03.03.05: Audit Record Review, Analysis, and Reporting

To meet the 03.03.05: audit record review, analysis, and reporting requirement, you must routinely review audit logs, analyze them for suspicious or noncompliant activity, and report actionable findings to the right owners so they can respond. Operationalize it by defining what gets reviewed, at what cadence, with what detection logic, and what evidence proves the reviews happened. ¹

Key takeaways:

• You need a repeatable log review + analysis + reporting workflow, not just “logs exist.” ¹
• Evidence must show who reviewed what, when, what they found, and what actions followed. ¹
• Scope must match your CUI environment and the systems that support it, including security tooling and identity layers. ¹

03.03.05 sits in the part of NIST SP 800-171 that examiners use to separate “we collect logs” from “we can detect and respond.” The requirement expects your program to (1) look at audit records, (2) interpret them to identify anomalies or policy violations, and (3) communicate results to people who can take action. That communication step is where many teams fail: they either bury findings in a ticket queue with no tracking, or they produce a dashboard that no one owns.

For a CCO, compliance officer, or GRC lead, the fast path is to treat this as an operational control with clear inputs and outputs: defined log sources, defined review triggers, defined analysis rules, and defined reporting recipients and SLAs. Your goal is to prove two things during an assessment: coverage (the right systems are in scope) and operation (reviews happen, findings are triaged, and issues are tracked to closure). This page gives you a practical way to stand up that machinery quickly for a nonfederal system handling CUI. ¹

Regulatory text

Requirement: “NIST SP 800-171 Rev. 3 requirement 03.03.05 (Audit Record Review, Analysis, and Reporting).” ¹

What the operator must do: establish a documented, recurring process to review audit records, analyze them for indicators of inappropriate activity or control failure, and report results to the teams responsible for response and remediation. The requirement is about ongoing oversight and escalation, not the technical capability to generate logs. ¹

Plain-English interpretation

03.03.05 expects you to answer, consistently and with evidence:

• Are you looking at the logs that matter?
• Are you interpreting them for security and compliance signals (not just storing them)?
• Do the right people learn about meaningful events quickly enough to act? ¹

If your environment can generate audit records but no one reviews them, or reviews are ad hoc, you will struggle to defend compliance. If reviews happen but findings don’t flow into incident response or problem management, you will also struggle.

Who it applies to (entity and operational context)

Entities: federal contractors and other organizations operating nonfederal systems that handle Controlled Unclassified Information (CUI). ¹

Operational context (where this control lives):

• The “CUI environment” and supporting services: identity provider, endpoint security, EDR, SIEM/log platform, email security, file storage, network security controls, and administrative access paths.
• Central IT plus any business unit that runs systems in scope for CUI handling.
• Third parties matter if they operate or manage in-scope systems; your contract and oversight should ensure audit records and reporting are available to you for compliance and security operations.

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

1) Define scope and log sources (write it down)

Create a Log Source Register for the CUI environment:

• Systems: endpoints, servers, cloud workloads, network devices, applications that store/process CUI
• Security systems: EDR, email security, DLP (if used), vulnerability tooling
• Identity & admin: IdP, MFA, PAM (if used), directory services
• Logging platform: SIEM or centralized log store (if used)

Control test: can you show an assessor a list of in-scope sources and confirm they feed audit records suitable for review and analysis? ¹

2) Set review objectives tied to risks you care about

Document the “why” in operational terms. Examples:

• Detect unauthorized access attempts to CUI repositories
• Detect privilege escalation or admin logins from unusual contexts
• Detect disabled logging, audit policy changes, or agent tampering
• Detect policy violations (e.g., blocked data transfer attempts if monitored)

Keep this aligned to your threat model and CUI processing reality, but stay concrete: each objective should map to log sources and detection content. ¹

3) Establish review cadence and triggers (recurring + event-driven)

Write a Log Review SOP with two lanes:

• Recurring reviews: scheduled checks by role (SOC, IT security, or designated reviewer) for high-value sources.
• Event-driven reviews: immediate review triggered by alerts such as suspected compromise, privileged access changes, or integrity warnings from logging infrastructure.

Avoid vague wording like “periodically.” Pick a cadence you can sustain and defend, then enforce it through workflow and evidence collection. ¹

4) Build analysis rules: what “good” looks like in your environment

Analysis should include at least:

• Baseline expectations: normal admin login patterns, normal access paths to CUI repositories, normal volume of authentication failures.
• Detection logic: correlation rules, alert thresholds, or queries that map to your objectives.
• Triage criteria: what counts as informational vs. needs investigation vs. becomes an incident.

