AU-3(2): Centralized Management of Planned Audit Record Content

AU-3(2) requires you to centrally define and manage what audit records should contain, so logging across systems is consistent, reviewable, and harder for teams to “customize away.” Operationalize it by publishing a single enterprise audit record content standard, enforcing it through centralized configuration (SIEM/log pipeline), and keeping evidence that systems inherit and cannot silently deviate. ¹

Key takeaways:

• Centralize the definition of required audit record fields and event context, not just log storage. ²
• Make the standard enforceable through shared logging controls (agents, collectors, schemas, and policy-as-code where possible). ¹
• Retain evidence that planned audit content is documented, approved, implemented, and monitored for drift. ¹

The au-3(2): centralized management of planned audit record content requirement is about governance of “what goes into logs” across your environment. Most logging programs focus on retention and SIEM onboarding, then discover during an assessment that different platforms capture different fields, omit actor identifiers, or fail to record what was “supposed” to be logged for high-risk events. AU-3(2) pushes you to treat audit record content as a centrally managed baseline that systems must follow, with controlled exceptions.

For a CCO, GRC lead, or Compliance Officer, this control is operationally valuable because it reduces variability that breaks investigations and makes audit records unreliable evidence. It also gives assessors a single place to evaluate design: a centrally approved audit record content plan, mapped to systems, implemented through standardized configurations, and verified through testing and monitoring. NIST expresses this as an enhancement to AU-3 in SP 800-53 Rev. 5. ³

The rest of this page turns the requirement into an implementation checklist you can assign, track, and evidence.

Regulatory text

Control: “NIST SP 800-53 control AU-3.2.” ²

Operator interpretation of the text you must satisfy: AU-3(2) expects a centralized function to manage the planned content of audit records. Practically, you need one authoritative specification for required audit record fields and event context, plus a management process that pushes those requirements into system configurations and prevents unmanaged drift. ¹

Plain-English interpretation (what AU-3(2) really means)

• You decide centrally what an audit record must include (for example: who, what, when, where, outcome, object, and correlation identifiers).
• You publish that planned content as a standard and apply it across systems that generate security-relevant audit logs.
• You control changes to that standard (versioning, approvals, exceptions).
• You verify systems produce audit records that match the plan, and you can prove it with evidence. ¹

Who it applies to

AU-3(2) applies to environments implementing NIST SP 800-53, commonly:

• Federal information systems (agencies and operators of federal systems). ¹
• Contractor systems handling federal data where 800-53 controls are contractually flowed down or used in an authorization boundary. ¹

Operationally, it applies anywhere you have:

• Multiple log-producing platforms (identity, endpoints, network, cloud control plane, applications).
• Multiple teams with admin rights who can change logging settings.
• An incident response or investigations function that depends on consistent event context. ¹

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

Step 1: Name a single control owner and decision forum

Assign an accountable owner (often Security Engineering, SOC platform owner, or GRC with delegated engineering authority) and define who approves changes (security, privacy, IT operations, application platform). AU-3(2) fails most often because “everyone owns logging,” which means nobody can enforce content consistency. ¹

Deliverable: AU-3(2) control owner entry in your control register and a lightweight RACI.

Step 2: Define your “planned audit record content” standard (minimum required fields)

Create an enterprise audit record content specification that is technology-neutral and testable. Write it as required fields plus conditional fields by event type.

A practical structure:

• Common required fields (all audit records):
  • Event timestamp (with time source expectations)
  • Event type / action
  • Actor (user/service principal) identifier
  • Source (IP/device/workload identifier)
  • Target/object (resource name, record ID, system component)
  • Result (success/failure) and failure reason when available
  • System-of-record and environment (prod/dev), plus tenant/account/subscription where applicable
  • Correlation ID / request ID when available
• Sensitive actions (admin, access changes, key actions):
  • Privilege level at time of action
  • Authorization decision point (policy, role, entitlement)
  • Before/after values for changes when feasible (or a pointer to a change record)

Keep the standard short enough that teams follow it, but specific enough that auditors can test conformance. AU-3(2) is about planned content, so write it as “must capture,” not “best effort.” ¹

Deliverables: “Audit Record Content Standard” (versioned), and an event taxonomy aligned to your systems.

