PE-8(2): Physical Access Records

A PE-8(2) finding is rarely about fancy locks. It’s about whether you can prove who entered controlled spaces, when they entered, and how you know the record is accurate. For a CCO, GRC lead, or security compliance owner, the fastest path is to treat physical access records like any other audit-grade log source: you define scope, instrument it, protect it, review it, and retain evidence on a schedule.

This requirement shows up most often during NIST SP 800-53 assessments for federal information systems and for contractor environments handling federal data. If you run a hybrid environment, you also need to address third-party sites (colocation, managed offices, hosted data centers) where your system components reside. In practice, auditors will test two things: (1) can you produce records quickly for a named area and timeframe, and (2) do the records support investigations (unique identities, timestamps, and a chain of custody).

This page gives you requirement-level implementation guidance you can execute: scoping, procedures, evidence, audit questions, and a pragmatic execution plan.

Requirement overview (PE-8(2): physical access records requirement)

PE-8(2) sits in the Physical and Environmental Protection (PE) family and focuses on maintaining physical access records. Your goal is straightforward: maintain audit-ready records showing physical access to the facility and/or sensitive areas that support the system, and be able to produce them on request for assessments and incident investigations. ¹

Plain-English interpretation

You need a dependable “paper trail” (electronic preferred) for physical entry and exit events into areas where system components or sensitive information could be accessed. That includes:

• Employee/contractor badge events (granted/denied, door forced, door held, after-hours access)
• Visitor access (who sponsored them, where they went, and when)
• Exceptions (lost badge, mechanical key issuance, emergency entry)

The records must be complete enough to reconstruct who had access, and defensible enough that an auditor trusts they weren’t altered.

Regulatory text

The framework source for this requirement is NIST SP 800-53 control PE-8.2. ²

What the operator must do: implement and operate a process to generate and retain physical access records for the relevant facility/areas supporting the system, and maintain those records as assessable evidence. At assessment time, you should be able to (a) show the logging mechanism, (b) produce logs for a specified period and area, and (c) demonstrate governance (ownership, procedures, and recurring checks). ¹

Who it applies to (entity + operational context)

Entities

• Federal information systems and the organizations operating them. ¹
• Contractors handling federal data where NIST SP 800-53 is a contractual or program requirement. ¹

Operational contexts

• Corporate offices with server rooms, network closets, or secure records rooms
• Data centers, labs, and manufacturing floors housing system components
• Colocation cages, managed suites, and other third-party facilities where your assets live (you still need records, even if the third party operates the doors)

Scoping decision you must make early Define the physical boundary of the system: the facility and sub-areas where unauthorized entry would reasonably enable access to system components, sensitive media, or administrative consoles. Document the list of controlled areas; auditors will use it to decide what logs they expect.

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

1) Define scope and controlled areas

Create a “Controlled Areas Register” with:

• Site/facility name and address
• Areas in scope (data center floor, server room, MDF/IDF closets, security office, records room)
• Door identifiers (reader names) mapped to areas
• Ownership (Facilities/Security) and system/security point of contact (GRC/ISSO)

Practical tip: if you can’t map badge readers to rooms cleanly, you won’t be able to answer basic audit sampling requests.

2) Define the event types you will record

Write a short standard for physical access records that states, at minimum:

• Events captured: successful entries, denied entries, door forced/held, mechanical override/key events, visitor sign-in/out
• Identity requirements: unique person identifier (badge ID linked to HR identity), visitor identity (government ID or other defined verification), sponsor
• Time requirements: time zone, synchronized clocks for access control system and log storage
• Location requirements: door/reader identifier and area name

3) Implement logging mechanisms for employees and contractors

Typical implementations:

• Electronic Access Control System (EACS) with badge readers on controlled-area doors
• Central log storage (SIEM, log server, or secured access control reporting database)
• Controlled administrator access and change logging for the EACS

Minimum operational expectations:

• Access events are recorded automatically.
• Admin changes (adding/removing access rights) are controlled and auditable.
• Logs are protected from deletion or alteration by ordinary users.

4) Implement visitor management that produces audit-grade records

Your visitor process should generate:

• Visitor name, organization, and verification method
• Sponsor name and approval
• Areas authorized to visit
• Badge/temporary pass number
• Sign-in/out times
• Escort requirement (if applicable) and exceptions

If you use a paper log, treat it like regulated evidence: numbered pages, controlled storage, and defined retention. If you use an electronic visitor system, export evidence on a recurring basis so you’re not dependent on ad hoc UI screenshots during an audit.

5) Set retention and retrieval expectations (and prove you can retrieve)

NIST assessments commonly test whether you can produce records for a defined timeframe and location. Make retrieval easy:

• Standard report templates (by door, by person, by date range)
• Evidence exports stored in a compliance repository with naming conventions
• A documented procedure for responding to audit samples and incident requests

If your retention is governed by contract, policy, or program requirements, record it in your control narrative and apply it consistently. ¹

6) Add recurring review and exception handling

Physical access records become meaningful when you review them.

