03.03.02: Audit Record Content

To meet the 03.03.02: audit record content requirement, you must define and consistently capture the specific fields your logs need so investigators can reconstruct security-relevant events on systems that process, store, or transmit CUI. Operationally, this means standardizing audit record schemas across key log sources, validating field completeness, and retaining evidence that your logging configuration actually records required details ¹.

Key takeaways:

• Define a minimum audit record field set (who/what/when/where/how/result) and enforce it across log sources.
• Configure systems and centralized logging to record those fields for prioritized event types tied to CUI protection.
• Prove it with repeatable evidence: config exports, sample logs, and periodic completeness checks.

03.03.02 is easy to “claim” and hard to prove. Most environments already generate logs, but examiners and assessors look for something stricter: do your audit records contain the fields needed to answer basic investigative questions with confidence, and is that true across the systems in your CUI boundary? If a high-risk event occurs (privilege escalation, authentication anomaly, policy change), weak audit content turns incident response into guesswork and increases the chance you miss containment windows.

This requirement sits in the core auditability path for NIST SP 800-171 Rev. 3. It is not about collecting every possible log. It is about collecting the right fields, consistently, for events that matter, and being able to demonstrate that design and operation during assessments ¹. For a Compliance Officer, CCO, or GRC lead, the fastest way to operationalize 03.03.02 is to treat it as an engineering spec: define the required audit fields, map them to systems and event types, implement collection and normalization, then continuously test for completeness and drift.

Regulatory text

Regulatory excerpt (as provided): “NIST SP 800-171 Rev. 3 requirement 03.03.02 (Audit Record Content).” ¹

Operator interpretation: You must ensure audit records include sufficient content to support monitoring, detection, investigation, and accountability for actions affecting CUI and the systems that handle it ¹.

What an assessor expects you to show:

• You defined what “sufficient content” means for your environment (a documented minimum field set).
• Your key systems produce audit records that contain that content (configuration and sample outputs).
• You can sustain it over time (monitoring for dropped fields, schema changes, or log pipeline failures).

Plain-English interpretation (what 03.03.02 is really asking)

Your logs must answer the investigative basics without heroics:

• Who did it (user/service identity, and where relevant the acting process or role)?
• What happened (event type, object/resource, action performed)?
• When it happened (timestamp with timezone/normalization expectations)?
• Where it happened (host, system, application, source endpoint, network context)?
• How it happened (authentication method, protocol, client/app where applicable)?
• What was the result (success/failure, error codes, denied reason)?

If your audit records cannot reliably answer those questions for security-relevant events in your CUI boundary, you are not meeting the 03.03.02: audit record content requirement ¹.

Who it applies to (entity and operational context)

Entity scope

• Federal contractors and subcontractors operating nonfederal systems that handle CUI ¹.

Operational scope Apply 03.03.02 to:

• Systems inside the CUI boundary (endpoints, servers, identity, email, collaboration, cloud workloads, network/security tooling, and line-of-business apps that store/process/transmit CUI).
• Centralized logging and monitoring components (SIEM/log platform, collectors/agents, forwarders, parsing/normalization rules).
• Security-relevant administrative planes (IAM, PAM, MDM, hypervisors, cloud control planes) if they can change access to CUI systems.

A common scoping failure: treating 03.03.02 as “a SIEM control.” It is a system control plus logging architecture control ¹.

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

Step 1: Define a minimum audit record content standard

Create a one-page “Audit Record Minimum Content Standard” that lists required fields and acceptable mappings. Keep it practical, for example:

Minimum fields (example schema)

• event_time (normalized; include original time)
• event_type (login, privilege change, policy change, object access, etc.)
• subject_id (user/service principal)
• subject_type (human/service)
• actor_session_id (where available)
• src_ip / src_host
• dest_host / system / application
• object (file, mailbox, record, configuration item)
• action (read/write/delete/create/modify/execute)
• result (success/failure)
• reason / error_code (where available)
• privilege_level or role context (where relevant)
• correlation_id / trace id (for apps)

You do not need every field for every event. You do need a documented rule for what must be present for each event category ¹.

Step 2: Identify event categories that must meet the standard

Build a short list of “must-log” security event categories tied to CUI protection. Typical categories:

• Authentication events (interactive and non-interactive)
• Account lifecycle and privilege/role changes
• Access to CUI repositories or systems of record
• Administrative configuration changes (security policies, audit settings, logging agents)
• Remote access and VPN events
• Security tool alerts and enforcement actions (EDR blocks, DLP actions)

Document this as an “Audit Event Coverage Matrix” that maps categories to systems.

Step 3: Inventory log sources in the CUI boundary and map field availability

For each in-scope system, record:

• Log source name and owner
• Log transport method (agent, syslog, API)
• Native fields available vs. required fields
• Gaps (for example, missing user identity on a legacy app)
• Compensating approach (app change, reverse proxy logs, identity provider logs)

This matrix becomes your primary assessment artifact because it shows intent, design, and coverage.

Step 4: Configure systems to emit the required content

Implementation is system-specific. Your job is to ensure engineering has explicit acceptance criteria:

• Enable appropriate audit categories on OS, identity platforms, SaaS/cloud services, and key applications.
• Ensure logs include identity attributes (user, service account, role), source context (IP/host), and object/action context for CUI access where feasible.
• Protect against “logging drift” by managing audit configuration as code or via controlled baselines.

