Audit Record Generation is where the logging plan becomes actual records. Event Logging (03.03.01) defines which event types to log and Audit Record Content (03.03.02) defines what each record must contain, but Audit Record Generation (03.03.03) is the requirement that the system actually generates those records and retains them. It has two (2) parts: generate audit records for the event types and content specified in 03.03.01 and 03.03.02, and retain those records for a time period consistent with your records retention policy. This requirement explicitly points back to the other two audit requirements, so it only works if those are already in place.
A common difficulty with this requirement is retention. Generating the records is usually the easy half, since the logging is configured under 03.03.01 and 03.03.02. The retention half depends on having a records retention policy and actually keeping the audit records for the period that policy defines. If there is no retention policy, or logs roll off before the policy period, the retention objective is unmet.
Where things stand for companies facing the transition from NIST 800-171 R2 to R3:
The following is reproduced verbatim from NIST 800-171 R3, requirement 03.03.03 Audit Record Generation. Only the formatting has been adjusted for readability. This requirement has two (2) lettered parts:
The source controls are AU-11 and AU-12 from NIST 800-53. There are no Organization-Defined Parameters (ODPs). Per the NIST discussion, audit records can be generated at various levels of abstraction, including at the packet level as information traverses the network, and selecting the appropriate level of abstraction is a critical aspect of an audit logging capability that can facilitate identifying root causes of problems. You can read the requirement directly at NIST 800-171 R3, 03.03.03 (p. 23).
None (0). Requirement 03.03.03 contains no bracketed assignment, so there is no organization-defined value to select and nothing for the DoD to specify. The requirement applies as written.
Your System Security Plan (SSP) narrative for 03.03.03 therefore records how the requirement is implemented rather than a parameter you chose.
NIST 800-171A R3 breaks 03.03.03 into two (2) determination statements, and it has no Organization-Defined Parameters (ODPs). These AOs are:
The two (2) objectives are generation (A.03.03.03.a) and retention (A.03.03.03.b). Generation depends on the event types from 03.03.01 and the content from 03.03.02, while retention depends on a defined records retention policy. Each carries its own evidence. The full guidance on assessment methods and objects, is in NIST 800-171A R3, 03.03.03 (p. 27).
Examine: audit and accountability policy and procedures; procedures for audit record generation; system design documentation; list of auditable events; system audit records; audit record retention policy and procedures; organization-defined retention period for audit records; audit record archives; system configuration settings; system security plan.
Interview: personnel with audit record generation responsibilities; personnel with audit record retention responsibilities; personnel with information security responsibilities; system developers; system administrators.
Test: mechanisms for implementing the audit record generation capability.
03.03.03 maps from NIST 800-171 R2 requirement 3.3.1 (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):
Mapped against the two (2) AOs, both (2) are direct (minimal effort), with no net-new AOs and none with no mapping. This is a clean carry-forward. R2 3.3.1 bundled specifying, generating, and retaining audit records into one requirement. R3 split that work across 03.03.01 (specify the event types), 03.03.02 (content), and 03.03.03 (generate and retain). The generation and retention pieces map directly, so if you satisfied 3.3.1 you are close, provided your retention policy is documented and your records actually persist for its defined period.
Source Controls in NIST 800-53 R5:
Secure Controls Framework (SCF) Crosswalk
Organizations running a single control set across multiple frameworks can satisfy 03.03.03 through the following SCF controls:
The crosswalks from NIST 800-171 R3 and NIST 800-171A R3 to the SCF are available at no cost through the SCF Set Theory Relationship Mapping (STRM): https://securecontrolsframework.com/start-here/set-theory-relationship-mapping-strm. The STRM also carries the relationship type for each mapping (Equal, Subset Of, Intersects With), which tells you whether an SCF control fully satisfies the requirement or only part of it. Mapping above taken from SCF 2026.3.
The following are issues teams may encounter rather than certainties. They are about retention and the dependency on the other audit requirements, each of which needs documented evidence of due diligence and due care such as policies, standards, procedures, and configuration screenshots:
Reasonable objective evidence for an assessment is often subjective. The following examples of evidence to address NIST 800-171 R3 03.03.03 are sourced from the SCF Evidence Request List (ERL), available at https://securecontrolsframework.com/free-content/scf-download. These ERL artifacts are mapped to NIST 800-171 R3 03.03.03 through SCF controls. They establish a starting point for discussions on what an organization needs to have for evidence of due diligence and due care to withstand external scrutiny by an assessor or regulator.
Alongside these, keep the System Security Plan (SSP) narrative for 03.03.03.
With both AOs mapping directly, 03.03.03 is a light lift once 03.03.01 and 03.03.02 are in place. A realistic sequence:
How many assessment objectives does NIST 800-171 R3 03.03.03 have? NIST 800-171A R3 breaks 03.03.03 into two (2) assessment objectives. An assessor works through each one separately, so each needs its own evidence.
Which NIST 800-53 R5 controls does NIST 800-171 R3 03.03.03 come from? AU-11, AU-12.
How many Organization-Defined Parameters (ODPs) does NIST 800-171 R3 03.03.03 have? None (0). The requirement contains no bracketed assignment, so there is no organization-defined value and nothing for the DoD to specify.
Where does NIST 800-171 R3 03.03.03 sit in the NIST 800-171 R3 Kill Chain? Phase 11, Situational Awareness (SA). The Kill Chain is a phased model for sequencing R3 implementation, and it assigns this requirement to that phase.
03.03.03 Audit Record Generation generates audit records for the event types and content defined in 03.03.01 and 03.03.02 and retains them per the records retention policy. It maps directly from R2 3.3.1 with both assessment objectives transitioning directly, so there is no net-new work. The recurring problem is retention without a policy, or logs that roll off before the policy period. Confirm the upstream event types and content, verify records generate, document the retention period, and make sure records actually persist for it.
Authoritative sources:
Authoritative sources:
This guide reproduces U.S. Government text from NIST 800-171 R3 and NIST 800-171A R3. It is educational, not legal or assessment advice. Last reviewed: 2026-09-22.