If you do not have a SIEM, you can still comply with a smaller footprint using native logging + scheduled queries + documented review output. The key is disciplined analysis and reporting, not a specific tool category. ¹

5) Define reporting paths and accountability

Create a Reporting and Escalation Matrix:

• Audience: SOC/IT security, system owners, compliance/GRC, incident response lead
• What gets reported: confirmed incidents, suspicious activity, control failures (e.g., logging gaps), and trends that require remediation
• How tracked: ticketing system with severity, owner, due date, closure notes

Reporting must be actionable. A dashboard with no ownership does not meet the spirit of “reporting.” ¹

6) Prove operation: connect findings to remediation

Your workflow should end with one of:

• closed as benign with justification
• remediation ticket for configuration fix
• incident record and response actions
• third-party escalation if an external provider owns the system/control

This is where Daydream typically fits naturally: map 03.03.05 to policy, control statements, and recurring evidence pulls so you can demonstrate operation without chasing screenshots at audit time. ¹

Required evidence and artifacts to retain

Keep artifacts that show design and operation:

Design artifacts

• Audit Logging & Monitoring Policy (covers review, analysis, and reporting expectations) ¹
• Log Review SOP (roles, cadence, triggers, escalation) ¹
• Log Source Register / System inventory for CUI environment ¹
• Reporting & Escalation Matrix (who receives what, and how it’s tracked) ¹

Operational artifacts

• Review records (exported reports, query outputs, or review checklists) with reviewer name, date, scope, and results ¹
• Alert/ticket samples showing triage notes, assignment, and closure ¹
• Incident records tied to audit log detections (where applicable) ¹
• Evidence of follow-up: remediation changes, configuration updates, third-party communications ¹

Common exam/audit questions and hangups

Expect assessors to probe these areas:

1. “Show me what you reviewed.”
   They will ask for specific log sources and recent review outputs, not a policy excerpt. ¹

2. “Who is responsible?”
   If “everyone” owns review, no one owns it. Name a role, backup role, and escalation owner. ¹

3. “How do you analyze vs. just collect?”
   They will look for queries, correlation rules, alert logic, baselines, and triage criteria. ¹

4. “Do findings go anywhere?”
   Tickets, incident records, and remediation evidence matter. Reporting means action. ¹

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails	Fix that works in practice
Logging exists, but no documented review	Cannot prove review and analysis occurred 1	Create a recurring review job with saved outputs and named reviewers 1
“We have a SIEM” as the whole story	Tool presence ≠ operational control 1	Document detections, triage steps, reporting, and ticket closure evidence 1
Scope gaps (IdP/admin access not included)	Most meaningful audit signals sit in identity and privileged access	Put identity, admin actions, and logging system integrity in the Log Source Register 1
No link to incident response	Findings do not drive response	Add escalation triggers and require incident/ticket linkage in the SOP 1
Evidence is screenshots only	Hard to scale, weak traceability	Prefer exported reports, query outputs, and tickets with immutable timestamps 1

Enforcement context and risk implications

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

Operationally, weak audit record review creates predictable risk: you may miss unauthorized access to CUI, fail to detect account compromise, and discover incidents late. For a contractor, that becomes a contractual and customer trust issue even before it becomes a regulatory dispute. Aligning 03.03.05 with incident response and problem management reduces that exposure. ¹

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

Use phases (not calendar promises) so you can execute based on current maturity.

First 30 days (stabilize scope + minimum viable operation)

• Identify CUI systems and build the first Log Source Register draft. ¹
• Publish a short Log Review SOP with named roles, recurring review cadence, and event-driven triggers. ¹
• Run and document initial reviews for your highest-value sources (identity, CUI repositories, endpoints). Save outputs as evidence. ¹
• Stand up a reporting path: tickets or cases with owners and closure notes. ¹

Next 60 days (improve analysis quality + reporting discipline)

• Add baseline expectations and triage criteria to reduce noise and reviewer fatigue. ¹
• Expand log source coverage to remaining in-scope systems and critical third-party-managed components. ¹
• Create a standard weekly/monthly reporting format to compliance and system owners: top findings, trends, open items. ¹

By 90 days (audit-ready evidence + sustained operations)

• Demonstrate continuous operation: a clean chain from review → analysis → report → ticket/incident → closure. ¹
• Run an internal control check: sample recent reviews, verify evidence quality, and confirm the SOP matches reality. ¹
• In Daydream, map 03.03.05 to policy/control language and schedule recurring evidence collection so you stop rebuilding the audit trail each assessment cycle. ¹

Frequently Asked Questions

Do we need a SIEM to satisfy 03.03.05?

No tool is mandated by the requirement text provided, but you must be able to review audit records, analyze them, and report results with evidence of operation. A SIEM often makes this easier to sustain and prove. ¹

What’s the minimum evidence an assessor will accept?

Keep proof of review outputs (queries/reports), documentation showing who reviewed them and when, and tickets or records showing how findings were reported and resolved. Policies alone rarely satisfy 03.03.05. ¹

How do we handle third parties that manage part of our CUI environment?

Contractually require access to relevant audit records or actionable reporting, then integrate their outputs into your review and reporting workflow. Your evidence should show you received reports and acted on them when needed. ¹

What should we report if there are “no findings”?

Report that the review occurred, define the scope reviewed, and document “no exceptions found” with reviewer name/date and the artifacts reviewed. “No findings” is still a result that needs an audit trail. ¹

Can GRC own this control, or must it be Security/IT?

GRC can own governance and evidence, but an operational team must perform or directly oversee log review and analysis. Split ownership cleanly: Security runs reviews; GRC verifies and retains evidence. ¹

How do we keep this from becoming a screenshot-heavy manual process?

Standardize exports (scheduled reports, saved queries, ticket templates) and store them in a controlled evidence repository. Tools like Daydream help by mapping 03.03.05 to recurring evidence requests and keeping artifacts organized for assessments. ¹

Footnotes

1. NIST SP 800-171 Rev. 3