03.01.15: Withdrawn

A withdrawn requirement is still an assessment landmine. In many programs, the control library, SSP narratives, POA&M templates, and GRC tooling lag behind the current revision of the framework. That gap creates confusion during internal assessments, customer audits, or CMMC-aligned reviews: teams waste time assembling evidence for a requirement that is no longer required, or worse, misstate compliance by marking it “implemented” without a real underlying safeguard.

For 03.01.15, NIST SP 800-171 Rev. 3 explicitly indicates the requirement is withdrawn (NIST SP 800-171 Rev. 3). Your job as a CCO/GRC lead is to make that operationally real across documentation, control ownership, and assessment workflows. That means: clearly scoping it out; documenting why it is withdrawn; ensuring your SSP and control crosswalks don’t reference it as active; and making sure assessors see a clean, current control baseline.

This page gives you requirement-level implementation guidance for the target keyword “03.01.15: withdrawn requirement,” focused on fast, defensible execution.

Regulatory text

Excerpt (framework text): “NIST SP 800-171 Rev. 3 requirement 03.01.15 (Withdrawn).” (NIST SP 800-171 Rev. 3)

Plain-English interpretation

03.01.15 has been removed from the Rev. 3 requirements set. Practically, that means you are not expected to design, implement, or operate a discrete safeguard tied to 03.01.15, and an assessor should not expect evidence for it. Your operational obligation is governance: keep your SSP, control inventory, and assessment scope aligned to the current version of NIST SP 800-171 Rev. 3 so withdrawn items do not create false requirements or inaccurate compliance claims (NIST SP 800-171 Rev. 3).

What the operator must do

• Do not implement or test a “03.01.15 control.” There is no requirement text to satisfy (NIST SP 800-171 Rev. 3).
• Do document disposition and scope. Your SSP and any control crosswalk should show 03.01.15 as “Withdrawn (Rev. 3)” with a short rationale and a pointer to your versioned baseline (NIST SP 800-171 Rev. 3).
• Do ensure your POA&M does not carry 03.01.15 items forward. If it appears, close it as “Removed/Withdrawn due to Rev. 3 baseline update,” with approval and change record.

Who it applies to

This affects any organization that claims alignment to NIST SP 800-171 Rev. 3 for systems that handle Controlled Unclassified Information (CUI), including:

• Defense contractors and subcontractors
• Federal contractors
• Nonfederal organizations handling CUI in support of federal work
  Applicability is especially important where your compliance artifacts are shared externally (prime contractors, government customers, or third-party assessors) and where your internal control library is reused across multiple frameworks (NIST SP 800-171 Rev. 3).

Operational contexts where withdrawn requirements cause friction:

• SSP authoring and updates for a CUI enclave or shared services boundary
• CMMC-aligned readiness assessments that import control IDs
• Tool-driven control catalogs that auto-generate test steps and evidence requests

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

1) Confirm the baseline and freeze the interpretation

1. Set the authoritative baseline: “NIST SP 800-171 Rev. 3 requirements list” as your source of truth (NIST SP 800-171 Rev. 3).
2. Create a formal interpretation note for 03.01.15: “Withdrawn in Rev. 3; no control implementation required; treat as not applicable due to withdrawal.”
3. Assign an owner (GRC lead or SSP owner) accountable for keeping the control catalog synchronized to the baseline.

2) Clean up your control library and mappings

1. Search and remove/retire references to 03.01.15 in:
   • Control catalog entries
   • Test procedures
   • Evidence requests
   • Policy cross-references
2. Update crosswalks (SSP-to-control mapping, customer matrices, internal control IDs):
   • Mark 03.01.15 as “Withdrawn (Rev. 3)”
   • Remove any linked system components, implementations, or owners that imply operation
3. Add a “Withdrawn requirements handling rule” in your control catalog governance:
   • Withdrawn = excluded from assessment scope
   • Documented with citation and version

Practical tip: if your GRC tool forces a status, avoid “Compliant/Implemented.” Use “Not Applicable” with the reason “Withdrawn in Rev. 3” and keep the citation in the field notes (NIST SP 800-171 Rev. 3).

3) Update the SSP in assessor-readable language

In the SSP, assessors look for clarity and consistency. Add a short entry in the relevant family/section where 03.01.15 would otherwise appear:

• Control ID: 03.01.15
• Implementation: Withdrawn in NIST SP 800-171 Rev. 3; excluded from system assessment scope
• Responsible role: SSP Owner (documentation governance)
• Evidence: Baseline reference and change log entry (NIST SP 800-171 Rev. 3)

This is also where you connect the requirement governance to your broader documentation hygiene: accurate mappings prevent assessors from issuing findings for missing evidence.

4) Reconcile the POA&M so it doesn’t create “zombie work”

1. Find POA&M items referencing 03.01.15.
2. Disposition each item:
   • If created solely due to 03.01.15: close as “Withdrawn requirement; removed from baseline.”
   • If the item reflects a real security gap: re-map it to the correct active requirement(s) and keep it open.
3. Document closure validation:
   • Approval by control owner + GRC
   • Link to baseline change record (NIST SP 800-171 Rev. 3)

5) Adjust testing and evidence operations

Even though 03.01.15 is withdrawn, your operational testing program must reflect that:

• Remove test scripts tied to 03.01.15.
• Update evidence collection checklists so analysts do not chase irrelevant logs or screenshots.
• Train control owners (short memo or enablement note): “Withdrawn means do not provide evidence; point assessors to SSP disposition.”