Step 3: Map the standard to log sources and configurations

Build a matrix that ties the standard to each log source and how it is enforced.

Example columns you can use immediately:

• System / application
• Log source type (OS, IAM, app audit log, DB audit)
• Required events enabled (yes/no + config reference)
• Required fields present (yes/no + notes)
• Collection method (agent/forwarder/API)
• Normalization mapping (field mapping to your schema)
• Owner
• Exception granted (yes/no + ticket/reference)
• Last validation date and validator

This mapping is where “centralized management” becomes real, because it documents planned content per system and exposes gaps. ¹

Deliverables: Audit content coverage matrix; configuration references (links to code repos, screenshots, or CMDB pointers).

Step 4: Centralize enforcement through your logging platform and configuration management

You need more than documentation. Put control points in the shared logging path:

• Standard log agents/collectors with centrally managed configs.
• Normalization rules in the SIEM/log pipeline that enforce required fields (for example, drop/flag events missing actor IDs).
• Central change control for logging settings on critical platforms (IAM, cloud audit logs, EDR, PAM, application audit modules).
• “Drift detection” checks (scheduled queries that alert on missing fields, unexpected event volume drops, or disabled categories).

Where teams need to deviate, force an exception workflow with an expiration and compensating controls. ¹

Deliverables: Baseline configs; change control procedure; exception process; drift monitoring queries and alert tickets.

Step 5: Validate with tests that an assessor will accept

Run periodic validation tests that sample real events and confirm fields. Make this repeatable:

• Generate a known event (failed login, role assignment, privileged action, configuration change).
• Capture the resulting log event.
• Verify required fields and mappings.
• Record the evidence (query output, raw event, timestamp, validator).

If you cannot safely generate events in production, use a controlled test environment but document equivalence and any differences. ¹

Deliverables: Validation test plan; test records; remediation tickets for gaps.

Step 6: Operationalize ongoing governance

Create a small operating rhythm:

• Review new systems during onboarding for audit record content conformance.
• Review changes that might affect logging (platform upgrades, agent changes).
• Track exceptions to closure.
• Re-validate after major releases or security incidents.

Daydream can help you keep AU-3(2) “always audit-ready” by mapping the requirement to a named control owner, a repeatable implementation procedure, and recurring evidence artifacts so the program does not rely on tribal knowledge. ²

Required evidence and artifacts to retain

Assessors will look for proof of centralized definition, enforcement, and verification. Keep:

• Versioned Audit Record Content Standard with approvals. ¹
• Audit content coverage matrix mapping requirements to systems/log sources. ¹
• Centralized logging configuration baselines (agent configs, cloud audit settings, SIEM parsers/normalizers). ¹
• Change records for modifications to the standard and key logging configurations. ¹
• Exception register with risk acceptance, expiration, and compensating controls. ¹
• Validation test evidence (raw events, queries, screenshots, stored exports) and remediation tracking. ¹

Common exam/audit questions and hangups

Expect these questions in a 800-53 assessment:

1. “Show me your planned audit record content.” They want a documented standard, not a SIEM architecture diagram. ¹
2. “Who centrally manages it?” Name the owner and show approvals and change control. ¹
3. “How do you enforce consistency across platforms?” Point to centrally managed configurations and normalization rules. ¹
4. “How do you know systems didn’t drift?” Show monitoring and re-validation evidence. ¹
5. “What about SaaS and third parties?” Show how you require audit log fields/exports in third-party onboarding and how you validate ingestion quality. ¹

Frequent implementation mistakes (and how to avoid them)

Mistake 1: Treating AU-3(2) as “central log storage”

