03.03.03: Audit Record Generation

To meet the 03.03.03: audit record generation requirement, you must configure systems that process, store, or transmit CUI to automatically create audit records for defined security-relevant events, and you must prove those logs are actually being generated and collected. Operationalize it by setting an event logging standard, enabling logs across in-scope platforms, and retaining repeatable evidence for assessors. ¹

Key takeaways:

• Define which events must be logged, then enable audit record generation consistently across all CUI in-scope systems. ¹
• Treat “enabled logging” as insufficient; you need evidence that logs are being produced, forwarded, and reviewable on demand. ¹
• Document scope, event coverage, and exceptions; assessors will look for gaps between your standard and real configurations. ¹

03.03.03 sits in the Audit and Accountability family and is one of the controls that fails quietly. Teams often believe they “have logging” because a SIEM exists or because default logs are on, then discover during a CUI assessment that key systems were never configured to generate the needed audit records, or that logs exist only on a few servers.

For a Compliance Officer, CCO, or GRC lead, the fastest path is to translate this requirement into a tight, testable statement: for each in-scope system, audit records must be generated for your defined set of security-relevant events, in a way that supports investigation and accountability. Then you operationalize that statement with three things: (1) a logging standard that names required events and minimum record fields, (2) technical implementation across endpoints, identity, network, cloud, and apps that touch CUI, and (3) standing evidence that demonstrates the control works in production.

NIST SP 800-171 is widely used to protect Controlled Unclassified Information (CUI) in nonfederal systems. This page focuses on requirement-level execution so you can assign owners, implement quickly, and be ready to defend the control in an assessment. ¹

Regulatory text

Requirement: “NIST SP 800-171 Rev. 3 requirement 03.03.03 (Audit Record Generation).” ¹

Operator interpretation (what you must do):

• Ensure each in-scope system is configured to generate audit records (logs) for the security-relevant events you define for your environment. ¹
• Ensure audit records are generated in a way that supports accountability and downstream monitoring/investigation (for example, records are accessible and can be correlated across systems). This is an operational expectation implied by the purpose of audit records within the Audit and Accountability family. ¹

What assessors typically test here: They look for (1) a defined event set, (2) proof that audit records are produced on real systems, and (3) evidence that scope is complete for CUI systems, not just “critical servers.” ¹

Plain-English interpretation

03.03.03 means: your systems must create logs that show what happened, who did it, and when, for the events you’ve decided matter for security and compliance. If something suspicious occurs (account misuse, privileged changes, policy tampering, authentication failures), you should be able to reconstruct actions from audit records rather than guess.

This requirement is about generation. Retention, protection, review, correlation, and time synchronization are usually handled by other audit-related requirements, but you should design generation with those downstream needs in mind so you do not produce incomplete or unusable records. ¹

Who it applies to (entity and operational context)

Applies to:

• Federal contractors and subcontractors, and other organizations operating nonfederal systems handling CUI. ¹

Operational scope (what systems are “in”):

• Any system that processes, stores, or transmits CUI, plus supporting components that provide identity, administration, or security monitoring for those systems (for example: identity provider, endpoint management, jump hosts, bastions, key security tools). ¹

Third-party reality check: If CUI touches third-party SaaS or a managed service, you still need assurance that audit records are generated for relevant events in those services. That becomes a due diligence and contract requirement, plus evidence collection for assessment. ¹

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

Step 1: Freeze the control statement into a “logging standard”

Create a short “Audit Record Generation Standard” scoped to CUI systems. Keep it testable.

Include:

• In-scope system categories: endpoints, servers, network devices, cloud control plane, identity provider, applications handling CUI, databases/storage, security tooling. ¹
• Required event categories (your minimum set). A practical baseline most operators adopt includes:
  • Authentication events (success/failure), session creation, logout
  • Privileged activity (role changes, admin actions, sudo/use of elevated tokens)
  • Account lifecycle (create/disable/delete), password/MFA changes
  • Access to CUI repositories (read/write/delete/export) where technically feasible
  • Security configuration changes (policy changes, logging disabled, agent removed)
  • System/service starts/stops and critical errors for systems that host CUI
• Minimum fields per audit record: timestamp, actor identity, source system, target resource, action, outcome (success/failure), and a correlation identifier when available.

