Time Stamps is the requirement that makes audit records comparable across systems by giving them consistent, sufficiently precise time. Audit Record Content (03.03.02) says a record must capture when an event occurred, and Time Stamps (03.03.07) defines how that time is generated and recorded. It has two (2) parts: use internal system clocks to generate time stamps for audit records, and record time stamps that meet a defined granularity and that use Coordinated Universal Time (UTC), a fixed local offset from UTC, or an included local offset. Per the NIST discussion, granularity refers to the degree of synchronization between system clocks and reference clocks, and time service can be critical to other security capabilities such as access control and identification and authentication.
A common difficulty with this requirement is inconsistent time. If two systems disagree on the time, correlating their audit records (03.03.05) and preserving time ordering (03.03.06) both break down. R3 wraps a granularity Organization-Defined Parameter (ODP) around this and adds an explicit time-representation objective, and for Department of Defense (DoD) contractors the granularity is specified. There is also a transition subtlety: R3 no longer lists specifying an authoritative time source as its own objective, even though synchronization is still what makes the granularity achievable.
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 03.03.07 Time Stamps. Only the formatting has been adjusted for readability. This requirement has two (2) lettered parts:
The source control is AU-08 from NIST 800-53. The bracketed assignment in part b is the Organization-Defined Parameter (ODP): the granularity of time measurement. Per the NIST discussion, time stamps include the date and time, time is often expressed in UTC or local time with an offset, and organizations may define different granularities for different system components. You can read the requirement directly at NIST 800-171 R3, 03.03.07 (p. 25).
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 03.03.07 into four (4) assessment objectives: one (1) Organization-Defined Parameter (ODP) and three (3) determination statements. These AOs are:
The determination statements split part b into meeting the granularity (b[01]) and using an acceptable time representation (b[02]). 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 granularity of time measurement (ODP[01]) is one (1) second or smaller. The full guidance on assessment methods and objects, is in NIST 800-171A R3, 03.03.07 (p. 30).
Examine: audit and accountability policy and procedures; procedures for timestamp generation; system design documentation; system configuration settings; system audit records; system security plan.
Interview: personnel with information security responsibilities; system developers; system administrators.
Test: mechanisms for implementing timestamp generation.
03.03.07 maps from NIST 800-171 R2 requirement 3.3.7 (provide a system capability that compares and synchronizes internal system clocks with an authoritative source to generate time stamps for audit records):
Mapped against the four (4) AOs, two (2) 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 clock generation and synchronization carry forward, but the time-representation objective (UTC or a defined offset) is new and the granularity parameter has no R2 predecessor. As ComplianceForge's NIST 800-171 R3 Transition Guide notes in its "Situational Awareness" analysis, R3 also dropped the R2 objective that required specifying an authoritative time source (3.3.7[b]), so while synchronization is still implied by the granularity requirement, there is no longer an explicit objective to name your authoritative source. Document it anyway, because you cannot reliably meet a one-second granularity without one.
Source Control in NIST 800-53 R5:
Secure Controls Framework (SCF) Crosswalk
Organizations running a single control set across multiple frameworks can satisfy 03.03.07 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 representation, granularity, and the dropped authoritative source, 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 03.03.07 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 03.03.07 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 03.03.07 recording the ODP values you adopted.
With two (2) of the four (4) AOs at significant effort, 03.03.07 needs deliberate configuration. A realistic sequence:
What value does the DoD require for the organization-defined parameter in NIST 800-171 R3 03.03.07? R3 leaves the value to the organization. For the DIB, the DoD set it in the 10 April 2025 memorandum under ODP identifier 03.03.07.b: a granularity of one (1) second or smaller.
How many assessment objectives does NIST 800-171 R3 03.03.07 have? NIST 800-171A R3 breaks 03.03.07 into four (4) assessment objectives: one (1) Organization-Defined Parameters (ODPs) and three (3) determination statements. An assessor works through each one separately, so each needs its own evidence.
Which NIST 800-53 R5 control does NIST 800-171 R3 03.03.07 come from? AU-08.
Where does NIST 800-171 R3 03.03.07 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.
03.03.07 Time Stamps requires generating time stamps from internal system clocks and recording them at a defined granularity using UTC or a defined local offset. It maps from R2 3.3.7 with clock generation and synchronization transitioning directly, while the time-representation objective is net new and the granularity has no R2 predecessor. R3 also dropped the explicit authoritative-time-source objective, but you still need a synchronized source to hit a one-second granularity. Define the granularity, synchronize to an authoritative source, generate stamps from system clocks, and record them in UTC or a defined offset.
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.