This aligns with a practical control pattern: define measurable implementation criteria and collect recurring evidence for active controls only (NIST SP 800-171 Rev. 3).

Required evidence and artifacts to retain

You are proving governance and baseline alignment, not control operation. Retain:

• SSP excerpt showing 03.01.15 marked as withdrawn and excluded from scope (NIST SP 800-171 Rev. 3)
• Control catalog entry with status “Withdrawn/Not Applicable,” including citation (NIST SP 800-171 Rev. 3)
• Change log / revision history for the SSP/control catalog update (who approved, what changed, date)
• POA&M cleanup records: closures or remaps with approvals
• Assessment procedures update: removed tests/evidence requests tied to 03.01.15

If you use Daydream to manage requirement mappings, keep the exported mapping report that shows 03.01.15 treated as withdrawn and not generating evidence tasks. That reduces assessor back-and-forth because the disposition is consistent across SSP, control catalog, and workflows.

Common exam/audit questions and hangups

Assessors and customer auditors tend to probe consistency:

• “Why is 03.01.15 missing from your evidence pack?”
  Answer: It is withdrawn in Rev. 3; show SSP disposition and baseline citation (NIST SP 800-171 Rev. 3).
• “Your crosswalk references 03.01.15, but your SSP does not.”
  Hangup: inconsistent artifacts. Fix by aligning the control catalog and crosswalk exports to the same baseline.
• “Is the risk addressed elsewhere?”
  If you had prior controls mapped to 03.01.15, explain how any underlying security objective is covered by other active requirements, or document that the item is obsolete. Do not claim equivalence unless you can show the mapping in your own artifacts.

Frequent implementation mistakes and how to avoid them

Mistake	Why it hurts	Avoid it by
Marking 03.01.15 as “Compliant”	Creates a false statement; invites evidence requests you can’t satisfy	Use “Withdrawn/Not Applicable” with a baseline citation (NIST SP 800-171 Rev. 3)
Leaving 03.01.15 in the POA&M	Keeps dead work alive; dilutes remediation reporting	Close/remap with an approval trail
Only updating the SSP (not the tool/library)	Crosswalk exports and evidence tasks stay wrong	Update SSP, control catalog, test scripts, and reporting templates together
Deleting references with no change record	Auditors read it as sloppy governance	Keep a change log entry and approval

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this specific withdrawn requirement, so treat enforcement risk here as programmatic rather than punitive. The main risk is assessment failure modes:

• Time sink and distraction during audits because teams chase non-existent evidence.
• Credibility hit if your documentation looks out of date relative to NIST SP 800-171 Rev. 3 (NIST SP 800-171 Rev. 3).
• Inaccurate compliance assertions in customer deliverables if you claim “full compliance” but your control set includes withdrawn items.

Practical 30/60/90-day execution plan

First 30 days (stabilize baseline and artifacts)

• Confirm your authoritative baseline is NIST SP 800-171 Rev. 3 (NIST SP 800-171 Rev. 3).
• Update SSP: add a clear withdrawn disposition entry for 03.01.15.
• Update control catalog: mark 03.01.15 withdrawn; remove owners, implementations, and tests.
• Identify and disposition POA&M items linked to 03.01.15.

Days 31–60 (align operations and assessment workflow)

• Update evidence request lists and test procedures to remove 03.01.15.
• Run an internal “documentation consistency check”: SSP vs control catalog vs crosswalk exports.
• Brief control owners and internal auditors on how to answer assessor questions about withdrawn requirements.

Days 61–90 (institutionalize governance)

• Add a recurring control-baseline review checkpoint to your SSP governance (triggered by NIST revisions or customer-required baselines) (NIST SP 800-171 Rev. 3).
• Standardize a template field: “Withdrawn/Deprecated handling” across your GRC system.
• Validate your next assessment package export: no phantom evidence tasks; withdrawn items show as excluded with citations.

Frequently Asked Questions

What does “03.01.15: withdrawn requirement” mean for my compliance scope?

It means 03.01.15 is no longer an active requirement in NIST SP 800-171 Rev. 3, so you exclude it from assessment scope. Your obligation is to document that exclusion clearly in the SSP and control catalog (NIST SP 800-171 Rev. 3).

Should I keep 03.01.15 in my SSP at all?

Keep it only as a disposition line item if your SSP format enumerates requirement IDs. Mark it “Withdrawn (Rev. 3)” and do not attach implementations or evidence (NIST SP 800-171 Rev. 3).

An auditor asked for evidence for 03.01.15. What do I show?

Provide the SSP entry showing it is withdrawn and your baseline reference to NIST SP 800-171 Rev. 3. Also show your change log demonstrating you maintain a current control set (NIST SP 800-171 Rev. 3).

Our GRC tool won’t allow “Withdrawn.” What status should we use?

Use “Not Applicable” with the reason “Withdrawn in NIST SP 800-171 Rev. 3,” and store the citation in the notes field. Then ensure reports and exports carry that rationale (NIST SP 800-171 Rev. 3).

What if we built a control for an older version that mapped to 03.01.15?

Do not remove the safeguard if it still reduces risk, but re-map it to the correct active requirement(s) or treat it as an internal best practice control. Update the POA&M and SSP mapping so 03.01.15 is not the anchor identifier (NIST SP 800-171 Rev. 3).

How do I prevent withdrawn requirements from reappearing in future audits?

Put version control around your control catalog and SSP, and require a baseline review before each assessment cycle. Tools like Daydream help by keeping requirement mappings current and consistent across SSP, evidence requests, and POA&M workflows (NIST SP 800-171 Rev. 3).