You are not trying to predict every possible event. You are defining what “good enough” means and what you will enforce across the estate. ¹

Step 2: Build a CUI system inventory mapped to log sources

You cannot prove generation without a scope list.

Create a table with columns:

• System name / asset ID
• CUI touchpoint (process/store/transmit/supporting)
• Platform type (Windows, Linux, firewall, IdP, SaaS, PaaS)
• Log source mechanism (agent, API, native forwarder)
• Owner (system + logging owner)
• Status (enabled / partially enabled / blocked)
• Exception record (if any)

This becomes your assessment backbone and drives remediation work. ¹

Step 3: Turn on audit record generation per platform, not per team preference

Execute enablement in platform-native ways, then standardize collection.

Common patterns:

• Identity provider: enable sign-in logs, admin audit logs, risky sign-ins if available, and export/forwarding to your central logging platform.
• Endpoints/servers: enable OS audit policy categories aligned to your standard; ensure EDR telemetry does not replace OS audit logs if the EDR is configurable or optional.
• Network/security devices: enable configuration change logs and authentication logs for administrative access; forward via syslog or vendor connectors.
• Cloud: enable control-plane audit logs (for example, API calls) and data-plane logs where feasible for CUI stores.
• Applications: ensure app logs include authentication/authorization decisions and access to CUI objects when feasible.

Your job as GRC lead: require consistency and document deviations with a formal exception, owner, and timeline. ¹

Step 4: Prove generation with “show me” tests

For each log source type, run a small test script and capture evidence:

• Attempt a failed login, verify a failed-auth record exists.
• Create or disable a test account, verify an audit record exists.
• Perform a privileged action in a controlled way, verify an admin/audit event exists.
• Change a logging setting (in a test environment if needed), verify it is logged.

Record: date/time, tester, system, action performed, log excerpt, and where it is stored/queried. ¹

Step 5: Operationalize recurring evidence collection (assessment-ready)

Create a recurring evidence package that you can regenerate without heroics:

• Monthly (or aligned to your internal cadence): export a sample of log events per system category.
• Quarterly: rerun generation tests on a representative sample plus any new systems.
• On change: require a logging checklist in change management for any new CUI system or major upgrade.

This is where Daydream fits naturally: map 03.03.03 to owners, tie it to the CUI system inventory, and schedule evidence pulls so your audit trail stays current instead of being rebuilt under deadline pressure. ¹

Required evidence and artifacts to retain

Keep evidence tight and directly tied to 03.03.03:

1. Audit Record Generation Standard (approved, versioned). ¹
2. CUI system inventory with log-source mapping (exportable list). ¹
3. Configuration evidence for each platform category (screenshots, exported settings, CLI outputs, policy objects). ¹
4. Sample audit records showing required events and minimum fields (redact sensitive data). ¹
5. Test records (“performed action” + “resulting log entry”). ¹
6. Exception register for gaps (system, reason, compensating control, target date, owner approval). ¹
7. Third-party evidence where CUI touches external services (SOC reports if available, platform audit log exports, contract clauses, shared responsibility notes). ¹

Common exam/audit questions and hangups

Expect these questions in a CUI-focused assessment:

• “Show me your defined list of auditable events. Where is it documented and approved?” ¹
• “Which systems are in scope for CUI, and how do you know logging is enabled on all of them?” ¹
• “Demonstrate a privileged change and the resulting audit record.” ¹
• “How do you handle SaaS where you can’t install an agent?” (Answer: native audit logs + API export + contract requirements + compensating monitoring.) ¹
• “What happens if someone disables logging?” (This touches other controls, but for 03.03.03 you must show that configuration changes are themselves logged where feasible.) ¹