• Review triggers: after-hours access, repeated denied attempts, door forced/held alarms, access by terminated users (should be zero)
• Triage workflow: investigate, document outcome, and create tickets for remediation
• Escalation: Security/Facilities + HR + system owner when needed

7) Document the control so it can be assessed

Create a one-page control implementation summary:

• Scope (sites/areas)
• Tools (EACS, visitor system, log storage)
• Roles and responsibilities
• How records are protected
• How reviews happen and how issues are tracked This is where tools like Daydream help: map the requirement to an owner, a procedure, and a recurring evidence set so you don’t rebuild the story every audit cycle. ²

Required evidence and artifacts to retain (audit-ready checklist)

Maintain evidence that shows design + operation:

Design artifacts

• Physical security policy / standard covering access logging
• Controlled Areas Register (doors/readers mapped to areas)
• Role assignments (control owner, operators, approvers)
• Procedure: how to pull logs, how to grant temporary access, visitor process

Operational evidence (recurring)

• EACS log exports for sampled periods (include door, badge ID, timestamp, event type)
• Visitor logs for sampled periods (visitor identity, sponsor, sign-in/out)
• Exception records: lost badge issuance, mechanical key logs, emergency access logs
• Access review evidence related to physical access (termination removal confirmation, privileged physical access approvals)
• Incident/ticket evidence for anomalies found during reviews

System integrity evidence

• Admin access list for EACS and visitor system
• Change records for access control configuration (reader additions, schedules, access groups)
• Backup/export configuration evidence (how logs are preserved)

Common exam/audit questions and hangups

Auditors and assessors commonly ask:

• “Show me physical access records for this server room for the last sampled period.”
• “How do you know visitors didn’t enter unescorted?”
• “What happens when the badge system is down?”
• “Who can edit or delete access logs, and how is that controlled?”
• “Prove terminated personnel cannot badge into controlled areas.”
• “Do you have physical access records for your colocation site, and how do you obtain them?”

Hangups that trigger findings:

• Doors in scope with no reader coverage (or readers not actually enforced)
• Logs exist but cannot be exported, filtered, or tied back to identities
• Visitor records don’t connect to the areas visited or to a sponsor
• Inconsistent retention across sites or between employees and visitors

Frequent implementation mistakes (and how to avoid them)

1. No clear scoping boundary.
   Fix: publish a controlled-areas list and keep it current as closets/rooms change.

2. Badge logs aren’t attributable to a person.
   Fix: ensure badge IDs map to HR identities, and contractors are uniquely identified.

3. Visitor management is “front desk theater.”
   Fix: require sponsor, time in/out, and pass numbers; store logs as evidence.

4. Mechanical keys become an unlogged backdoor.
   Fix: implement a key issuance log with approvals and returns tracked.

5. You can’t respond to sampling quickly.
   Fix: standardize report templates and store periodic exports in a compliance repository.

Risk implications (what failure looks like)

Weak physical access records increase the impact of:

• Insider threat investigations that stall because you can’t verify presence
• Incident response where you must correlate physical and logical access
• Asset tampering allegations where you can’t establish chain of custody
• Assessment failures that cascade into broader control doubts (if logs can be edited, what else is informal?)

The most practical risk statement for leadership: if you can’t produce reliable facility access records, you can’t prove that system components were protected from physical access, and you can’t support investigations with defensible evidence. ¹

Practical execution plan (30/60/90 days)

You asked for speed; here is a plan you can run as a compliance project. Timelines are approximate and depend on site count and tool maturity.

First 30 days (Immediate stabilization)

• Name the control owner and backups (Facilities/Security operator + GRC owner).
• Build the Controlled Areas Register for all in-scope sites.
• Confirm tooling: EACS in use, visitor process in place, and where logs live.
• Draft the “physical access records standard” (events, identity, timestamps, retrieval method).
• Run an internal audit sample: pick one door, one week, produce logs in under a day; fix gaps.

By 60 days (Operationalize and evidence)

• Implement standardized log exports (scheduled where possible).
• Lock down admin access to EACS/visitor platforms; document who has it and why.
• Implement exception logging for keys, badge outages, and emergency entry.
• Start a lightweight review cadence for anomalies (after-hours, forced doors, repeated denials).
• Store evidence in a single repository with naming conventions and a retrieval runbook.

By 90 days (Assessment-ready)

• Validate coverage: every controlled-area entry point has an access record path (badge, visitor, or documented alternative).
• Test an end-to-end scenario: visitor entry, escort, exit, records retention, and audit retrieval.
• Run a tabletop with Security + HR: terminated user scenario, prove physical access is removed and confirm in logs.
• Finalize the control narrative and map recurring evidence in Daydream so collection and ownership are consistent across quarters. ²

Frequently Asked Questions

Do we need electronic badge logs, or are paper sign-in sheets acceptable?

NIST SP 800-53 doesn’t require a specific technology in the excerpt provided, but auditors expect reliable, retrievable records. Paper can work if it is controlled, legible, retained, and tied to identity and time; electronic systems are usually easier to evidence and protect. ¹

What areas should be in scope for physical access records?

Include any facility or room where entry could enable access to system components, sensitive media, or administrative consoles. Document the list and map it to doors/readers so you can produce logs by location. ¹

How do we handle colocation or third-party data centers?

Treat the third party’s access logs and visitor records as required evidence, and define how you request and retain them. Your procedure should state retrieval steps and who owns the relationship so audit sampling doesn’t become a scramble. ¹

Do we need to review physical access logs regularly?

PE-8(2) is about records, but reviews are how you prove the records matter operationally and catch anomalies. Set review triggers (after-hours access, forced doors, repeated denials) and retain tickets or investigation notes as evidence.

What do auditors usually sample for PE-8(2)?

Expect requests for a specific door/area and a date range, plus proof that identities are unique and timestamps are consistent. They also ask how you prevent alteration of logs and who can administer the access control system.

How does Daydream help with PE-8(2) quickly?

Daydream is useful once you’ve defined scope and sources. Map PE-8(2) to an owner, a written procedure, and a recurring evidence list (log exports, visitor records, exceptions, reviews) so collection and audit response become repeatable. ²

Footnotes

1. NIST SP 800-53 Rev. 5

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