03.01.21: Withdrawn

For 03.01.21: withdrawn requirement, you do not implement a technical or procedural control because NIST SP 800-171 Rev. 3 lists it as Withdrawn. You operationalize it by proving you recognized the withdrawal, updated your control catalog and SSP accordingly, and can show assessors you did not miss a replacement requirement or leave an audit trail gap. ¹

Key takeaways:

• Treat 03.01.21 as a governance and evidence task: document “withdrawn” status, rationale, and mappings. ¹
• Update your SSP, control matrix, and POA&M logic so assessors don’t flag a missing control or “N/A” without support. ¹
• Confirm whether your contracts, customer overlays, or internal policies still reference “03.01.21” and remediate the mismatch.

Withdrawn requirements create a predictable assessment failure mode: teams either (a) keep an outdated control alive “just in case,” which adds scope and friction, or (b) delete the row and lose the audit trail, which looks like a documentation gap. For a CCO, GRC lead, or Compliance Officer running NIST SP 800-171 governance for CUI environments, 03.01.21: withdrawn requirement is a fast operational win if you treat it like configuration management for your compliance system.

NIST SP 800-171 Rev. 3 explicitly marks requirement 03.01.21 as Withdrawn. ¹ That means your job is not to guess what the control “should have been.” Your job is to show you have a reliable method to (1) ingest standard updates, (2) reflect them in your SSP/control set, and (3) prevent “ghost requirements” from lingering in policies, third-party expectations, or evidence schedules.

This page gives you requirement-level implementation guidance you can execute quickly: applicability, concrete steps, assessor-ready artifacts, common audit hangups, and a phased rollout plan that doesn’t create extra work.

Regulatory text

Excerpt / summary: “NIST SP 800-171 Rev. 3 requirement 03.01.21 (Withdrawn).” ¹

Plain-English interpretation (what it means)

• There is no control to implement for 03.01.21 in Rev. 3 because NIST withdrew it. ¹
• Your obligation is assessment hygiene: keep your compliance mappings accurate, prevent stale references, and retain enough evidence to show why this requirement is marked withdrawn in your program documentation. ¹

What an operator must do

You need an explicit, documented disposition for 03.01.21 that:

1. Marks it as Withdrawn in your control catalog/control matrix. ¹
2. Explains the treatment (for example: “No implementation required; withdrawn in Rev. 3; remove from testing plan and evidence calendar; verify no dependent internal policies/contractual clauses require an equivalent”).
3. Preserves traceability so an assessor can see you didn’t ignore a requirement; you processed a standards change.

Who it applies to (entity and operational context)

This matters if you run a NIST SP 800-171 program for:

• Nonfederal systems handling CUI, including regulated enclaves, shared services supporting those enclaves, and security boundary components. ¹
• Federal contractors and subcontractors where NIST SP 800-171 is flowed down contractually for CUI protection. ¹

Operational contexts where “withdrawn” items still cause findings:

• Your SSP/control matrix is used as the source for internal audits, customer assessments, or external certification readiness.
• A third party risk program asks suppliers for evidence against “all NIST controls,” and your team needs a defensible “withdrawn” response.
• Your policies or standard operating procedures still reference legacy numbering.

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

Step 1: Confirm the authoritative status and lock the citation

• Capture the authoritative statement that 03.01.21 is Withdrawn from the standard. ¹
• Store the reference in your GRC knowledge base so the answer is consistent across security, compliance, and procurement.

Output: “Requirement disposition record” for 03.01.21 with citation. ¹

Step 2: Update your control catalog/control matrix

In your control matrix row for 03.01.21:

• Set status to Withdrawn (not “Implemented,” not “Planned,” and not a silent deletion).
• Add “No control exists in Rev. 3; not assessable; removed from test plan.”
• Cross-reference any internal control IDs that previously mapped to it, and note their new parent mapping or retirement decision.

Operator tip: If your tool cannot represent “Withdrawn,” use “Not Applicable” plus a required justification field that explicitly says “Withdrawn per NIST SP 800-171 Rev. 3.” ¹

Step 3: Check for replacement or dependent expectations (don’t assume)

NIST’s withdrawal may mean the concept moved, merged, or was removed. Your job is to:

• Review your current NIST SP 800-171 Rev. 3 control set for coverage of the risk area your internal teams previously associated with 03.01.21. ¹
• Search your internal policy library, SSP narrative, and standards mappings for “03.01.21” references and update the text.

Decision rule:

• If the old internal control is still valuable (security benefit), keep it as an internal standard and map it elsewhere.
• If it existed only to satisfy 03.01.21, retire it with a documented rationale and approvals.

Step 4: Update SSP, assessment procedures, and evidence calendar

Make three aligned edits:

• SSP: mark the requirement “Withdrawn” and ensure no narrative claims implementation. ¹
• Test plan: remove test steps that validate 03.01.21 as a requirement.
• Evidence calendar: stop requesting recurring artifacts “for 03.01.21” and re-assign any still-needed artifacts to the correct active requirement(s).

Step 5: Fix downstream references (contracts, third parties, and questionnaires)

Where this breaks in practice:

• Customer security questionnaires may list “03.01.21” by number.
• A prime contractor might demand “evidence for all requirements.”

