PR.PS-04: Log records are generated and made available for continuous monitoring

The pr.ps-04: log records are generated and made available for continuous monitoring requirement is where “we log things” becomes a defensible control. Auditors and incident responders do not need every byte of telemetry; they need reliable, searchable records for the events that matter, across the assets that matter, with confidence that logs are complete enough to detect and investigate suspected misuse.

PR.PS-04 sits in NIST CSF 2.0’s Protect function and pushes you toward operational outcomes: (1) logs exist, (2) logs can be accessed by the monitoring function, and (3) monitoring is continuous in practice, not a quarterly screenshot exercise. ¹

For a CCO or GRC lead, the fastest path is to treat PR.PS-04 as a control package: a logging standard, a coverage map, a central collection mechanism (SIEM or log platform), and an evidence routine that proves “generated and available” every audit period. NIST CSF does not prescribe a single tool; it does expect repeatable execution aligned to your risk and environment. ¹

Regulatory text

Requirement (excerpt): “Log records are generated and made available for continuous monitoring.” ¹

Operator meaning: you must (a) configure systems to produce log records for relevant security and operational events, and (b) ensure those records are accessible to the team or capability responsible for ongoing monitoring (SOC, IT operations, or an outsourced monitoring third party). “Available” means timely access for search, correlation, alerting, and investigation, not “stored somewhere.” ¹

Where it comes from in NIST CSF 2.0: PR.PS-04 is a specific CSF 2.0 subcategory and is referenced in the CSF transition materials. ²

Plain-English interpretation

PR.PS-04 expects a closed loop:

1. Systems generate logs (endpoints, servers, identity, cloud, network, applications, databases, security tools).
2. Logs flow to a place your monitoring function can access (central log platform or equivalent).
3. Continuous monitoring uses those logs (detections, dashboards, investigations, and recurring review).
4. You can prove it with evidence that is consistent over time. ¹

If any part breaks (logs not enabled, ingestion failing, SOC can’t access, timestamps wrong, retention missing, alerting not wired), you are out of alignment with the requirement’s intent.

Who it applies to

Entity scope: any organization operating a cybersecurity program that uses NIST CSF 2.0 as a framework baseline, including regulated and non-regulated entities adopting CSF for governance. ¹

Operational contexts where PR.PS-04 becomes “exam critical”:

• You have centralized monitoring (internal SOC) or outsourced monitoring (MSSP/managed detection).
• You run hybrid environments (cloud + on-prem) and need consistent investigative records.
• You have third parties operating systems on your behalf (SaaS platforms, cloud hosting, outsourced IT) and need log access to support your monitoring and incident response expectations. ¹

Control owners typically involved:

• Security Operations (SIEM/monitoring), IAM team, Infrastructure/Cloud, App owners, GRC for control design and evidence.

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

Step 1: Define scope and a minimum log baseline

Create a “log coverage baseline” that answers two questions:

• Which assets must log? Start with identity systems, security tooling, critical applications, cloud control planes, privileged admin paths, and core network/security infrastructure.
• Which events must be captured? Focus on authentication, authorization/privilege changes, administrative actions, security policy changes, key application transactions, and security tool findings.

Deliverable: Logging Standard + Coverage Matrix (system → required logs/events → destination → owner). ¹

Step 2: Centralize collection and make it accessible for monitoring

Implement or validate:

• Collection pipelines from in-scope sources to a central repository (SIEM/log analytics).
• Access model so analysts can search and correlate logs (role-based access, break-glass for incident response).
• Time synchronization expectations so correlation works (document the standard even if enforcement is technical).
• Service reliability controls for log ingestion (alert on gaps and ingestion failures).

Deliverable: Data flow diagram (sources → collectors/agents → SIEM → monitoring/alerting) and access control listing for log platforms. ¹

Step 3: Protect log integrity and operationalize retention

PR.PS-04 is about availability for monitoring, but monitoring collapses if logs are untrustworthy. Operational minimums to document and implement:

• Limit who can disable logging or delete/modify log records.
• Separate duties: admins who operate systems should not be the only people who can alter logs about those systems.
• Define retention aligned to monitoring and investigation needs, then implement it in the platform configuration.

Deliverable: Log retention standard and platform configuration evidence (retention policies, immutability settings where available, admin roles). ¹

Step 4: Turn logs into continuous monitoring

“Continuous monitoring” needs defined use cases:

• Prioritize detections for identity abuse, privileged activity, malware signals, risky cloud configuration changes, and unusual access patterns.
• Establish dashboards and alert routes (ticketing, paging, or outsourced SOC workflow).
• Document triage and escalation paths (what happens when alerts fire).

Deliverable: Detection catalog (use case → log sources → query/rule → severity → response owner) and alert workflow artifacts. ¹

Step 5: Prove the control runs (recurring evidence)

Build a recurring evidence routine that answers what auditors ask first:

• Are the required sources logging?
• Are logs arriving within an acceptable window for monitoring?
• Are there ingestion gaps, and how were they handled?
• Did you review coverage when systems changed?

