03.14.05: Withdrawn

03.14.05 is a withdrawn requirement in NIST SP 800-171 Rev. 3, so you do not implement a standalone control for it. You still must operationalize it by documenting the withdrawal in your SSP, confirming no contractual/customer requirement depends on it, and maintaining traceable mapping so assessors see a deliberate, governed decision. ¹

Key takeaways:

• Treat 03.14.05: withdrawn requirement as a documentation and traceability task, not a technical implementation task.
• Update your SSP/control catalog mappings to show “Withdrawn,” with ownership and a rationale tied to NIST SP 800-171 Rev. 3. ¹
• Verify downstream obligations (contracts, primes, customer overlays) so “withdrawn” does not create an assessment or legal gap.

Withdrawn controls cause real friction in audits because they sit in the control family numbering and look like “missing work.” For a CCO or GRC lead, the goal is simple: prevent an assessor, customer, or prime from concluding you skipped a requirement. For 03.14.05: withdrawn requirement, operationalizing the requirement means proving three things: (1) you recognized it is withdrawn in NIST SP 800-171 Rev. 3, (2) you intentionally removed or did not create a discrete control for it, and (3) your documentation set (SSP, mappings, and POA&M governance) remains internally consistent and assessable. ¹

You also need to manage the practical reality that other documents, older mappings, inherited templates, and third-party questionnaires may still reference 03.14.05. Your team should be prepared with a short, repeatable response and a clean evidence package.

This page gives you requirement-level implementation guidance to close the loop quickly: where to record the withdrawal, who owns it, what artifacts to keep, what auditors ask, and how to avoid common mapping mistakes that turn a non-requirement into a finding.

Regulatory text

Excerpt: “NIST SP 800-171 Rev. 3 requirement 03.14.05 (Withdrawn).” ¹

Plain-English interpretation

• There is no control to implement for 03.14.05 in Rev. 3 because NIST withdrew it. ¹
• Your obligation is governance and clarity: document that it is withdrawn, keep your control inventory and SSP mapping consistent, and ensure nobody relies on it as a live requirement. ¹

What an operator must do

You must be able to show an assessor that:

1. Your authoritative source is Rev. 3 and you track withdrawn items accordingly. ¹
2. Your SSP and control mapping explicitly mark 03.14.05 as “Withdrawn” rather than “Not Implemented” or “N/A,” which can trigger unnecessary scrutiny.
3. If a customer/prime contract still cites an older revision or an overlay that expects the withdrawn item, you have a documented resolution (e.g., contract interpretation memo, customer confirmation, or compensating mapping).

Who it applies to

Entity types and context:

• Federal contractors and other organizations operating nonfederal systems that handle CUI and use NIST SP 800-171 Rev. 3 as the security requirement baseline. ¹

Operationally, this hits teams who manage:

• System Security Plans (SSPs) for CUI environments
• Control catalogs and control-to-requirement mappings (GRC tools or spreadsheets)
• POA&Ms and remediation governance
• Contractual compliance where a prime, agency, or customer references NIST SP 800-171

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

1) Confirm the baseline and lock the interpretation

• Record in your compliance baseline statement that you are aligning to NIST SP 800-171 Rev. 3, and that 03.14.05 is Withdrawn per the framework text. ¹
• Assign an owner for “framework change management” (often GRC lead or ISSO) to prevent drift between templates and current requirements.

Deliverable: Baseline memo or SSP “Applicable Standards” section update.

2) Update your control mapping so assessors don’t see a “gap”

In your control crosswalk (requirement-to-control mapping):

• Set 03.14.05 status to Withdrawn ¹. ¹
• Provide a short rationale note: “Control withdrawn in Rev. 3; no implementation required; retained for numbering continuity and audit traceability.” ¹
• Ensure the mapping does not auto-create POA&Ms for withdrawn items.

Practical tip: Many GRC tools default unknown requirements to “Not Implemented.” Override that label for withdrawn items to avoid false deficiency reporting.

3) Reconcile SSP content (avoid internal contradictions)

In the SSP:

• If you have a control statement library, ensure no control narrative references “03.14.05” as implemented.
• If you inherit a template that includes a stub for 03.14.05, replace it with a one-line “Withdrawn” statement and link it back to the mapping entry. ¹
• Validate your SSP-to-POA&M linkage: withdrawn items should not appear as open weaknesses.

4) Check contracts and customer overlays (the real-world trap)

Even if NIST withdrew the requirement, your contract might:

• Reference a different revision,
• Include an overlay that still asks for it,
• Or include a prime’s “minimum controls list” that hasn’t been updated.

Action steps:

• Search active contracts/SOWs/security addenda for “800-171,” “03.14.05,” and “3.14.5/3.14.05” formatting variants.
• If found, open a compliance question to the contract owner and customer/prime: “NIST SP 800-171 Rev. 3 lists 03.14.05 as withdrawn; confirm whether you still expect an equivalent control, or whether ‘withdrawn’ is acceptable.” ¹
• Document the response and store it with the SSP package.

5) Put it under change control

Treat this as a documentation control:

• Add the mapping update and SSP edit to your change log (who changed, what changed, approval).
• Add a quick quality check: “Withdrawn requirements present? Marked as Withdrawn? No POA&Ms spawned?”

6) Operationalize recurring evidence collection (so it stays clean)

Withdrawn items tend to reappear during:

• Annual SSP refresh,
• Tool migrations,
• New assessment prep.

Set a recurring control hygiene task:

• Re-run your crosswalk completeness check and confirm withdrawn entries remain correctly labeled.

