Audit and Accountability 3.3.9 (3.3.9)
Limit management of audit logging functionality to a subset of privileged users.
Get Full GuidanceWhat Is This CMMC Control?
This control requires organizations to restrict who can manage audit logging systems and settings. Only a small group of specially authorized privileged users should be able to configure audit systems, modify audit settings, or access audit management functions. This prevents individuals who are being audited from tampering with or disabling the audit logs that track their own activities.
Control Intent
Prevent unauthorized modification, deletion, or disabling of audit logging by limiting audit management capabilities to a trusted subset of privileged users who are separate from those being audited.
Who This Control Applies To
- •All systems that process, store, or transmit CUI
- •Systems with audit logging capabilities
- •Privileged user accounts with administrative access
- •Audit management systems and tools
- •Centralized logging platforms
- •SIEM systems
- •Cloud service audit configurations
- •Network device audit settings
Not Applicable When
- •The system has no audit logging capability (though this would likely fail other audit controls)
- •The organization has only a single privileged user (though this creates significant risk and should be remediated)
- •Audit logging is fully managed by a FedRAMP authorized cloud service provider with no customer access to audit management functions
Key Objectives
- 1Restrict audit logging management functions to a defined subset of privileged users
- 2Prevent individuals subject to audit from modifying or disabling audit mechanisms that track their activities
- 3Establish separation of duties between system administration and audit administration
- 4Protect the integrity and reliability of audit information by controlling who can manage audit functionality
Sample Self-Assessment Questions (Partial)
Who currently has the ability to modify audit logging settings in your systems?
How many people have administrative access that includes audit management capabilities?
Implementation Approaches (High-Level)
Role-Based Access Control for Audit Management
Implement dedicated audit administrator roles that are separate from general system administrator roles, with technical controls enforcing the separation.
Centralized Audit Management Platform
Use a centralized logging or SIEM platform where audit management is restricted to a dedicated team, with source systems configured to forward logs without local management capability.
Separation of Duties with Dual Control
Implement technical controls requiring multiple authorized users to approve or execute audit management changes, preventing any single user from unilaterally modifying audit settings.
Privileged Access Management for Audit Functions
Use a PAM solution to broker and monitor access to audit management functions, with session recording and just-in-time access provisioning.
Cloud Service Provider Managed Audit Logging
Leverage FedRAMP authorized cloud service provider audit logging where the CSP manages audit infrastructure and the customer has limited or no access to audit management functions.
Evidence & Assessment Notes
Expected Evidence
Organizations should maintain documentation and evidence demonstrating compliance with this control. This may include policy documentation, configuration records, audit logs, access reviews, and other relevant artifacts that show how the control is implemented and maintained.
Plan of Action & Milestones (POA&M)
If all privileged users currently have audit management access, create a phased plan to implement role-based access control with audit management separated from general administration For small organizations with limited staff, document compensating controls such as increased monitoring, dual control procedures, or third-party audit log management If technical separation is not immediately feasible, implement procedural controls and monitoring as interim measures while working toward technical enforcement Consider leveraging cloud service provider managed audit logging to reduce the burden of implementing this control for cloud-based systems Prioritize restriction of audit management for the most critical systems first, then expand to all in-scope systems Document any systems where audit management cannot be restricted and provide detailed justification and compensating controls If using managed service providers, ensure contracts specify that MSP personnel with audit management access are identified and approved Plan for implementation of privileged access management solutions if managing audit access across many diverse systems Include timeline for periodic review and recertification of audit management privileges Address any gaps in monitoring of audit management activities as part of the remediation plan
Frequently Asked Questions
What does it mean to 'limit management of audit logging functionality' and what functions does this include?
Audit logging management includes any function that can configure, modify, enable, disable, or delete audit settings or audit logs themselves. This includes changing what events are audited, modifying audit log retention settings, disabling audit logging, deleting audit logs, changing audit log storage locations, and modifying audit policies. The control requires that only a small, defined group of privileged users can perform these functions, not all system administrators.
How many users should have audit management privileges?
There is no specific number mandated, but the control requires 'a subset of privileged users,' meaning fewer users than the total number of privileged users. Best practice is to limit audit management to the minimum number needed for operational requirements, typically 2-3 individuals to ensure coverage while maintaining restriction. The key is that audit management is more restricted than general administrative access.
Can the same person be both a system administrator and an audit administrator?
While not ideal, this may be necessary in small organizations with limited staff. If the same person must perform both roles, implement compensating controls such as increased monitoring of their activities, dual control procedures requiring approval for audit changes, use of privileged access management to record sessions, or third-party review of audit logs. Document the business justification and compensating controls in your SSP.
How is this control verified during a CMMC assessment?
Assessors will request a list of all users with audit management privileges and compare it to the total list of privileged users to verify it is a subset. They will examine system configurations, role definitions, and access control settings to confirm technical restrictions are in place. Assessors will test whether general administrators can modify audit settings and verify that audit management activities are logged. They will also review documentation showing periodic access reviews and business justifications for audit management access.
Does this control apply to cloud services where we cannot manage audit logging?
If you are using a FedRAMP authorized cloud service where the provider manages audit logging and you have no access to audit management functions, you can inherit satisfaction of this control from the provider's authorization. Document this inheritance in your SSP and maintain evidence of the provider's FedRAMP status. However, if you have any ability to configure audit settings in the cloud service (such as enabling/disabling logs or changing retention), those functions must be restricted per this control.
What is the difference between this control and AC.L2-3.1.5 (separation of duties)?
AC.L2-3.1.5 addresses separation of duties broadly across all security-relevant functions, while AU.L2-3.3.9 specifically focuses on separating audit management from other privileged functions. This control implements separation of duties specifically for audit logging to prevent individuals from disabling or modifying the audit trail of their own activities. Both controls work together, with 3.3.9 providing specific requirements for the audit domain that support the broader separation of duties principle in 3.1.5.
How ConformatIQ Helps With CMMC Readiness
ConformatIQ is an AI-assisted CMMC readiness platform designed to help organizations prepare for assessments more efficiently. The platform supports document generation such as SSPs and POA&Ms, guided readiness workflows, centralized evidence tracking, and interview preparation for assessments.
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Request Full GuidanceInformation sourced from NIST SP 800-171 Rev. 2. See full disclaimer.