03.01.14: Withdrawn

A withdrawn control creates a predictable failure mode in audits: teams either ignore it entirely (leaving gaps in traceability), or they keep an old implementation in place and can’t explain why it exists. For a Compliance Officer, CCO, or GRC lead, the fastest path is to treat 03.01.14: withdrawn requirement as a structured exception in your control baseline. Your goal is not to “implement” 03.01.14. Your goal is to prove that you recognized it as withdrawn, updated governance artifacts accordingly, and removed any stale references that could confuse an assessor or weaken your System Security Plan (SSP).

NIST SP 800-171 assessments are documentation-driven as much as they are technical. If your SSP, control matrix, policies, or procedures still reference 03.01.14 as active (or omit it without explanation), you create avoidable friction in review and risk an “incomplete mapping” finding. This page gives you requirement-level implementation guidance to operationalize withdrawn status: how to document it, who must sign off, what evidence to retain, and how to prevent it from reappearing in templates and inherited control sets (NIST SP 800-171 Rev. 3).

Requirement: 03.01.14: withdrawn requirement (NIST SP 800-171 Rev. 3)

Plain-English interpretation

03.01.14 is withdrawn in NIST SP 800-171 Rev. 3. That means there is no current requirement text to implement, test, or produce operational evidence for as a discrete control objective. Your obligation is procedural: reflect its withdrawn status in your compliance mapping, ensure you are not relying on outdated control language, and maintain defensible documentation showing how you handled the change (NIST SP 800-171 Rev. 3).

In practice, assessors want to see that:

• your SSP/control matrix aligns to the current revision,
• you did not “lose” the requirement in translation, and
• you do not have unresolved POA&M items tied to a control that no longer exists.

Regulatory text

Regulatory excerpt: “NIST SP 800-171 Rev. 3 requirement 03.01.14 (Withdrawn).” (NIST SP 800-171 Rev. 3)

Operator meaning: You should not build or claim a separate safeguard for 03.01.14. You should document the requirement as withdrawn, remove/retire legacy mappings tied to 03.01.14, and ensure your SSP and supporting procedures do not cite it as an active obligation (NIST SP 800-171 Rev. 3).

Who it applies to (entity and operational context)

This applies to any nonfederal organization that implements NIST SP 800-171 Rev. 3 to protect CUI, including:

• defense contractors and subcontractors,
• federal contractors more broadly,
• nonfederal systems handling CUI under contractual requirements (NIST SP 800-171 Rev. 3).

Operationally, this matters most for teams running:

• SSP maintenance and control ownership,
• internal control testing / readiness assessments,
• POA&M governance,
• evidence collection and audit response workflows.

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

Treat this as a baseline hygiene and documentation control. The steps below are written to be executed quickly and defended in an assessment.

Step 1: Update your control inventory / matrix to explicitly mark “Withdrawn”

1. Locate where you track NIST SP 800-171 requirements (control matrix, GRC tool, spreadsheet, SSP appendix).
2. Add or update the entry for 03.01.14 with status: Withdrawn.
3. Add a short rationale note: “Withdrawn in NIST SP 800-171 Rev. 3; no standalone implementation required.” Cite the source (NIST SP 800-171 Rev. 3).
4. Assign an owner anyway (often the SSP owner or GRC lead) so the status can’t drift.

Audit lens: An assessor who sees 03.01.13 and 03.01.15 will expect 03.01.14 to be accounted for. Explicitly marking it avoids the “missing requirement” argument.

Step 2: Purge stale references across your SSP, policies, procedures, and templates

Perform a targeted search for “03.01.14” and any legacy statement your organization previously associated with it.

• SSP control narratives: remove or annotate old descriptions.
• Procedures/runbooks: remove references that instruct staff to execute a withdrawn requirement.
• Policy citations: ensure you’re not listing withdrawn controls as “required by NIST.”

If you must keep historical references (for contract or internal traceability), tag them clearly as “Withdrawn in Rev. 3” and avoid language that implies it is currently required (NIST SP 800-171 Rev. 3).

Step 3: Decide how you treat any existing technical or procedural safeguard that “used to satisfy” 03.01.14

A withdrawn requirement does not automatically mean a safeguard is bad. It means NIST no longer expresses it as a discrete requirement in Rev. 3.

1. Identify any controls you previously mapped to 03.01.14.
2. Re-map them to the correct current requirement(s) if they still support CUI protection.
3. If a safeguard no longer has a home, decide to:
   • keep it as an internal control (document why), or
   • retire it through change management.

Common operator call: Keep the safeguard if it meaningfully reduces risk, but stop claiming it as “required for 03.01.14.” Tie it to the correct current control objective or your internal baseline (NIST SP 800-171 Rev. 3).

Step 4: Clean up POA&M items tied to 03.01.14

Withdrawn requirements create messy POA&Ms.

• Find any open POA&M items labeled 03.01.14.
• If work is still needed for security reasons, re-scope the POA&M item under the correct active requirement.
• If it was solely to satisfy 03.01.14, close it with evidence and a closure note: “Control withdrawn in Rev. 3; item closed or re-mapped.” Cite the source (NIST SP 800-171 Rev. 3).

Do not simply delete POA&M history. Retain the audit trail and show the decision path.

Step 5: Add a “withdrawn requirements handling” rule to your governance process

This prevents recurrence when templates get reused.

• In your SSP maintenance SOP, add a rule: “Withdrawn requirements remain listed with ‘Withdrawn’ status and rationale; they are not tested as active controls.”
• In your control testing plan, include a rule: “Withdrawn requirements are excluded from testing; verify documentation accuracy and mapping completeness instead.”

