NIST 800-171 3.3.2 (AU.L2-3.3.2): User Accountability

Ensure that the actions of individual system users can be uniquely traced to those users, so they can be held accountable for their actions.

NIST SP 800-171 Rev. 2, requirement 3.3.2

CMMC Level 2 practice AU.L2-3.3.2Published 2026-11-11

What 3.3.2 means in practice

Every logged action has to trace back to one person. That rules out shared accounts for interactive work and requires log records that carry a unique user or service identity, so an investigation can say who did what.

SPRS points and the CMMC POA&M

CMMC Level 2 practice: AU.L2-3.3.2
SPRS points: 3 points. When it is not met, the DoD Assessment Methodology subtracts 3 from the score of 110.
CMMC POA&M: Not allowed. It is worth 3 points, and 32 CFR 170.21(a)(2)(ii) admits only requirements worth 1 point, with one exception: 3.13.11 when encryption is used but not FIPS validated.

Sources: NIST SP 800-171 DoD Assessment Methodology, version 1.2.1 (June 24, 2020), Annex A; 32 CFR 170.21, Plan of Action and Milestones requirements.

What an assessor checks for 3.3.2

NIST SP 800-171A gives 2 determination statements for 3.3.2, each found satisfied or other than satisfied. Determine if:

3.3.2[a] the content of the audit records needed to support the ability to uniquely trace users to their actions is defined.
3.3.2[b] audit records, once created, contain the defined content.

NIST SP 800-171A (June 2018), assessment objectives for 3.3.2

Evidence that shows 3.3.2 is met

Sample audit records showing a unique identity on each action.
The policy prohibiting shared accounts, with any exceptions and their controls.
Logging settings that capture user and service principal identities.

How PolicyCortex gathers the evidence

PolicyCortex reads this evidence with the collectors below, read only, and grades 3.3.2 from it. Each line says what the product checks.

Azure Monitor: Diagnostic settings. Checks that diagnostic settings capture user identities and service principal activity in the audit logs.
AWS: CloudTrail and CloudWatch. Checks that CloudTrail, which records the identity behind each AWS API call, is on in every region.

Related pages

Calculator: SPRS score calculator: mark 3.3.2 and the other 109 requirements and see the score.
Sample package: Sample package: an SSP, a POA&M and an evidence chain the product generated from demonstration data.
Family: All 9 Audit and Accountability requirements (3.3).
Previous: 3.3.1: System Audit Logs
Next: 3.3.3: Review Logged Events
All requirements: All 110 NIST SP 800-171 requirements, by family.

Related records

Guides and articles describe the work. The evidence that work produces is described in three proof pages, the architecture page, and the two pages on authorization.

proof.state: Proof of State. What the environment was, as of a date someone else picks: point-in-time records, content hashed and chained.
proof.change: Proof of Change. Who or what altered the environment, under what authority, with before and after state hashes.
proof.agency: Proof of Agency. What a machine was permitted to do before it acted, what it did, and what would have stopped it.
architecture: Architecture. How the chain is built and where the evidence is stored in each delivery mode.
authorization: Continuous ATO. How an authorizing official's decision is recorded with its package, and how the authorized system is checked against it every hour.
baseline: NIST SP 800-53. The Low, Moderate and High baselines as evidence, with the SSP, SAR and POA&M generated from one record.