Frequent implementation mistakes and how to avoid them

Mistake	Why it fails 03.03.03	How to avoid
“We have a SIEM” as the only claim	Collection is not proof that each in-scope system generates audit records	Maintain per-system log-source mapping and generation tests. 1
Partial scope (servers only)	CUI access often happens via identity, SaaS, endpoints, and cloud control planes	Tie scope to the CUI data flow and identity boundary, not just infrastructure. 1
Logs exist but miss key fields	Records that can’t attribute actor/action/time reduce accountability	Set minimum fields in your standard; validate with samples. 1
No exception discipline	“Temporary” gaps become permanent and surface during assessment	Run an exception register with approvals and deadlines. 1
Treating third-party systems as out of scope	CUI in external platforms still needs audit records	Put audit logging obligations in contracts and collect artifacts. 1

Enforcement context and risk implications

NIST SP 800-171 itself is a standard, but it is commonly embedded in contractual and program requirements for handling CUI. If you cannot generate audit records, you lose investigation capability and may not be able to support incident response, insider threat inquiries, or contractual compliance assertions tied to CUI handling. ¹

Risk shows up in two places:

• Operational risk: delayed detection and weak root-cause analysis because actions cannot be reconstructed from logs. ¹
• Assurance risk: assessment findings due to missing evidence that logs are produced across the full CUI system boundary. ¹

A practical 30/60/90-day execution plan

First 30 days (stabilize scope and standards)

• Confirm CUI system boundary and publish the initial CUI system inventory with owners.
• Draft and approve the Audit Record Generation Standard (event categories + minimum fields + platforms).
• Identify top log-source gaps (systems with no feasible logging path or unclear ownership).
• Set an evidence folder structure and naming convention; start capturing “current state” configs.

Days 31–60 (enable and validate generation)

• Implement logging enablement on highest-risk/highest-coverage platforms first: identity, endpoints, admin access paths, and CUI repositories.
• Configure forwarding/export to your central logging location where possible.
• Run “show me” tests and store the results as formal evidence.
• Open exceptions for systems that cannot meet the standard yet; assign remediation owners.

Days 61–90 (make it repeatable)

• Add a logging checklist to change management for new CUI systems.
• Create recurring evidence tasks (sample log extracts, periodic generation tests).
• Run an internal mini-assessment: pick a random in-scope system from each category and verify event generation end-to-end.
• If you use Daydream, map 03.03.03 to the standard, inventory, owners, and scheduled evidence so assessors can trace requirement → control → implementation → proof. ¹

Frequently Asked Questions

What’s the difference between “audit record generation” and “log retention”?

03.03.03 focuses on whether required audit records are created in the first place. Retention, protection, and review are separate operational needs that often live in adjacent audit/accountability requirements. ¹

Do we have to log access to every single CUI file?

NIST SP 800-171 Rev. 3 does not provide a file-by-file prescription in the provided excerpt. A practical approach is to log authentication, authorization decisions, and access to CUI repositories or systems at the level your platforms support, then document gaps and exceptions. ¹

How do we handle SaaS platforms where we can’t install agents?

Use the provider’s native audit logs and export them via available connectors or APIs, then keep evidence of configuration and sample records. Add contractual language requiring audit logging support for CUI-relevant events. ¹

What evidence is strongest for assessors?

Pair configuration exports (showing audit settings enabled) with “show me” tests that produce specific log entries for defined events. Tie both back to your inventory and logging standard. ¹

Can we meet 03.03.03 with EDR-only telemetry?

Possibly, if the EDR reliably generates audit records for your defined event set across all in-scope systems and you can prove coverage with evidence. Document exactly which events are covered and where gaps exist. ¹

Who should own this control: Security, IT, or GRC?

GRC should own the requirement mapping, standard, and evidence plan; IT/Security own implementation on platforms; system owners must resolve gaps. Assign each log source a named technical owner in the inventory. ¹

Footnotes

1. NIST SP 800-171 Rev. 3