03.02.03: Withdrawn

03.02.03 is a withdrawn requirement in NIST SP 800-171 Rev. 3, so you do not implement a standalone control for it. You operationalize it by documenting that it is “Withdrawn,” verifying no contractual or customer overlay still expects the prior control intent, and maintaining traceable evidence in your SSP/control matrix to prevent audit gaps. (NIST SP 800-171 Rev. 3)

Key takeaways:

• Treat the 03.02.03: withdrawn requirement as a documentation and scoping task, not a technical implementation task. (NIST SP 800-171 Rev. 3)
• Update your SSP, control crosswalks, and assessment artifacts so assessors see an explicit “Withdrawn” disposition with rationale and source reference. (NIST SP 800-171 Rev. 3)
• Confirm downstream obligations (contracts, flowdowns, customer security addenda) do not still reference legacy numbering or expectations tied to 03.02.03. (NIST SP 800-171 Rev. 3)

Withdrawn controls create a predictable failure mode in assessments: teams either (a) ignore the requirement and get flagged for an “unaddressed” item, or (b) waste time building a control that no longer exists in the standard. Your job as a CCO/CCO-adjacent GRC lead is to make the withdrawal explicit, traceable, and assessment-ready.

NIST SP 800-171 Rev. 3 lists 03.02.03 as “Withdrawn.” That single word still translates into operational work: you must ensure your compliance system of record (SSP, control matrix, evidence library, and any customer-facing attestations) reflects the withdrawal, and that nothing else you are bound to still expects what 03.02.03 used to represent. (NIST SP 800-171 Rev. 3)

This page gives requirement-level implementation guidance for the 03.02.03: withdrawn requirement: what it means, who must care, what artifacts to produce, and how to answer the audit questions that tend to follow. Where teams struggle is not the “control,” it’s the governance mechanics: crosswalk hygiene, contract interpretation, and clean assessor narratives. (NIST SP 800-171 Rev. 3)

Regulatory text

Excerpt / status: “NIST SP 800-171 Rev. 3 requirement 03.02.03 (Withdrawn).” (NIST SP 800-171 Rev. 3)

What the operator must do

Because 03.02.03 is withdrawn, the operational requirement is: treat it as not applicable due to withdrawal, document that disposition, and ensure your compliance mappings and assessment materials explicitly show it. (NIST SP 800-171 Rev. 3)

Assessors still expect to see the requirement ID accounted for in your control set inventory. If your SSP/control matrix skips a number without explanation, it often reads as a missed requirement. Your goal is to prevent ambiguity by recording “Withdrawn ¹” and linking it to your authoritative source. (NIST SP 800-171 Rev. 3)

Plain-English interpretation (03.02.03: withdrawn requirement)

• Meaning: NIST removed this requirement from Rev. 3. You are not expected to design or operate a discrete control to satisfy 03.02.03 in Rev. 3. (NIST SP 800-171 Rev. 3)
• What remains: You still need a complete, numbered, reviewable accounting of all requirements in your compliance documentation, including those marked withdrawn. (NIST SP 800-171 Rev. 3)
• Why it matters: Withdrawn items commonly surface as “gaps” in external reviews when documentation is incomplete, or when contract language points to older control catalogs. (NIST SP 800-171 Rev. 3)

Who it applies to

This applies to:

• Entities: Federal contractors and other organizations operating nonfederal systems handling CUI and aligning to NIST SP 800-171 Rev. 3. (NIST SP 800-171 Rev. 3)
• Operational contexts where it shows up:
  • You maintain an SSP and a control matrix for a CUI environment and you track control IDs by requirement number. (NIST SP 800-171 Rev. 3)
  • You respond to customer due diligence questionnaires that cite NIST SP 800-171 requirements by number and expect an “implemented / not implemented / not applicable” status. (NIST SP 800-171 Rev. 3)
  • You are preparing for an assessment where the assessor expects a clean requirement inventory and traceability. (NIST SP 800-171 Rev. 3)

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

Step 1: Record the authoritative disposition

1. In your control matrix (or GRC tool), create an entry for 03.02.03 with status Withdrawn.
2. Add a short rationale: “Withdrawn in NIST SP 800-171 Rev. 3.”
3. Attach or link the standard reference you use as evidence. (NIST SP 800-171 Rev. 3)

Operator note: Treat this like a scope decision. It needs ownership, review, and change control like any other requirement mapping. (NIST SP 800-171 Rev. 3)

Step 2: Validate no “overlay obligation” still requires it

Withdrawn in the framework does not automatically mean withdrawn in your obligations. Do a quick obligation check:

1. Review active contracts, flowdowns, and customer security addenda for references to:
   • NIST SP 800-171 revisions (explicitly “Rev. 3” versus ambiguous “800-171”),
   • requirement numbering that might reflect prior revisions,
   • supplemental requirements that may have inherited older control intent. (NIST SP 800-171 Rev. 3)
2. If a contract references a prior rev or an older requirement list, log an exception task: “Confirm required revision and applicability with customer/prime.”