Where Daydream fits naturally: Daydream can track requirement mappings to SSP statements, owners, and evidence expectations so withdrawn entries stay explicitly governed and don’t silently become “missing controls” during updates.

Required evidence and artifacts to retain

Keep a tight evidence packet. Auditors want traceability, not volume.

Minimum artifacts:

• SSP excerpt showing 03.14.05 marked as Withdrawn, with a short rationale. ¹
• Control crosswalk/export (spreadsheet or GRC report) showing:
  • Requirement ID 03.14.05
  • Status = Withdrawn
  • Reference to Rev. 3 as authority ¹
  • Owner and date last reviewed
• Change record (ticket, PR, or approval log) showing the mapping/SSP update and approver.
• Contract review notes (if applicable): search results, contract excerpts, customer/prime confirmation, and final determination.
• POA&M snapshot proving 03.14.05 is not tracked as an open deficiency.

Common exam/audit questions and hangups

Assessors, primes, and internal audit teams commonly ask:

• “Why is 03.14.05 missing from your SSP/control list?”

  • Answer: “It is withdrawn in NIST SP 800-171 Rev. 3 and is explicitly marked Withdrawn in our SSP and crosswalk.” ¹

• “Show me where you documented the decision.”

  • Provide the SSP excerpt, crosswalk entry, and change ticket.

• “Is your contract based on Rev. 3?”

  • Show the contract clause or your compliance baseline statement. If it’s ambiguous, show the customer/prime confirmation.

• “Did you replace it with something else?”

  • Avoid inventing a compensating control unless a contract requires it. If you did map it to an internal control for customer reasons, document it as a contractual overlay, not a NIST requirement.

Frequent implementation mistakes and how to avoid them

Mistake	Why it becomes a finding	Fix
Marking 03.14.05 as “N/A” or “Not Implemented”	Looks like a control gap or scoping failure	Use a distinct “Withdrawn” label and cite Rev. 3 1
Creating a POA&M item for it	Wastes remediation time and can confuse scoring/closure	Exclude withdrawn items from deficiency tracking; keep only a mapping note
Leaving the SSP template stub blank	Assessors interpret blanks as incomplete documentation	Replace with an explicit one-line withdrawn statement 1
Failing to check contract language	A customer can still expect legacy control behavior	Do a targeted contract search and document the outcome
Tool migration resets labels	Withdrawn can revert to “unanswered”	Add a control hygiene check to your SSP refresh process

Enforcement context and risk implications

No public enforcement cases were provided for this specific requirement in the supplied sources, and NIST SP 800-171 is commonly assessed through contractual and programmatic mechanisms rather than direct regulatory enforcement actions. ¹

Your practical risk is assessment friction:

• A withdrawn requirement that appears “missing” can cause extra scrutiny of your SSP quality, your mapping discipline, and your change management.
• Confusion here can bleed into broader doubts about whether your SSP and POA&M accurately reflect control operation and remediation governance for CUI systems. ¹

A practical execution plan (30/60/90)

You asked for fast operationalization. Use these phases as an execution checklist.

First 30 days (stabilize documentation)

• Update SSP and crosswalk to mark 03.14.05: withdrawn requirement as Withdrawn with Rev. 3 citation. ¹
• Add a change record and assign an owner.
• Run a contract keyword search; flag any documents that still require 03.14.05 explicitly.

Next 60 days (reconcile downstream dependencies)

• Resolve any contract/prime/customer references and document outcomes.
• Update internal assessment scripts and auditor request lists so the team can answer “why withdrawn” consistently.
• Ensure POA&M governance excludes withdrawn items from deficiency queues.

Next 90 days (make it durable)

• Add a recurring “withdrawn requirement check” to your SSP annual review and any GRC tool import/export process.
• Train control owners and proposal/contract teams on how to respond to questionnaires that still reference 03.14.05.
• If you use Daydream or another GRC platform, codify Withdrawn as an allowed requirement state and require an approval trail for state changes.

Frequently Asked Questions

If 03.14.05 is withdrawn, can I delete it from my SSP?

Keep it as a placeholder entry marked “Withdrawn” so your numbering stays consistent and assessors see intentional handling. Deleting it entirely often triggers “missing requirement” questions. ¹

Should I create a compensating control anyway?

Only if a contract, prime requirement, or customer overlay explicitly expects behavior equivalent to the withdrawn item. Otherwise, treat it as withdrawn and document that decision in the SSP and mapping. ¹

What’s the best evidence to show an assessor?

A clean crosswalk entry marked Withdrawn with the Rev. 3 citation, plus the SSP section that mirrors the same status. Add a change ticket showing who approved the update. ¹

My GRC tool doesn’t have a “Withdrawn” status. What do I do?

Create a custom status or an exception tag and standardize the label across exports. Avoid “N/A” if it will be interpreted as scoping; you want “Withdrawn per Rev. 3” in plain text. ¹

A third party questionnaire still asks for 03.14.05. How should we respond?

Respond that the requirement is withdrawn in NIST SP 800-171 Rev. 3 and provide your SSP/crosswalk excerpt. If the requester insists, route it through contracts to confirm whether they are using an older baseline. ¹

Could an assessor still score this as a deficiency?

If your documentation is inconsistent (missing from SSP, appears as “not implemented,” or shows an open POA&M item), it can create assessment issues. Make the withdrawn status explicit and consistent across artifacts. ¹

Footnotes

1. NIST SP 800-171 Rev. 3