System Auditing

Official reference

The requirement

Create and retain system audit logs and records to the extent needed to enable the monitoring, analysis, investigation, and reporting of unlawful or unauthorized system activity.

DoD CMMC Assessment Guide, Level 2, version 2.13. AU.L2-3.3.1; requirement and objectives, printed page 72 ↗

Assessment objectives

What must be established

Determine if each applicable objective is satisfied. The labels below follow the cited DoD assessment guide.

1. [a]

   audit logs needed (i.e., event types to be logged) to enable the monitoring, analysis, investigation, and reporting of unlawful or unauthorized system activity are specified;

2. [b]

   the content of audit records needed to support monitoring, analysis, investigation, and reporting of unlawful or unauthorized system activity is defined;

3. [c]

   audit records are created (generated);

4. [d]

   audit records, once created, contain the defined content;

5. [e]

   retention requirements for audit records are defined; and

6. [f]

   audit records are retained as defined.

MET requires evidence that all applicable objectives are satisfied. Final, approved evidence is needed. A NOT APPLICABLE determination needs a scope-based basis and is equivalent to MET for scoring. Enduring exceptions and temporary deficiencies have specific conditions under 32 CFR 170.24; they are not a general permission to defer implementation.

GAVII Cybersecurity assessment approach

Connect the objective to the evidence

Identify events, record detail, and retention needed for monitoring and investigation. Check applications and cloud services as well as infrastructure, and distinguish log generation from successful retention.

Assessment focus: objectives [a], [b], [c], [d], [e], [f]. Use the methods together; a single example does not establish every objective.

GAVII Cybersecurity’s examples illustrate ways to examine, interview, and test. They are not a mandatory artifact list or a guarantee of an assessment result. Combine methods and address every applicable objective in the actual scope.

Assessment constraints

Scoring and POA&M eligibility

Conditional Level 2 requires a score of at least 88 out of 110 and satisfaction of every eligibility condition. A 1-point requirement is not automatically eligible. The permitted POA&M must be closed through the appropriate closeout assessment within 180 days of the Conditional CMMC Status Date. An operational remediation plan does not confer Conditional Status.

Assessment planning

Location and observation

Not specifically listed in CAP P.11

This requirement is not specifically listed in CAP P.11. That does not establish that remote assessment is sufficient: the Lead CCA and C3PAO determine an adequate approach for the actual scope and evidence.

Check the source

References and related requirements

• DoD CMMC Assessment Guide, Level 2 ↗AU.L2-3.3.1; requirement and objectives, printed page 72. 2.13, September 2024.
• 32 CFR 170.24: Assessment findings and scoring ↗170.24(b) and (c)(2). Current electronic Code of Federal Regulations.
• 32 CFR 170.21: POA&M eligibility and closeout ↗170.21(a)(2) and (b). Current electronic Code of Federal Regulations.
• NIST SP 800-171 Rev. 2 ↗Requirement 3.3.1. February 2020, updated January 2021.
• NIST SP 800-171A ↗Assessment procedure 3.3.1. June 2018.
• Cyber AB CMMC Assessment Process (CAP) ↗P.11, printed pages 10-11; Level 2 certification assessment-location planning. 2.0, December 2024.

Program timing and contract applicability can change independently of these requirements. Check current DoD program notices and your solicitation or contract before making a compliance decision. Open the official DoD resource hub.