Step 5: Normalize and preserve fields in the log pipeline

Many teams “collect” the right fields, then lose them during parsing. Fix this at the pipeline layer:

• Confirm parsers do not drop key fields.
• Maintain a canonical schema or mapping table (source_field → normalized_field).
• Tag events with system, environment, and CUI-boundary identifiers so you can scope searches during an incident.

Step 6: Test completeness with repeatable checks

Do not rely on screenshots alone. Add an operational test:

• Generate a known event (failed login, group membership change, access to a CUI folder).
• Verify the audit record contains required fields end-to-end (source system → collector → SIEM).
• Record evidence and schedule periodic re-tests after upgrades or logging rule changes.

Step 7: Operationalize ownership, exceptions, and change control

You need named owners:

• Security owns the standard and the monitoring logic.
• System owners own enabling/maintaining audit settings.
• GRC owns the control narrative, evidence calendar, and exception register.

Track exceptions explicitly (system cannot log object IDs, SaaS limitation) with compensating controls and an expiration date.

Required evidence and artifacts to retain

Assessors typically want “design + implementation + operation” proof. Keep:

• Policy/standard: Audit Record Minimum Content Standard (approved, versioned).
• Audit Event Coverage Matrix: event categories mapped to in-scope systems, with field gap notes.
• Configuration evidence: exports of audit policy settings, logging agent configs, SIEM parser rules, and log source onboarding settings.
• Sample audit records: redacted examples showing required fields for representative event categories.
• Test records: runbooks and results of completeness tests (including failed tests and remediation tickets).
• Exception register: documented gaps, compensating controls, and timelines.
• Change records: tickets/CRs for changes to audit settings, parsers, and log routing.

Tip: Store evidence by “control requirement” so you can answer 03.03.02 directly, rather than dumping generic SIEM evidence.

Common exam/audit questions and hangups

Expect these lines of questioning:

• “Show me a log for a failed login and point to the user, source, target, timestamp, and result.”
• “Show me a privileged role change event and how you identify the actor and the change.”
• “Which systems in the CUI boundary do not meet your minimum field set, and why?”
• “How do you know parsers didn’t drop fields after the last update?”
• “Who approves changes to audit configuration and how do you detect audit logging being disabled?”

Hangup pattern: teams show that “logging exists,” but cannot demonstrate field-level sufficiency across systems ¹.

Frequent implementation mistakes (and how to avoid them)

1. Mistake: No documented minimum field set.
   Fix: Publish a standard and tie it to event categories and log sources.

2. Mistake: Assuming SIEM ingestion equals compliance.
   Fix: Validate end-to-end field preservation from source to search interface.

3. Mistake: Logging only perimeter/network devices.
   Fix: Prioritize identity, endpoints, admin planes, and CUI repositories.

4. Mistake: “We’ll fix gaps during incidents.”
   Fix: Treat missing fields as a blocking defect; create exceptions with compensating controls.

5. Mistake: Evidence is screenshots without context.
   Fix: Add config exports and a repeatable test script with dated results.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this specific requirement, so this page does not cite case outcomes.

Operationally, weak audit record content increases:

• Investigation risk: you cannot reconstruct the sequence of actions around CUI access.
• Containment risk: delays in identifying the actor, affected systems, and actions taken.
• Assessment risk: inability to demonstrate field-level logging sufficiency ¹.

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

Use phases rather than day-count commitments. Adjust based on system count and logging maturity.

First phase: Immediate stabilization

• Name an owner for the audit record content standard and for each major log source.
• Draft and approve the minimum field set and event categories.
• Identify the CUI boundary systems and create the initial Audit Event Coverage Matrix.
• Pick representative “proof events” for testing (auth failure, privilege change, CUI access).

Second phase: Near-term implementation

• Enable/adjust audit settings on the highest-risk systems (identity, CUI repositories, admin planes).
• Fix parsing/normalization to retain required fields.
• Build saved searches or reports that display required fields for proof events.
• Start an exception register for systems with logging limitations and assign remediation tasks.

Third phase: Operationalization and readiness

• Run completeness tests on a recurring cadence and after material changes.
• Add monitoring for logging disablement, collector failures, and schema drift.
• Package evidence for assessors: standard, matrix, configs, sample logs, test results, exceptions.
• If you use Daydream, map 03.03.02 to your policy/control narrative and schedule recurring evidence pulls so the control stays assessment-ready ¹.

Frequently Asked Questions

What is the fastest way to prove compliance with the 03.03.02: audit record content requirement?

Keep a documented minimum field set, then show sample logs for key event categories with those fields present end-to-end. Pair that with config exports and a repeatable completeness test record ¹.

Do all log sources need to include every required field for every event?

No. You need defined rules that specify which fields are required per event category and log source, plus documented exceptions when a system cannot produce a field ¹.

How do we handle SaaS systems that don’t provide object-level audit details?

Document the limitation in an exception register and capture the closest available fields (actor, action, time, target system, result). Add compensating visibility from identity provider logs, CASB, or downstream application logs where feasible ¹.

Are screenshots of SIEM dashboards enough evidence?

Rarely. Screenshots can support narratives, but assessors typically expect configuration evidence and raw or exported sample events that show field content clearly ¹.

What’s the most common technical failure mode for 03.03.02?

Field loss during parsing and normalization. The source system logs the right attributes, but the collector or SIEM parser drops or overwrites them, so the searchable record becomes incomplete.

How should we scope 03.03.02 if only part of our environment handles CUI?

Apply the standard to systems in the defined CUI boundary and to the admin/identity components that control access to those systems. Keep the boundary definition and system inventory aligned so the logging scope is defensible ¹.

Footnotes

1. NIST SP 800-171 Rev. 3