03.01.17: Withdrawn

A withdrawn control causes real operational problems if you treat it casually. Teams leave old test steps in the audit workbook, keep a “phantom” POA&M item open, or cite the requirement in policies long after it disappeared. Then an assessor asks a simple question: “Show me how you meet 03.01.17,” and you either scramble or contradict your own documentation.

For 03.01.17: withdrawn requirement, the win condition is clean governance: your System Security Plan (SSP) reflects the current framework text, your crosswalks do not map production safeguards to a control that no longer exists, and your evidence set shows you actively manage framework updates rather than letting them drift. This is especially relevant for defense contractors, federal contractors, and any nonfederal organization handling CUI in scope for NIST SP 800-171 assessments. ¹

This page gives you requirement-level implementation guidance for operationalizing the withdrawal quickly: what to change, what to keep, what to show an auditor, and what mistakes trigger rework.

Regulatory text

Excerpt / status: “NIST SP 800-171 Rev. 3 requirement 03.01.17 (Withdrawn).” ¹

What the operator must do

Because 03.01.17 is explicitly withdrawn, there is no standalone security control objective to implement under this identifier. Your operational obligation shifts to program integrity:

• Your SSP and control catalog must reflect that 03.01.17 is withdrawn and is not assessed as an active requirement. ¹
• Your internal mappings (crosswalks to policies, procedures, system components, and test steps) must not incorrectly reference 03.01.17 as a live requirement.
• Your POA&M must not track a gap against a withdrawn requirement as if it were still required; instead, you should close, re-scope, or re-map the item with a documented rationale.

This is a documentation and governance requirement in practice: you are proving you can maintain alignment to the current version of the framework text. ¹

Plain-English interpretation (what “withdrawn” means in practice)

“Withdrawn” means NIST SP 800-171 Rev. 3 no longer includes an enforceable expectation under that control number. You should not spend engineering time building new safeguards specifically to satisfy 03.01.17. Instead, you should:

• Confirm the control’s former intent is either covered elsewhere in Rev. 3 or no longer required under this framework.
• Prevent stale references from creating assessment confusion.
• Preserve a clean audit trail that you noticed the withdrawal, evaluated impact, and updated your compliance system accordingly. ¹

A practical way to think about it: auditors don’t “test” a withdrawn requirement, but they do test whether your compliance program is current, internally consistent, and evidence-backed.

Who it applies to (entity and operational context)

This applies to organizations that implement NIST SP 800-171 for CUI protection, including:

• Defense contractors
• Federal contractors
• Nonfederal systems handling CUI ¹

Operationally, it applies to the people and artifacts that define and prove your program:

• SSP authors and system owners responsible for CUI-scoped enclaves and connected services
• GRC teams maintaining control libraries, crosswalks, assessment workpapers, and POA&Ms
• Internal audit or assessment teams validating control design and operating effectiveness evidence

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

Use this as a short execution runbook. The goal is “no dangling references, no phantom gaps, clean evidence.”

Step 1: Locate every reference to 03.01.17

Search across:

• SSP sections (control implementations, summaries, inheritance statements)
• Control matrix / crosswalks (NIST-to-policy, NIST-to-system components, NIST-to-procedures)
• Assessment procedures and test scripts
• POA&M items and risk register entries
• Policy documents that list control IDs

Operator tip: include attachments and spreadsheets. Withdrawn controls often survive in “versioned” evidence folders.

Step 2: Decide the disposition for each reference (remove, replace, or re-map)

For each occurrence, pick one path and document it:

Scenario	What to do	What to record
SSP lists an implementation for 03.01.17	Remove the section or mark as “Withdrawn” and move content to the correct active control if applicable	SSP change note + mapping note
Test script has a step for 03.01.17	Retire the step and update the test plan index	Test plan revision history
POA&M has an open item for 03.01.17	Close as “No longer applicable (withdrawn)” or re-map to the correct active requirement	POA&M closure rationale + approver
Policy cites 03.01.17	Update policy references to current control IDs	Policy redline + approval record

Keep the tone factual: you are aligning to Rev. 3 text. ¹

Step 3: Update SSP control statements and ownership mappings

Even though 03.01.17 is withdrawn, you still want your SSP to show mature governance:

• Maintain a control index that indicates 03.01.17 is withdrawn.
• Ensure every active requirement has: implementation statement, responsible system components, and an accountable control owner.

This aligns with strong practice: “Map the requirement to SSP control statements, responsible system components, and accountable control owners.” ¹

Step 4: Reconcile evidence collection and assessment cadence

Withdrawn controls create evidence sprawl. Clean it up:

• Remove scheduled evidence tasks tied to 03.01.17 from your compliance calendar.
• Keep a short “framework change log” entry that notes the withdrawal and the date you updated your artifacts.
• Confirm your recurring operational evidence focuses on active requirements: “logs, reviews, approvals, test outputs.” ¹

Step 5: Clean POA&M governance and validate closure

If anything referenced 03.01.17:

• Re-score or re-scope the risk impact if the underlying issue still exists but belongs elsewhere.
• If you close an item, capture closure validation (for example: updated crosswalk + updated SSP section + retired test procedure).
• Avoid marking “complete” without proof of disposition: “Track gaps in POA&M with target dates, risk ratings, and closure validation before marking complete.” ¹

Step 6: Prepare the “auditor-ready” explanation

You want a simple, consistent narrative:

• 03.01.17 is withdrawn in NIST SP 800-171 Rev. 3. ¹
• Your SSP/crosswalk reflects that status.
• Any legacy references were retired or re-mapped, with documented approvals.

