3.3.3Revisit what you log in Rev. 3
Reworded: 03.03.03 Audit Record Generation.
Status as of 2026-09-08
Rev. 2 is what a contract requires today. DFARS 252.204-7012 and the CMMC rule at 32 CFR 170 point at NIST SP 800-171 Rev. 2, and a standing DoD class deviation keeps it there. NIST has published Rev. 3, but publishing a revision does not change an obligation. A move to Rev. 3 would arrive through the Department's reform process and formal rulemaking, a change to that deviation or an amendment to the rule, not through publication. The Department has published its organization-defined parameter values for Rev. 3 in preparation; that is groundwork, not adoption.
Side by side
Rev. 2 · in force 3.3.3 Event Review
Assessment objectives · 800-171A
- [a] a process for determining when to review logged events is defined
- [b] event types being logged are reviewed in accordance with the defined review process
- [c] event types being logged are updated based on the review
Rev. 3 · not adopted 03.03.03 Audit Record Generation
a. Generate audit records for the selected event types and audit record content specified in 03.03.01 and 03.03.02.
b. Retain audit records for a time period consistent with the records retention policy.
Determination statements · 800-171A Rev. 3
- 03.03.03.a audit records for the selected event types and audit record content specified in 03.03.01 and 03.03.02 are generated.
- 03.03.03.b audit records are retained for a time period consistent with the records retention policy.
Draws on Rev. 2 3.3.3.
Left: NIST SP 800-171 Rev. 2 and 800-171A, verbatim. Right: NIST SP 800-171 Rev. 3 and 800-171A Rev. 3, verbatim, with organization-defined blanks highlighted.
Word by word
The Rev. 2 requirement compared with its Rev. 3 successor. A mechanical comparison of the two verbatim texts, not an interpretation.
removed in Rev. 3 added in Rev. 3
Rev. 2 3.3.3 → Rev. 3 03.03.03 Audit Record Generation
1 words kept, 4 removed, 29 added. Rev. 3 statement labels omitted for the comparison.
What NIST says changed
- New security requirement title
- Aligned with SP 800-53, Rev 5 to provide more comprehensive detail on and foundational tasks for audit records generation and retention
NIST, SP 800-171 Rev. 2 to Rev. 3 change analysis, class “Significant change”. At adoption, Bedrock files this under “Rework”.
NIST's Rev. 3 discussion for 03.03.03
Audit records can be generated at various levels of abstraction, including at the packet level as information traverses the network. Selecting the appropriate level of abstraction is a critical aspect of an audit logging capability and can facilitate the identification of root causes to problems. The ability to add information generated in audit records is dependent on system functionality to configure the audit record content. Organizations may consider additional information in audit records, including the access control or flow control rules invoked and the individual identities of group account users. Organizations may also consider limiting additional audit record information to only information that is explicitly needed for audit requirements.
What this means for you now
Nothing changes in what you are assessed against until a class deviation or a published rule adopts Rev. 3. Keep meeting 3.3.3 as written in Rev. 2.
Bedrock CMMC shows this same comparison against your own package, with your current status on the Rev. 2 side, so the day adoption lands the migration is a review, not a rewrite.
Where this page's facts come from
- Rev. 2 text and objectives
- bedrock-cmmc-api@89b8e8e:migrations/004_reference_requirements.sql#Requirement.basicRequirement@rev2; bedrock-cmmc-api@89b8e8e:migrations/005_reference_objectives.sql#AssessmentObjective.description@rev2
- Mapping and change class
- bedrock-cmmc-api@89b8e8e:docs/reference/nist-800-171-rev3/normalized/r2_r3_transition_map.json#r2_to_r3
- Rev. 3 03.03.03
- bedrock-cmmc-api@89b8e8e:docs/reference/nist-800-171-rev3/normalized/rev3.json#requirements[]