03.01.19: Withdrawn

A withdrawn requirement creates a specific kind of risk: teams either waste time building a control that is no longer required, or they fail to document why the control is absent and get flagged in an assessment as incomplete. For a CCO, Compliance Officer, or GRC lead, the job is to make the withdrawal operationally real across your control library, system security plan (SSP), and assessment workflow.

NIST SP 800-171 Rev. 3 lists 03.01.19 as “Withdrawn.” (NIST SP 800-171 Rev. 3) That single word changes the work. Your deliverable is not technical implementation; it is defensible governance: clear mapping, clear rationale, and repeatable evidence that you recognized the withdrawal and confirmed it does not conflict with contract language or customer requirements for your nonfederal systems handling CUI.

This page gives you requirement-level implementation guidance you can put into your SSP and control matrix immediately, plus the artifacts assessors expect to see. It also covers the most common hangups: “Should we implement the Rev. 2 version anyway?”, “How do we mark this in the SSP?”, and “How do we prove we didn’t miss something?”

Regulatory text

Excerpt: “NIST SP 800-171 Rev. 3 requirement 03.01.19 (Withdrawn).” (NIST SP 800-171 Rev. 3)

What that means for an operator

A withdrawn requirement means NIST SP 800-171 Rev. 3 no longer expects organizations to implement a discrete control statement for 03.01.19. Your operational obligation is to:

1. Record that the requirement is withdrawn in your compliance documentation, and
2. Prevent downstream confusion (internal teams, assessors, customers) by clearly marking it as not applicable due to withdrawal, with supporting rationale and a review mechanism. (NIST SP 800-171 Rev. 3)

Do not stop at “N/A.” Assessors often test whether “N/A” is thoughtful or lazy. Your evidence should show you made a decision, checked for overlays, and placed the result under change control.

Plain-English interpretation (what the requirement is asking)

For the 03.01.19: withdrawn requirement, the requirement is effectively:

• “Acknowledge this control no longer exists in Rev. 3, and keep your compliance system aligned with the Rev. 3 catalog.” (NIST SP 800-171 Rev. 3)

Operationally, you are implementing control governance: crosswalk hygiene, SSP accuracy, and assessment readiness.

Who it applies to

This applies when:

• You are a federal contractor or subcontractor handling CUI in nonfederal systems, or otherwise scoping NIST SP 800-171 Rev. 3 into your compliance obligations. (NIST SP 800-171 Rev. 3)
• You maintain an SSP, policies/standards, a control matrix, and assessment artifacts for NIST SP 800-171.
• You rely on third parties (MSPs, cloud providers, SaaS platforms) that touch CUI and therefore influence your SSP narratives and control inheritance decisions.

Operational contexts where withdrawn requirements cause real friction:

• Contract transitions (older language referencing prior revisions)
• Assessment preparation (control-by-control evidence pulls)
• Tooling migrations (GRC platforms importing older control catalogs)

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

Step 1: Confirm the withdrawal and freeze the control statement

• In your control library, set 03.01.19 status to Withdrawn (Rev. 3) and prevent anyone from re-adding a legacy control statement without a formal exception. (NIST SP 800-171 Rev. 3)
• If you maintain multiple catalogs (Rev. 2 legacy, customer overlays), label the older requirement as “legacy reference only” and point to the Rev. 3 withdrawal.

Operator tip: This is a common place where “helpful” engineers create work. Lock it down with governance.

Step 2: Update SSP and control matrix mapping

Update these locations, explicitly:

• SSP control table: Mark 03.01.19 as Withdrawn with a one-line rationale that cites Rev. 3. (NIST SP 800-171 Rev. 3)
• Control implementation statement: “Withdrawn in NIST SP 800-171 Rev. 3; no standalone implementation required. Reviewed for contract overlays; none identified.”
• Crosswalks: If you map to other frameworks (ISO 27001, NIST CSF), keep the mapping but annotate that the specific NIST requirement is withdrawn.

Step 3: Check contract and customer overlays (the real risk)

Because NIST withdrew the requirement, your contract might still reference older language. Run a targeted review:

• Prime contract, subcontract terms, and security addenda
• Customer “supplier security requirements” documents
• Flow-downs from primes or managed service agreements that mention NIST SP 800-171 without revision clarity

Document the outcome as a memo (even if the answer is “none found”). If you do find an overlay, treat it as a customer requirement or contractual obligation, not a NIST requirement, and implement accordingly.

Step 4: Decide how you will treat evidence requests in assessments

Assessors may still ask: “Where is 03.01.19?” Your playbook should be:

• Provide the SSP/control matrix row showing Withdrawn (with citation to Rev. 3). (NIST SP 800-171 Rev. 3)
• Provide the overlay review memo showing you checked for contractual carryover.
• If relevant, show a change ticket or GRC workflow approval for the withdrawn status.

Step 5: Put it on a lightweight recurring review cadence

Withdrawn items still drift back into scope when:

• New contracts arrive
• A prime imposes a legacy matrix
• Your GRC tool updates content packs

Add a recurring control-library QA checkpoint: “Withdrawn requirements unchanged; overlays re-checked for new contracts.” Keep evidence of the check.

Step 6: Automate the mapping and evidence trail (where Daydream fits naturally)

If you manage multiple requirement sources and customer overlays, manual crosswalk hygiene breaks first. Daydream can track requirement states (like withdrawn), maintain SSP-ready mappings, and schedule recurring evidence tasks so your team does not rebuild retired controls or lose audit context during turnover.