If you use Daydream, this is where it earns its place: store the control status, attach SSP excerpts, map system components and owners, and keep a single evidence thread showing the withdrawal decision and downstream updates. That reduces the classic spreadsheet drift where one workbook still treats a withdrawn requirement as “open.”

Required evidence and artifacts to retain

Keep these artifacts in your assessment package:

1. SSP excerpt or control index page showing 03.01.17 marked as withdrawn (and not implemented as an active control). ¹
2. Framework change log / governance record (ticket, memo, or meeting minutes) documenting:
   • what changed (03.01.17 withdrawn),
   • what artifacts were reviewed,
   • what updates were made,
   • who approved.
3. Crosswalk revision history showing removal or re-mapping from 03.01.17 to active requirements (if applicable).
4. POA&M entries evidencing closure or re-mapping, including closure rationale and validation attachments.
5. Retired test procedures (archived) plus the updated current test plan.

Common exam/audit questions and hangups

Expect assessors and internal audit to probe consistency more than technical detail:

• “Where in your SSP do you address 03.01.17?”
  Desired response: “It is withdrawn in Rev. 3; here is our SSP index showing status and our change record.” ¹

• “Why does this spreadsheet still list 03.01.17 as ‘not met’?”
  Fix: retire the row or clearly label as withdrawn, and ensure rollups do not count it against compliance.

• “Show me the approval for closing the POA&M item.”
  Provide the closure workflow record and the artifact updates.

• “How do you ensure your control set stays current as NIST updates guidance?”
  Show a defined governance process: periodic review, tracked updates, and documented decisions.

Frequent implementation mistakes (and how to avoid them)

1. Leaving 03.01.17 in the SSP as “Implemented.”
   Avoid it by updating the SSP control index and removing the implementation narrative unless it is re-homed to an active requirement.

2. Closing a POA&M item as withdrawn without checking if the underlying weakness still matters.
   Fix: perform a quick “issue vs. control ID” review. If the issue is real, re-map it to the correct active requirement and keep it on the POA&M.

3. Breaking your scoring/rollup logic.
   If your dashboard counts withdrawn controls as failures, you will report false noncompliance. Exclude withdrawn requirements from pass/fail calculations.

4. No audit trail for the change.
   A withdrawn requirement is easy to handle; it becomes painful when you cannot show who decided what. Keep a change log entry and approvals.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so this page does not cite specific enforcement outcomes.

Operational risk still exists: inconsistent documentation can drive adverse assessment results, corrective actions, or delays in customer security reviews. Withdrawn controls often expose a broader weakness: weak configuration control over your compliance baseline (SSP, POA&M, and test procedures). For CUI programs, assessors expect current documentation and evidence-backed remediation governance. ¹

Practical execution plan (30/60/90)

You asked for speed, but the timeline must stay qualitative because no source-backed durations were provided.

First 30 days (Immediate cleanup)

• Run enterprise search for “03.01.17” across SSP, POA&M, policies, and test plans.
• Open a single tracking ticket for the withdrawal disposition with an approver (CCO/GRC lead).
• Update SSP index/control matrix to label 03.01.17 as withdrawn. ¹

Days 31–60 (Re-mapping and evidence hardening)

• Re-map any still-relevant control intent to the correct active requirement(s), if your program had real safeguards tied to the old ID.
• Close or re-scope POA&M items with documented validation attachments.
• Update assessment scripts and remove retired test steps.

Days 61–90 (Stabilize governance)

• Add “framework change management” to your compliance operating rhythm (agenda item, ticket workflow, or quarterly control library review).
• Run an internal “consistency check” between SSP, POA&M, and your assessment workbook so a withdrawn control cannot reappear.
• Centralize evidence and approvals in Daydream (or your GRC system) so assessors can trace changes without chasing email threads.

Frequently Asked Questions

What does “03.01.17: withdrawn requirement” mean for my CUI environment?

It means NIST SP 800-171 Rev. 3 no longer contains an active requirement under that identifier. You don’t implement a dedicated control for 03.01.17; you update your SSP/crosswalk and remove legacy references. ¹

Do I need to keep historical evidence that we previously met 03.01.17?

Keep archives only if your organization’s record retention policy requires it or if it supports audit trail continuity. For assessments, prioritize showing current alignment: the withdrawal status and your controlled updates to SSP, POA&M, and test plans. ¹

Our POA&M has an open item mapped to 03.01.17. Can we just close it?

Close it only if the underlying issue is no longer relevant; otherwise re-map the issue to the correct active requirement and keep it tracked. Retain closure or re-mapping approval and validation artifacts either way. ¹

How should 03.01.17 appear in our SSP?

List it as withdrawn in your control index or requirements matrix and ensure it does not appear as an implemented control with test steps and evidence requests. Keep a change record that shows when you updated the SSP to match Rev. 3. ¹

Will an assessor penalize us for not implementing 03.01.17?

They should not assess a withdrawn requirement as an unmet control, but they can flag inconsistent documentation and governance if your artifacts still treat it as active. Your best defense is a clean SSP/crosswalk and an auditable decision trail. ¹

What is the fastest way to prevent withdrawn controls from reappearing in spreadsheets?

Put withdrawn status into your system of record (GRC platform or Daydream), and drive assessment workpapers from that controlled library rather than copying old templates forward. Then run periodic consistency checks between SSP, POA&M, and testing artifacts. ¹

Footnotes

1. NIST SP 800-171 Rev. 3