03.14.04: Withdrawn

Withdrawn requirements create a specific kind of audit risk: teams either (a) waste time building controls for something that no longer exists, or (b) leave outdated statements in the SSP, policies, or customer attestations that suggest a control is present when it is not. For federal contractors and any nonfederal organization handling CUI, this becomes a real operational problem during assessments because your documentation set must match the current NIST SP 800-171 Rev. 3 requirement catalog (NIST SP 800-171 Rev. 3).

For a CCO or GRC lead, the goal is simple: ensure your compliance system of record (SSP, control library, control mapping, evidence plan, and exception register) reflects that 03.14.04 is withdrawn, and that your program has a clean trace from “requirement exists” to “control designed/operating” or “requirement withdrawn” with documented disposition. This page gives you requirement-level implementation guidance focused on speed: what to change, who should own it, what evidence to retain, and the exam questions that tend to stall teams.

Target keyword focus: 03.14.04: withdrawn requirement.

Requirement overview (what “Withdrawn” means in practice)

Meaning: NIST SP 800-171 Rev. 3 lists 03.14.04 as “Withdrawn,” which means there is no active requirement text to implement for that identifier in Rev. 3 (NIST SP 800-171 Rev. 3). Operationally, your job is to:

1. Stop treating it like an active control objective, and
2. Document the disposition so assessors and customers see intentional governance, not a gap.

Withdrawn does not mean “ignore the topic area.” It means this control ID no longer carries a discrete requirement. The underlying security intent may be covered elsewhere in Rev. 3, but you should not guess. Your workflow should force a mapping decision to specific, current Rev. 3 requirements, not to a withdrawn placeholder (NIST SP 800-171 Rev. 3).

Regulatory text

NIST SP 800-171 Rev. 3 lists the requirement as: “NIST SP 800-171 Rev. 3 requirement 03.14.04 (Withdrawn).” (NIST SP 800-171 Rev. 3)

Operator action from the text: Since the requirement is explicitly withdrawn, you are expected to maintain an accurate requirement inventory and compliance narrative that reflects the current baseline. The practical obligation is governance: update your SSP/control mappings so 03.14.04 is marked withdrawn and does not appear as a missing, failed, or “planned” control (NIST SP 800-171 Rev. 3).

Who it applies to (entity and operational context)

This matters if you are:

• A federal contractor operating a nonfederal information system that processes, stores, or transmits CUI, and you align your program to NIST SP 800-171 Rev. 3 (NIST SP 800-171 Rev. 3).
• A subcontractor or service provider in the CUI supply chain where primes request alignment to NIST SP 800-171 (NIST SP 800-171 Rev. 3).
• A GRC function managing an SSP, control library, and evidence program that must remain consistent with the Rev. 3 catalog (NIST SP 800-171 Rev. 3).

Operational contexts where this shows up:

• You migrated from Rev. 2 to Rev. 3 and imported an old control matrix that still lists 03.14.04 as active.
• A third party (auditor, prime, customer) asks for an “explanation of noncompliance” against a list that includes 03.14.04.
• Your tooling auto-generates evidence requests for every requirement ID, including withdrawn items.

Plain-English interpretation

For the 03.14.04: withdrawn requirement, compliance means:

• Your program recognizes that 03.14.04 is not an implementable requirement in Rev. 3, and
• Your documentation and control operations do not misstate its status.

A clean implementation reads like this in your SSP/control matrix:

• 03.14.04 — Withdrawn (Rev. 3). No control required. Refer to Rev. 3 requirement catalog for current applicable requirements. (NIST SP 800-171 Rev. 3)

What you actually need to do (step-by-step)

1) Fix the requirement inventory (single source of truth)

• Update your requirement register/control matrix to mark 03.14.04 = Withdrawn with a short justification referencing the Rev. 3 text (NIST SP 800-171 Rev. 3).
• Ensure downstream objects inherit this status: control library entries, assessment workpapers, evidence collections, and dashboards.

Done looks like: No open POA&M items, no “planned” remediation, and no evidence tickets for 03.14.04.

2) Clean up the SSP narrative and any customer-facing mappings

• Search your SSP for “03.14.04” and remove any implementation statements that imply the requirement exists.
• If you keep a “requirements addressed” appendix, ensure 03.14.04 is shown as withdrawn, not “not implemented.”

Practical tip: If your SSP template forces a response, use “Withdrawn in NIST SP 800-171 Rev. 3; not applicable” and cite the framework reference (NIST SP 800-171 Rev. 3).

3) Reconcile legacy Rev. 2 mappings (if you had them)

• If your program previously mapped controls to 03.14.04, create a “Rev. 2 to Rev. 3 reconciliation note”:
  • Identify the legacy control statement(s) that referenced 03.14.04.
  • Decide whether that control statement is still needed under other Rev. 3 requirements, internal policy, customer contract language, or risk management.
  • If still needed, re-map it to the correct current requirement(s) or keep it as an internal control objective.

Governance outcome: “Withdrawn” does not create a control vacuum. It forces a deliberate mapping choice (NIST SP 800-171 Rev. 3).

4) Align evidence collection to current requirements only

• Remove 03.14.04 from recurring evidence schedules, request lists, and audit PBC lists.
• Confirm your GRC tooling will not auto-flag 03.14.04 as “missing evidence.”

If you use Daydream to manage requirement mappings and evidence, set 03.14.04 to a withdrawn disposition and link the change record so assessors can see the rationale without a meeting.

5) Add change control and sign-off

• Create a formal change record: “NIST SP 800-171 Rev. 3 update: requirement 03.14.04 withdrawn.”
• Get sign-off from the SSP owner and control owner for the affected family area so you can show who approved the documentation change.

