Make audit logging configuration a controlled configuration item:

• Changes require a ticket, approver, and documented rationale.
• Emergency changes still get documented after the fact.

This step is where many programs get audit traction: it proves “subset” plus governance, and it creates a paper trail. ¹

6) Establish recurring access reviews for the privileged subset

Run periodic reviews of:

• Membership of logging admin groups/roles.
• Cloud role assignments for audit logging services.
• SIEM administrative privileges.

Document:

• Who reviewed, what they reviewed, what changed, and the date of completion.

7) Prove it continuously with evidence capture

Don’t wait for assessment month. Capture exports/screenshots after key changes and on a recurring cadence, then store them in your GRC repository with a clear naming convention. Daydream can help by mapping CMMC 3.3.9 to the exact evidence your assessor asks for and scheduling recurring evidence pulls so you are not rebuilding proof under deadline. ¹

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Required evidence and artifacts to retain

Keep evidence that answers two questions: “Who can manage logging?” and “How do you know it stays restricted?”

Minimum recommended artifacts:

• Policy/standard defining audit log management functions and privileged role requirements. ²
• Role definitions (RBAC matrix) mapping platforms → roles → allowed actions (configure/disable/clear/retention/forwarding).
• Current access lists (exports/screenshots) showing:
  • Group memberships for logging admin roles.
  • SIEM admin role assignments.
  • Cloud IAM role bindings for audit logging services.
• Configuration evidence demonstrating restriction:
  • GPO or platform configuration showing who can change audit policy / clear logs.
  • SIEM retention and delete permissions limited to subset.
• Change tickets for audit logging configuration changes, with approvals.
• Access review records showing periodic review and remediation actions. ¹

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Common exam/audit questions and hangups

Assessors and internal auditors tend to press on these points:

1. “Define ‘management’ in your environment.”
   If you can’t list the actions, you can’t prove you restricted them. Bring your definition and RBAC matrix. ²

2. “Show me who can clear logs or reduce retention.”
   Be ready with platform screenshots/exports showing delete/retention permissions.

3. “Do your sysadmins have implicit rights via broad admin roles?”
   This is where “Domain Admins can do anything” becomes a finding. You need a design narrative and compensating restrictions where the platform makes perfect separation hard.

4. “How do you control third-party admin access?”
   Have contracts/SSP narrative and access lists for MSP/SOC staff who can manage logging.

5. “How do you detect or govern changes to logging?”
   Tickets, approvals, and periodic reviews are the easiest evidence to present. ¹

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Frequent implementation mistakes and how to avoid them

Mistake 1: Treating log viewers as log managers

Many teams give analysts admin rights “because it’s easier.” Split read-only search from admin configuration in the SIEM and cloud consoles.

Avoidance: Implement separate roles; require escalation for configuration changes.

Mistake 2: Leaving “break glass” accounts unconstrained

Emergency accounts often end up with permanent broad rights and no monitoring.

Avoidance: Keep break-glass credentials tightly stored, require approval to use, and document each use as a change event.

Mistake 3: Overreliance on a single policy statement

A policy that says “only security manages logs” without access control proof will not carry the requirement.

Avoidance: Pair policy with role assignments, config screenshots, and review records. ²

Mistake 4: Ignoring cloud audit controls

Teams secure Windows logging but forget who can disable CloudTrail/Activity Logs/M365 auditing.

Avoidance: Include cloud audit services in the inventory and RBAC matrix and export IAM role assignments.

Mistake 5: No operational cadence for evidence

Evidence gathered once will drift.

Avoidance: Put role membership exports and logging configuration checks on a recurring schedule and store them centrally for assessment readiness. Daydream is well suited for this “recurring evidence capture” workflow because it ties the practice to specific artifacts and review intervals without turning prep into a one-off project. ¹

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Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this specific practice. ¹

Operational risk remains straightforward:

• If too many people can disable logging or clear logs, you lose investigation quality and may fail to demonstrate control operation during a CMMC Level 2 assessment. ⁴

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A practical 30/60/90-day execution plan

First 30 days (stabilize scope and access)

• Define “audit log management” actions and write the one-page scope statement. ²
• Inventory log control points in the CUI boundary (GPO, SIEM, cloud audit services, key network devices).
• Identify current privileged groups/roles that can disable logging, clear logs, or change retention.
• Implement quick wins: remove non-essential admins from SIEM/cloud audit admin roles; create a dedicated “Logging Admin” group if one does not exist.

Days 31–60 (standardize roles and governance)

• Publish RBAC matrix and align each platform’s role assignments to it.
• Add change control requirements for audit logging configuration (ticket + approval + evidence snapshot).
• Implement separation of duties in the SIEM (read-only analyst vs admin).
• Establish an access review procedure and owner for privileged logging roles. ¹

Days 61–90 (prove repeatability)

• Run the first formal access review; document results and removals.
• Collect a complete evidence set (policy, RBAC matrix, role exports, config screenshots, change tickets, review record).
• Dry-run the assessor walkthrough: “Here are the systems, here are the privileged subsets, here is how changes are controlled.” Fix gaps found in the walkthrough.
• Operationalize recurring evidence capture in your GRC system (or Daydream) so the next review cycle is routine rather than a scramble. ¹

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Frequently Asked Questions

Does “subset of privileged users” mean a specific number of administrators?

No number is stated in the requirement text. The practical test is whether the set is demonstrably limited to those with a job need and enforced through roles and permissions. ²

Are SIEM administrators in scope for 3.3.9?

Yes, if they can change collection, retention, deletion, or audit-related configuration, they are managing audit logging functionality. You should separate SIEM content users from SIEM platform admins. ²

If Domain Admins can always change logging, will we fail?

Assessors will focus on whether your design and operation limit routine log management to a controlled subset and whether broad privileges are justified and governed. Document the rationale, minimize membership, and back it with access reviews and change records. ¹

Does this control require centralized logging?

The practice is about restricting management of logging functions, not prescribing an architecture. Centralized logging can simplify access control and evidence, but you still must restrict who can administer the logging pipeline. ²

How do we handle a managed SOC or MSP that administers our logging tools?

Treat the managed provider’s admin access as privileged access. Keep named accounts, role assignments, and evidence that only approved provider personnel have log-management rights, plus ticketed change control for configuration changes. ¹

What evidence is fastest to produce for an assessment?

An RBAC matrix plus current role membership exports/screenshots from your SIEM and cloud/IAM, paired with a small sample of approved change tickets for audit logging configuration. That package shows both design and operation. ¹

Footnotes

1. DoD CMMC Program Guidance

2. NIST SP 800-171 Rev. 2

3. 32 CFR Part 170; DoD CMMC Program Guidance

4. NIST SP 800-171 Rev. 2; DoD CMMC Program Guidance