Audit Record Review, Analysis, and Reporting is where audit logs stop being a passive archive and start being used. Event Logging (03.03.01) through Audit Record Generation (03.03.03) produce the records, but Audit Record Review, Analysis, and Reporting (03.03.05) requires you to actually look at them, report what you find, and correlate across systems. It has three (3) parts: review and analyze audit records on a defined frequency for indications and potential impact of inappropriate or unusual activity, report findings to designated personnel or roles, and analyze and correlate records across different repositories to gain organization-wide situational awareness. Per the NIST discussion, findings can be reported to entities such as the incident response team, help desk, and security or privacy offices.
A common difficulty with this requirement is generating logs nobody reviews. Collection is not review. R3 requires a defined review frequency, a reporting step, and cross-repository correlation, and for Department of Defense (DoD) contractors the review frequency is specified. A pile of logs with no review cadence and no reporting satisfies none of these objectives.
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 03.03.05 Audit Record Review, Analysis, and Reporting. Only the formatting has been adjusted for readability. This requirement has three (3) lettered parts:
The source controls are AU-06 and AU-06(03) from NIST 800-53. The bracketed assignment in part a is the Organization-Defined Parameter (ODP): the review and analysis frequency. Per the NIST discussion, the scope, frequency, and depth of review may be adjusted based on new information, and if an organization is prohibited from or unable to review its records, another organization granted such authority may carry out the review. You can read the requirement directly at NIST 800-171 R3, 03.03.05 (p. 24).
One (1) value sits inside this requirement. Depending on your contract, your organization may be permitted to define it. Organizations in the DIB subject to CMMC are not, because the DoD has defined it as policy.
The value below comes from Attachment A of the DoD Chief Information Officer (CIO) memorandum dated 10 April 2025 (signed David W. McKeown). The memo identifies each parameter by requirement sub-part, while NIST 800-171A R3 identifies the same parameter by ODP number. Both identifiers appear below so you can match your System Security Plan (SSP) language to either document.
The memo states that its values "will be updated as necessary," so confirm against the current version before writing them into policy.
NIST 800-171A R3 breaks 03.03.05 into five (5) assessment objectives: one (1) Organization-Defined Parameter (ODP) and four (4) determination statements. These AOs are:
Note that part c splits into analyze (c[01]) and correlate (c[02]) as separate objectives. If you are a DoD contractor, the ODP is specified. Per the DoD-specified ODP value in ComplianceForge's NIST 800-171 R3 Transition Guide, the review and analysis frequency (ODP[01]) is at least weekly. The full guidance on assessment methods and objects, is in NIST 800-171A R3, 03.03.05 (p. 28).
Examine: audit and accountability policy and procedures; procedures for audit record review, analysis, and reporting; reports of audit record findings; records of actions taken in response to reviews and analyses of audit records; system design documentation; system audit records across different repositories; system security plan; system configuration settings.
Interview: personnel with audit record review, analysis, and reporting responsibilities; personnel with information security responsibilities.
Test: mechanisms for supporting the analysis and correlation of audit records.
03.03.05 maps from NIST 800-171 R2 requirement 3.3.5 (correlate audit record review, analysis, and reporting processes for investigation and response to indications of unlawful, unauthorized, suspicious, or unusual activity):
Mapped against the five (5) AOs, three (3) are direct (minimal effort), one (1) is net new, and one (1) has no clear mapping, with the last two (2) categories both counting as significant effort. The review, analysis, and correlation carry forward, but the explicit reporting objective is new and the review frequency has no R2 predecessor. Two of the five (5) objectives are significant effort, concentrated on reporting findings and defining the cadence.
Source Controls in NIST 800-53 R5:
Secure Controls Framework (SCF) Crosswalk
Organizations running a single control set across multiple frameworks can satisfy 03.03.05 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 the review cadence, reporting, and correlation, 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 03.03.05 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 03.03.05 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 03.03.05 recording the ODP values you adopted.
With two (2) of the five (5) AOs at significant effort, 03.03.05 needs a defined process, not just a tool. A realistic sequence:
What value does the DoD require for the organization-defined parameter in NIST 800-171 R3 03.03.05? R3 leaves the value to the organization. For the DIB, the DoD set it in the 10 April 2025 memorandum under ODP identifier 03.03.05.a: at least weekly.
How many assessment objectives does NIST 800-171 R3 03.03.05 have? NIST 800-171A R3 breaks 03.03.05 into five (5) assessment objectives: one (1) Organization-Defined Parameters (ODPs) and four (4) determination statements. An assessor works through each one separately, so each needs its own evidence.
Which NIST 800-53 R5 controls does NIST 800-171 R3 03.03.05 come from? AU-06, AU-06(03).
Where does NIST 800-171 R3 03.03.05 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.
03.03.05 Audit Record Review, Analysis, and Reporting requires reviewing and analyzing audit records on a defined frequency, reporting findings, and correlating records across repositories for situational awareness. It maps from R2 3.3.5 with review, analysis, and correlation transitioning directly, while the reporting objective is net new and the frequency has no R2 predecessor. The recurring problem is collecting logs nobody reviews. Set the review frequency (for DoD, at least weekly), review and analyze for suspicious activity, report findings, correlate across repositories, and keep the records.
Authoritative sources:
Authoritative sources:
This guide reproduces U.S. Government text from NIST 800-171 R3 and NIST 800-171A R3 and references the DoD ODP memorandum of 10 April 2025. It is educational, not legal or assessment advice. Last reviewed: 2026-09-22.