Step 6: Validate with an internal readiness check

Before an external assessment:

• confirm the SSP/control matrix includes 03.01.14 with withdrawn status,
• verify no active narratives, tests, or tickets reference it incorrectly,
• confirm your evidence repository has the mapping decision record.

Required evidence and artifacts to retain

You are proving governance, traceability, and change control. Retain:

SSP and mapping artifacts

• SSP excerpt/control matrix entry showing 03.01.14 marked “Withdrawn” with a citation to NIST SP 800-171 Rev. 3 (NIST SP 800-171 Rev. 3).
• Mapping rationale note (short, dated, with approver).

Change control artifacts

• Ticket/change record showing SSP updates and template/policy reference cleanup.
• Version history or redlines for SSP/procedure updates.

POA&M artifacts

• POA&M export showing re-mapped items or closure notes tied to withdrawal (NIST SP 800-171 Rev. 3).
• Closure validation record if any remediation work was completed and then closed.

Assessment artifacts

• Internal readiness checklist showing 03.01.14 accounted for and excluded from active testing due to withdrawal.

A simple rule: if an assessor asks “Where is 03.01.14 handled?”, you should answer in under a minute and open the exact SSP section that shows it.

Common exam/audit questions and hangups

Expect these lines of questioning:

• “Why is 03.01.14 missing from your matrix?”
  Fix: It should not be missing; it should be present and marked withdrawn (NIST SP 800-171 Rev. 3).
• “You have a procedure that references 03.01.14. Is it required?”
  Fix: Update/retire the procedure reference and document the change control.
• “You closed a POA&M item because the requirement is withdrawn. How did you confirm the risk is acceptable?”
  Fix: Show re-mapping to other active requirements or a risk decision record aligned to CUI protection goals (NIST SP 800-171 Rev. 3).

Frequent implementation mistakes and how to avoid them

Mistake	Why it hurts you	Fix
Omitting 03.01.14 entirely	Looks like incomplete mapping or a missed control	Keep it listed as “Withdrawn” with rationale (NIST SP 800-171 Rev. 3)
Leaving legacy narratives in the SSP	Creates contradictions (“implemented” vs “withdrawn”)	Remove or annotate and version-control the update
Closing POA&M items with no trail	Raises governance questions	Close with dated rationale and approver; retain history
Treating “withdrawn” as “ignore”	Leads to stale templates and recurring audit friction	Add withdrawn-handling rules to SSP maintenance and testing SOPs
Continuing to test it	Wastes time and can create conflicting evidence	Exclude from testing; test the mapping accuracy instead

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this specific withdrawn item. The practical risk is contractual and assessment-driven: if you represent NIST SP 800-171 alignment for a CUI environment, weak traceability and outdated control references can undermine confidence in your SSP and POA&M governance (NIST SP 800-171 Rev. 3). That translates into slower assessments, more follow-up questions, and findings that are avoidable with basic documentation discipline.

Practical execution plan (30/60/90-day format, without calendar claims)

Use this as an execution sequence. Adapt timing to your release cycle and assessment dates.

First phase (triage and alignment)

• Mark 03.01.14 as “Withdrawn” in the control matrix/SSP crosswalk (NIST SP 800-171 Rev. 3).
• Identify where 03.01.14 appears in SSP, policies, procedures, test plans, and evidence folders.
• Open change tickets for document updates and assign owners.

Second phase (cleanup and re-mapping)

• Remove or annotate all stale references to 03.01.14 in operational documentation.
• Re-map any existing safeguards to the correct active requirement(s) or document them as internal controls.
• Review POA&M: re-scope or close items tied to 03.01.14 with retained history and sign-off.

Third phase (institutionalize and prove repeatability)

• Update SSP maintenance SOP and assessment/testing methodology to include a “withdrawn requirement handling” rule.
• Run an internal readiness review: confirm the withdrawn status is consistently reflected, and evidence is stored in your audit repository.
• If you use a GRC platform, configure a control status taxonomy that includes “Withdrawn,” and require rationale plus approver. Daydream can help keep SSP/control mappings and POA&M workflows synchronized so withdrawn items don’t reappear in recycled templates during the next assessment cycle.

Frequently Asked Questions

What does “03.01.14: withdrawn requirement” mean for my compliance scope?

It means NIST SP 800-171 Rev. 3 no longer defines an active requirement at 03.01.14, so you don’t implement it as a standalone control. You still include it in your mapping as “Withdrawn” with a citation and rationale (NIST SP 800-171 Rev. 3).

Should I remove 03.01.14 from my SSP entirely?

Don’t remove it if your SSP or matrix enumerates requirements sequentially. Keep it listed as “Withdrawn” so assessors see that you accounted for it rather than missing it (NIST SP 800-171 Rev. 3).

We have an internal control mapped to 03.01.14 from a previous baseline. Do we turn it off?

Not automatically. Re-map it to an active requirement if it still supports CUI protection, or keep it as an internal control with a documented rationale and owner (NIST SP 800-171 Rev. 3).

How do I handle POA&M items that reference 03.01.14?

Preserve the audit trail. Re-scope the item to the correct active requirement if remediation is still needed, or close it with a withdrawal-based rationale and approval record (NIST SP 800-171 Rev. 3).

Will assessors expect evidence (logs/screenshots) for 03.01.14?

They should not expect operational evidence for a withdrawn requirement as an active control. They may expect evidence that your SSP/mapping is current and that you governed the change cleanly (NIST SP 800-171 Rev. 3).

What is the fastest way to prevent withdrawn controls from resurfacing in templates?

Add an explicit “Withdrawn requirements handling” rule to your SSP maintenance SOP and control testing plan, and require approval for any control-matrix changes. Then store the mapping rationale alongside your SSP evidence package (NIST SP 800-171 Rev. 3).