Central storage is helpful, but AU-3(2) is about centralized management of planned content. Fix: publish required fields and event types, then show enforcement and tests. ¹

Mistake 2: Writing an untestable logging policy

Policies that say “log security events as appropriate” fail under scrutiny. Fix: define required fields and specific event categories, then map them to sources. ¹

Mistake 3: Allowing per-team customization without governance

Teams disable verbose fields “for cost” or “noise,” then investigations lack actor or target context. Fix: central baseline, exception workflow, and drift alerts. ¹

Mistake 4: No evidence of ongoing operation

A one-time spreadsheet won’t survive an assessment. Fix: keep change tickets, validation records, and monitoring outputs as recurring evidence. Daydream’s control-to-evidence mapping pattern supports this operational cadence. ²

Enforcement context and risk implications

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

Risk implications you should treat as real operational exposure:

• Investigation failure: missing actor IDs, correlation IDs, or target objects slows containment and root cause analysis. ¹
• Auditability gaps: inconsistent logging content makes it hard to demonstrate control operation across an authorization boundary. ¹
• Change accountability gaps: if privileged changes are logged inconsistently, you lose non-repudiation and create disputes about “who did what.” ¹

Practical 30/60/90-day execution plan

Use phases without committing to fixed durations beyond these labels; adjust to your system count and engineering capacity.

First 30 days: Establish the baseline and ownership

• Assign the AU-3(2) owner and approvers; document RACI.
• Draft the Audit Record Content Standard (required fields + required event categories).
• Inventory major log sources and pick a short list of “must conform first” systems (IAM, cloud control plane, endpoints, privileged access). ¹

Day 31–60: Implement centralized control points

• Build the audit content coverage matrix and identify gaps by system.
• Standardize collectors/agents and central configs for priority systems.
• Implement normalization mappings and “missing required fields” detection in the SIEM/log pipeline.
• Stand up the exception workflow and start migrating informal exceptions into the register. ¹

Day 61–90: Prove operation and prevent drift

• Run validation tests across priority systems; store evidence.
• Add drift checks and alerting for disabled audit categories or missing fields.
• Fold AU-3(2) checks into SDLC and third-party onboarding requirements for systems that provide audit logs.
• Package the artifacts for assessors: standard, matrix, configs, tests, exceptions, and monitoring outputs. ¹

Frequently Asked Questions

Does AU-3(2) require a SIEM?

No. It requires centralized management of planned audit record content. A SIEM often becomes the enforcement and validation point, but you can meet the requirement with a centralized log pipeline and configuration governance. ¹

What does “planned audit record content” mean in practice?

It means your organization has predefined what fields and context each audit record must contain, by event type. You then manage and enforce that plan centrally through standards, configurations, and verification. ¹

How do we handle systems that cannot produce all required fields?

Document the gap, create an exception with an expiration, and define compensating controls (for example, augment with identity provider logs or network telemetry). Track remediation or replacement as part of the exception record. ¹

Does AU-3(2) apply to cloud and SaaS audit logs?

Yes, if those services are in your system boundary or support security-relevant functions. Centralized management means you define required fields and ensure SaaS audit exports are enabled, ingested, mapped, and validated like other sources. ¹

What evidence is most convincing to an assessor?

A versioned audit content standard with approvals, a system-by-system mapping matrix, and validation samples showing real events include required fields. Pair that with change control records and drift monitoring alerts. ¹

Where does Daydream fit if we already have a logging platform?

Daydream helps you operationalize the control by tying AU-3(2) to a control owner, a repeatable procedure, and recurring evidence artifacts so audits don’t turn into a one-off scramble. ²

Footnotes

1. NIST SP 800-53 Rev. 5

2. NIST SP 800-53 Rev. 5 OSCAL JSON

3. NIST SP 800-53 Rev. 5; Source: NIST SP 800-53 Rev. 5 OSCAL JSON