Requirements / Physical Protection (PE)
PE.L2-3.10.4
Physical Access Logs
Official Source Material
Maintain audit logs of physical access.
Determine if:
- [a] audit logs of physical access are maintained.
Source: CMMC Assessment Guide - Level 2, Version 2.13, September 2024
Practitioner Guidance
How to meet it
A paper sign-in sheet is a compliant audit log.
The requirement's discussion accepts procedural logs, automated logs, or a combination. A visitor logbook at the door plus badge system records for employees covers a typical office, and neither requires new spending.
Log the controlled areas, not just the front door.
Physical access points include interior areas with supplemental controls, such as a server room. Where the room has its own badge reader, its log answers this. Where it has a key, a key sign-out sheet does.
Cameras can be the log.
Motion-triggered footage where every clip carries a timestamp is a chronological record of access. For a facility with several entrances and no badge readers, timestamped camera coverage of the entry points is a workable log that asks nothing of anyone day to day.
Define a retention period and honor it.
The requirement says maintain and leaves the period to you. Pick a number, write it into the procedure, and keep the logs that long, because the assessor checks your practice against your own stated period.
Maintained means reviewable, not reviewed.
No objective requires a routine review of these logs. Keep them retrievable so an investigation can reconstruct who was where. A folder of sign-in sheets meets that bar.
This is another of the six requirements 32 CFR 170.21 keeps off any POA&M.
A POA&M, a plan of action and milestones, defers an unmet requirement past the assessment, and a missing log cannot be deferred that way. Have the log running before the assessment, not after it. A sheet of paper and a pen start the evidence today.
What falls short
- System logon records offered as physical access logs. Logging into a laptop shows where the account was used, not who entered the facility, so [a] is unanswered.
Edge cases
- Sign-out is not required by the objective, because entry records alone are an audit log of access. Add exit tracking when it is useful to you, not because the requirement demands it.
- A one-person home office can keep a simple log: entries for days when others were present, plus a statement of how nobody could enter otherwise. Describe the key control that backs the statement.