Create a standard response snippet:

• “03.01.21 is Withdrawn in NIST SP 800-171 Rev. 3; no implementation is required. We maintain a documented withdrawal disposition and update our SSP/control mappings accordingly.” ¹

Step 6: Put a change-control guardrail in place (so this doesn’t recur)

Add one procedural control to your compliance governance:

• A periodic standards intake review that flags Withdrawn/Added/Modified items and forces updates to: control matrix, SSP, test plan, and evidence schedule.

If you track controls in Daydream, treat this as a workflow requirement: a “Withdrawn” status should automatically generate tasks to update SSP text, retire evidence requests, and maintain an assessor-facing change log entry for the requirement.

Required evidence and artifacts to retain

Keep artifacts that show a deliberate, controlled disposition:

1. Control matrix entry showing 03.01.21 marked “Withdrawn,” with justification and citation. ¹
2. SSP excerpt or SSP change record reflecting the withdrawn status and removal of implementation narrative. ¹
3. Standards change log (simple is fine): date identified, owner, what changed, what documents were updated, and approval.
4. Policy/procedure update tickets showing references to 03.01.21 were removed or corrected.
5. Assessment plan update (or audit workpaper index) showing no testing is scheduled for withdrawn items.

Common exam/audit questions and hangups

Assessors and customer reviewers commonly press on a few points:

• “Why is this control missing?”
  Best answer: show the control matrix row marked Withdrawn with the standard citation. ¹

• “How do you know you didn’t miss a replacement?”
  Show your standards intake process (change log + review checklist) and the mapping review outcome.

• “Your SSP references 03.01.21 in a narrative section.”
  This is a classic documentation drift issue. Fix it, then show the SSP revision history.

• “Your evidence calendar still asks for 03.01.21 artifacts.”
  Demonstrate you re-homed the evidence to active requirements or retired the request.

Frequent implementation mistakes and how to avoid them

Mistake	Why it becomes a finding	How to avoid it
Deleting 03.01.21 from the matrix	Looks like an uncontrolled gap; assessor can’t see disposition	Keep the row, mark Withdrawn, cite the standard. 1
Marking as “Compliant” with evidence	Creates confusion and can expand scope unnecessarily	Treat as “Withdrawn / not assessable,” maintain only governance artifacts. 1
Leaving old policy references	Conflicting documentation triggers “inconsistent SSP/policy” notes	Run a targeted search across SSP, policies, and procedures for “03.01.21.”
Failing to notify stakeholders	Security, procurement, and third party risk teams keep requesting dead artifacts	Publish a short standards update note and update templates and questionnaires.

Enforcement context and risk implications

No public enforcement cases were provided for this specific withdrawn item. The practical risk is still real: a withdrawn requirement can produce avoidable audit friction, delayed assessments, and customer escalation if your documentation suggests you are out of sync with the standard. Treat it as a program maturity signal: clean change control builds confidence that your NIST SP 800-171 implementation is being actively governed. ¹

Practical 30/60/90-day execution plan

First 30 days (stabilize and document)

• Record the requirement disposition: “Withdrawn per NIST SP 800-171 Rev. 3” with citation. ¹
• Update the control matrix row and SSP section(s) that mention 03.01.21.
• Remove 03.01.21 from test procedures and evidence requests.

Days 31–60 (eliminate downstream drift)

• Search and remediate references in policies, procedures, and third party/security questionnaire templates.
• Validate internal controls previously tied to 03.01.21 are either re-mapped to active requirements or explicitly retired with approvals.
• Train control owners and GRC analysts on how withdrawn controls are handled (one-page SOP).

Days 61–90 (operationalize change control)

• Add “withdrawn/modified/added requirements review” to your standards governance cadence.
• Create an assessor-ready “standards delta” report format (what changed, what documents were updated, who approved).
• If you use Daydream or another GRC system, automate tasks triggered by a withdrawn status: SSP update, evidence calendar update, and change-log entry.

Frequently Asked Questions

What does “03.01.21: withdrawn requirement” mean for my control implementation?

It means there is no Rev. 3 control to implement for 03.01.21 because NIST withdrew it. Your task is to document the withdrawn status and keep your SSP/control matrix aligned. ¹

Should I keep collecting evidence for 03.01.21 anyway?

Don’t collect evidence “for 03.01.21.” Keep governance artifacts that show you processed the withdrawal, and only collect operational evidence if it maps to other active requirements.

Will assessors expect to see 03.01.21 in my SSP?

Many will expect to see a disposition to avoid ambiguity. Keep the row/entry and mark it Withdrawn with a citation to the standard. ¹

What if a customer or prime contractor questionnaire still asks about 03.01.21?

Respond with a standard statement that it is Withdrawn in NIST SP 800-171 Rev. 3 and provide your documented disposition if requested. ¹

Should I retire the internal control we previously mapped to 03.01.21?

Decide based on risk value and dependencies. If the control still reduces risk or supports other requirements, keep it and re-map it; if it existed only for 03.01.21, retire it with documented approval.

How do I prevent “withdrawn” items from becoming recurring audit noise?

Put a lightweight standards intake/change-control step in your GRC workflow: update the control matrix, SSP, testing, and evidence calendar together, then retain a change log entry.

Footnotes

1. NIST SP 800-171 Rev. 3