Required evidence and artifacts to retain

Keep evidence that proves you managed the withdrawal intentionally:

Governance artifacts

• Requirement register/control matrix entry showing 03.14.04 = Withdrawn (NIST SP 800-171 Rev. 3).
• SSP excerpt or revision history showing updated language for 03.14.04 disposition.
• Change ticket / change advisory record approving the update.

Mapping artifacts

• Rev. 2 to Rev. 3 reconciliation memo (if applicable), including what replaced the legacy mapping decision.
• Crosswalk notes showing whether any internal control statements were retained and where they map now.

Assessment readiness

• Most recent assessment scope statement or PBC list showing 03.14.04 excluded because it is withdrawn.
• POA&M extract demonstrating no open items exist solely for 03.14.04.

Common exam/audit questions and hangups

Assessors and customer security reviewers tend to probe these points:

1. “Why is 03.14.04 marked ‘not implemented’?”
   Hangup: marking it “not implemented” implies a deficiency. Correct answer: it is withdrawn in Rev. 3 (NIST SP 800-171 Rev. 3).

2. “Show the control that meets 03.14.04.”
   Provide: your requirement register entry and SSP note stating withdrawn, plus the Rev. 3 citation (NIST SP 800-171 Rev. 3).

3. “Your policy references 03.14.04; is the policy current?”
   Fix: update policy/control references so they don’t cite withdrawn IDs, or add a version note tied to the Rev. 3 baseline (NIST SP 800-171 Rev. 3).

4. “Did you remove a security safeguard because it was withdrawn?”
   Explain your reconciliation decision: withdrawn requirement ID does not automatically justify removing a safeguard. Show risk-based rationale and current mappings.

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it’s a problem	How to avoid
Treating 03.14.04 as a control gap	Creates fake POA&Ms and wasted remediation	Mark as “Withdrawn (Rev. 3)” and close any related tasks (NIST SP 800-171 Rev. 3)
Leaving SSP boilerplate that claims compliance	Misalignment between SSP and actual baseline	Run an SSP keyword sweep for “03.14.04” and update revision notes
Deleting a legacy safeguard without review	You may remove protection still required elsewhere	Do a short mapping/risk review before deprecating any control statements
Evidence program still requests artifacts for 03.14.04	Teams scramble during audit, assessors lose confidence	Remove it from evidence schedules and auto-generated PBC lists
No change record	Auditors see unexplained edits	Keep a ticket showing who approved the withdrawal disposition

Enforcement context and risk implications

No public enforcement cases were provided for this requirement in the source catalog. The practical risk is assessment friction and misrepresentation risk: inconsistent requirement status across SSP, policies, and customer attestations can trigger deeper sampling, added questions, and reputational damage during due diligence. Treat the 03.14.04: withdrawn requirement as a documentation accuracy control that reduces avoidable findings (NIST SP 800-171 Rev. 3).

Practical execution plan (30/60/90)

First 30 days (triage and correctness)

• Update requirement register: 03.14.04 marked withdrawn with citation (NIST SP 800-171 Rev. 3).
• Sweep SSP and policies for “03.14.04” references; correct them.
• Close any POA&M items created only to “implement 03.14.04.”

By 60 days (traceability and tooling)

• Publish a Rev. 2 to Rev. 3 reconciliation note for any legacy mappings involving 03.14.04.
• Update evidence calendar and PBC templates to exclude withdrawn items.
• Verify your GRC tool reflects the withdrawn disposition everywhere (control library, assessments, dashboards). If you use Daydream, attach the change ticket and the SSP update to the requirement record for one-click assessor context.

By 90 days (operational hardening)

• Add a control to your compliance change process: “withdrawn/added requirements check” during framework updates.
• Run an internal readiness review: confirm no teams are still collecting evidence or writing narratives for 03.14.04.
• Train control owners on how to respond to customer questionnaires that contain outdated requirement lists: “Withdrawn in Rev. 3; see current requirement set” (NIST SP 800-171 Rev. 3).

Frequently Asked Questions

Do we need a compensating control for 03.14.04 since it’s withdrawn?

No standalone compensating control is required for a withdrawn requirement ID. Do a mapping check to confirm the underlying security intent is addressed by other current requirements or internal controls, then document your disposition (NIST SP 800-171 Rev. 3).

How should 03.14.04 appear in the SSP?

Mark it as “Withdrawn (Rev. 3)” with a short statement that no implementation is applicable because the requirement is withdrawn. Keep the reference aligned to NIST SP 800-171 Rev. 3 (NIST SP 800-171 Rev. 3).

Our prime contractor’s checklist still includes 03.14.04. What do we say?

Respond that 03.14.04 is withdrawn in NIST SP 800-171 Rev. 3 and provide the updated requirement reference. Offer to map any concern they intended to test to the relevant current Rev. 3 requirement(s) (NIST SP 800-171 Rev. 3).

Should we delete old policies that cite 03.14.04?

Don’t delete without review. Update references to the current baseline and keep revision history; if the policy statement still makes sense, re-map it to the applicable current requirement or retain it as an internal standard.

Can we keep collecting the same evidence we used for 03.14.04 anyway?

You can keep collecting evidence if it supports an active requirement or your internal risk posture. Just don’t label it as evidence for 03.14.04, and don’t present it as fulfilling a withdrawn requirement (NIST SP 800-171 Rev. 3).

What’s the fastest way to prevent auditors from flagging this?

Ensure consistency across your requirement register, SSP, evidence schedule, and POA&M. Auditors flag discrepancies more than withdrawn items themselves, so make the withdrawn disposition visible and traceable (NIST SP 800-171 Rev. 3).