Daydream-style operationalization (tool-agnostic concept): map PR.PS-04 to a control owner, attach the logging standard and coverage matrix, and schedule recurring evidence pulls (SIEM health reports, source onboarding tickets, access reviews). This is the difference between “we have a SIEM” and “the PR.PS-04 control is operating.” ¹

Required evidence and artifacts to retain

Keep evidence in a way that shows design and operation:

Design artifacts

• Logging policy/standard (what must be logged; who owns it). ¹
• Log coverage matrix (source inventory mapped to required events and destinations).
• Monitoring use cases/detection catalog tied to log sources.
• Data flow diagram for log collection and monitoring access.

Operating evidence

• SIEM/log platform health reports (ingestion status, gap alerts).
• Screenshots or exports showing key sources are actively sending logs.
• Tickets/changes for onboarding new log sources and fixing ingestion failures.
• Access reviews for SIEM/log platform roles.
• Incident records demonstrating log search and investigation steps (sanitize as needed). ¹

Common exam/audit questions and hangups

What they ask	What they want to see	Common hangup
“Which systems are in scope for logging?”	A maintained inventory and rationale	Inventory exists, but logging scope is undocumented
“How do you know logs are complete and timely?”	Ingestion monitoring + gap handling	You only check during incidents
“Who can delete or alter logs?”	Role design + separation of duties	Too many admins; no review
“Show continuous monitoring.”	Alerting workflow + triage records	Alerts exist but no response evidence
“How do you handle third-party systems?”	Contract/SLA + access method + alternate telemetry	You rely on third party attestations without log access path

Frequent implementation mistakes (and how to avoid them)

1. Logging without a baseline. If you can’t name required sources/events, you can’t prove coverage. Fix: publish a minimum baseline and enforce it via onboarding checklists. ¹

2. Central SIEM exists, but key sources aren’t connected. Fix: treat “log source onboarding” as a control gate for production releases and new SaaS adoption.

3. No monitoring for ingestion failures. Fix: create alerts for “silent sources,” collector failures, and licensing/volume limits that drop events.

4. SOC cannot access needed logs quickly. Fix: pre-approve incident response roles and document break-glass access.

5. Third-party blind spots. Fix: for critical third parties, require audit logs and an access method (API/export/portal) that supports your monitoring and investigations. ¹

Risk implications (why PR.PS-04 fails in real incidents)

If logs are missing or inaccessible, you lose:

• Detection speed (threats persist longer before anyone sees them).
• Investigation quality (you cannot reconstruct actions or scope).
• Containment confidence (you do not know which accounts/systems were touched).
• Audit defensibility (you cannot evidence control operation). ¹

The practical risk is not theoretical: during incidents, “we think it happened” becomes “we can prove what happened” only if logging and access are already in place.

A practical 30/60/90-day execution plan

First 30 days (stabilize and scope)

• Assign PR.PS-04 control owner and backup.
• Publish a minimum logging baseline and a log coverage matrix template.
• Identify top critical log sources that must be connected (identity, EDR, cloud control plane, core network/security).
• Validate SOC/MSSP access to the log platform and document it. ¹

Next 60 days (connect and monitor)

• Onboard remaining in-scope sources per the matrix; track gaps with tickets and due dates.
• Implement ingestion health monitoring and escalation for missing logs.
• Define initial detection catalog tied to the log sources you have, and route alerts into your case/ticket workflow.
• Implement/administer log retention settings and document who can change them. ¹

By 90 days (operate and prove)

• Run a recurring control check: coverage review, access review, ingestion gap review, and a tabletop that verifies you can retrieve logs fast during an incident.
• Establish a change trigger: any new production system, major app release, or new third party must address logging requirements before go-live.
• Package evidence so an auditor can trace PR.PS-04 from policy → implementation → ongoing operation without interviews. ¹

Frequently Asked Questions

Do we need a SIEM to meet PR.PS-04?

NIST CSF 2.0 does not mandate a specific tool; it requires that log records are generated and available for continuous monitoring. A SIEM is a common way to meet the “available” and “monitoring” parts, but the key is accessible, searchable, and operationally used logs. ¹

What counts as “continuous monitoring” for this requirement?

Continuous monitoring means your organization regularly ingests and reviews logs through alerting and analyst workflows, not occasional spot checks. You should be able to show active detections, triage steps, and ingestion health checks. ¹

How do we handle SaaS and other third-party systems where we can’t install agents?

Require audit log access via native admin portals or APIs and define how logs will be exported or reviewed. If you cannot centralize logs, document an alternate monitoring method and how the monitoring team gets timely access during investigations. ¹

How much log retention is required?

PR.PS-04 does not specify a retention period in the provided NIST CSF sources. Set retention based on your investigation needs and any separate legal or regulatory obligations, then document and enforce it through platform configuration and evidence. ¹

Who should own PR.PS-04: Security Operations or GRC?

Security Operations typically owns implementation and daily operation because they manage log pipelines and monitoring. GRC should own control design, mapping, and evidence routines so you can prove operation consistently. ¹

What evidence is most persuasive in an audit?

Auditors respond well to a coverage matrix, SIEM ingestion/health reports, and a small set of representative alerts or cases showing that logs feed monitoring and response. Pair that with documented access controls and retention settings for the log platform. ¹

Footnotes

1. NIST CSWP 29

2. NIST CSF 1.1 to 2.0 Core Transition Changes