Required evidence and artifacts to retain

Keep these artifacts in your audit repository (and link them in your SSP/control matrix):

1. SSP excerpt or control matrix row for 03.01.19 showing status “Withdrawn” and rationale. (NIST SP 800-171 Rev. 3)
2. Control catalog change record (ticket, pull request, or GRC change log) showing who set it to withdrawn and when.
3. Overlay review memo (one page is fine): contracts reviewed, documents checked, outcome, owner approval.
4. Assessment response snippet (optional but helpful): a standard response you paste into assessor Q&A portals.
5. Recurring review evidence: meeting notes, checklist completion, or GRC task completion confirming it remains withdrawn and overlays were rechecked.

Common exam/audit questions and hangups

Expect these questions and prepare short, document-backed answers:

• “Why is 03.01.19 missing from your implementation?”
  Answer with SSP row + Rev. 3 citation + overlay memo. (NIST SP 800-171 Rev. 3)

• “Show me the procedure/control that satisfies 03.01.19.”
  Reframe: no standalone control exists; show governance artifacts and the withdrawal documentation. (NIST SP 800-171 Rev. 3)

• “Which withdrawn items did you mark N/A, and who approved?”
  Provide change control evidence and your withdrawn-requirements register.

• “How do you ensure your GRC tool didn’t import an outdated catalog?”
  Show catalog versioning and the change log that reconciled content to Rev. 3. (NIST SP 800-171 Rev. 3)

Frequent implementation mistakes and how to avoid them

Mistake	Why it causes findings	How to avoid
Leaving 03.01.19 blank (no row, no note)	Assessors read blanks as “missed control”	Keep a visible row marked “Withdrawn” with rationale. (NIST SP 800-171 Rev. 3)
Marking “N/A” without explanation	“N/A” is not a justification	Use “Withdrawn in Rev. 3” and add overlay review evidence.
Building a technical control anyway	Wastes time; creates inconsistent narratives	Only implement if a contract/customer overlay requires it.
Forgetting subcontractor/prime flow-downs	Legacy matrices can still be enforced contractually	Add overlay checks to intake and contract review.
Tool-driven drift (catalog changes)	Automated mappings can reintroduce old requirements	Version-control your control library and reconcile to Rev. 3 routinely. (NIST SP 800-171 Rev. 3)

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so the practical risk to manage is assessment failure risk and contract performance risk, not a known enforcement pattern.

What actually goes wrong in practice:

• You get an assessment “gap” because your evidence pack assumes every control has an implementation narrative.
• A customer insists on a legacy requirement because their template is outdated. If you cannot show you evaluated the request, the dispute becomes time-consuming and expensive to resolve.

Treat this as a documentation control with contractual awareness.

Practical 30/60/90-day execution plan

First 30 days (stabilize documentation)

• Update control library entry for 03.01.19: withdrawn requirement to “Withdrawn in Rev. 3.” (NIST SP 800-171 Rev. 3)
• Update SSP and control matrix rows; add rationale text and citation. (NIST SP 800-171 Rev. 3)
• Create an assessor-ready Q&A response template and store it with the SSP.

Days 31–60 (confirm overlays and prevent rework)

• Complete the overlay review for active contracts and common customer templates; store the memo.
• Add a governance gate: changes to withdrawn items require GRC approval.
• Validate your GRC tooling/catalog import settings align to Rev. 3 content. (NIST SP 800-171 Rev. 3)

Days 61–90 (operationalize and scale)

• Add withdrawn-requirements checks to onboarding for new contracts and new systems handling CUI.
• Run an internal tabletop: “Assessor asks for 03.01.19 evidence.” Confirm the team can answer in minutes.
• If you use Daydream, configure recurring tasks for catalog QA and evidence retention so the withdrawn status stays correct through staff turnover.

Frequently Asked Questions

What does “03.01.19: withdrawn requirement” mean in NIST SP 800-171 Rev. 3?

It means NIST SP 800-171 Rev. 3 lists 03.01.19 as withdrawn, so Rev. 3 no longer expects a standalone control implementation for that item. Your job is to document the withdrawal and keep assessment artifacts consistent with Rev. 3. (NIST SP 800-171 Rev. 3)

Should we implement the older Rev. 2 version anyway to be safe?

Only if a contract, customer requirement, or flow-down explicitly requires the legacy behavior. Otherwise, implement governance: mark it withdrawn, document the rationale, and keep overlay review evidence. (NIST SP 800-171 Rev. 3)

How do we show compliance for a withdrawn control during an assessment?

Provide the SSP/control matrix row stating “Withdrawn in Rev. 3,” the citation to Rev. 3, and a memo showing you checked contracts for overlays. That package answers “why nothing is implemented” with defensible documentation. (NIST SP 800-171 Rev. 3)

Can we mark 03.01.19 as “Not Applicable” and move on?

Yes, but add specificity: label it “Withdrawn (Rev. 3)” and include a short justification. Plain “N/A” without context often triggers follow-up questions.

What if our prime contractor’s checklist still includes 03.01.19?

Treat that as a contractual negotiation and documentation task. Share the Rev. 3 withdrawal reference, ask whether they require a legacy implementation as an overlay, and document the resolution in writing. (NIST SP 800-171 Rev. 3)

What artifacts are most likely to be requested by auditors?

The SSP/control matrix mapping that clearly marks 03.01.19 as withdrawn, plus change control evidence and the overlay review memo. Keep them together so the assessor does not need to hunt across systems. (NIST SP 800-171 Rev. 3)