Decision point

Situation	What to do	Evidence to keep
Contract explicitly cites Rev. 3	Mark 03.02.03 as Withdrawn	Contract excerpt + mapping note (NIST SP 800-171 Rev. 3)
Contract ambiguously cites “NIST 800-171”	Confirm revision in writing	Email trail / amendment note (NIST SP 800-171 Rev. 3)
Customer questionnaire asks about 03.02.03	Respond “Withdrawn in Rev. 3” and attach citation	Response copy + citation (NIST SP 800-171 Rev. 3)

Step 3: Update SSP narrative so assessors don’t hunt

In your SSP (or equivalent system security plan narrative):

1. Include 03.02.03 in the requirements list.
2. For implementation, state: “Withdrawn in NIST SP 800-171 Rev. 3; no control implementation required.”
3. Cross-reference the standard citation in your “References” section. (NIST SP 800-171 Rev. 3)

Step 4: Align evidence collection routines (yes, even for withdrawn)

You won’t collect operational logs for a withdrawn requirement, but you should still collect documentation evidence:

1. Screenshot/export of the control matrix entry showing “Withdrawn.”
2. SSP excerpt showing the same disposition.
3. Change ticket or approval record showing who validated the disposition and when. (NIST SP 800-171 Rev. 3)

If you run Daydream or another GRC workflow tool, set this requirement to a “documentation-only” evidence cadence so it stays present in audit exports without creating busywork.

Step 5: Train your responders and third-party due diligence team

Withdrawn items come up in two places: customer questionnaires and assessor interviews.

1. Provide a standard response snippet to Sales Engineering / Security Questionnaire team.
2. Provide a standard response snippet to internal audit / assessment prep team.
3. Store both in your knowledge base and link them to your SSP section. (NIST SP 800-171 Rev. 3)

Required evidence and artifacts to retain

Retain artifacts that prove you did not “miss” the requirement; you dispositioned it correctly.

Minimum evidence set

• Control matrix entry for 03.02.03 showing Withdrawn and citing the framework source. (NIST SP 800-171 Rev. 3)
• SSP excerpt that lists 03.02.03 and explains “Withdrawn.” (NIST SP 800-171 Rev. 3)
• Governance record (ticket, change log, or approval memo) showing review/approval of the withdrawn mapping. (NIST SP 800-171 Rev. 3)
• Contract/obligation check notes, including any customer confirmation if revision ambiguity exists. (NIST SP 800-171 Rev. 3)

Nice-to-have

• Questionnaire response template that references the withdrawal and points to your SSP section for traceability. (NIST SP 800-171 Rev. 3)

Common exam/audit questions and hangups

Expect these in interviews and written follow-ups:

1. “Why is 03.02.03 missing from your matrix?”
   Fix: It should not be missing. It should be present and marked Withdrawn with citation. (NIST SP 800-171 Rev. 3)

2. “Show me how you determined it was withdrawn.”
   Provide the citation reference and your internal approval record. (NIST SP 800-171 Rev. 3)

3. “Does your contract require a different revision?”
   Show the contract language and, if ambiguous, your written clarification trail. (NIST SP 800-171 Rev. 3)

4. “How do you ensure withdrawn requirements remain tracked over time?”
   Point to your compliance change management process and recurring review of the SSP/control matrix, including documentation-only items. (NIST SP 800-171 Rev. 3)

Frequent implementation mistakes (and how to avoid them)

Mistake 1: Dropping the requirement ID entirely

What happens: An assessor flags it as “unaddressed.”
Avoidance: Keep 03.02.03 in your inventory with explicit “Withdrawn” status and citation. (NIST SP 800-171 Rev. 3)

Mistake 2: Building a control anyway

What happens: You create unnecessary procedures, then struggle to explain why your implementation doesn’t map cleanly to Rev. 3.
Avoidance: Treat withdrawn as “no standalone requirement.” If the old intent overlaps with other active requirements, map those controls to the active requirements, not to 03.02.03. (NIST SP 800-171 Rev. 3)

Mistake 3: Failing to check contractual overlays

What happens: Your internal program says “withdrawn,” but your customer expects older numbering or extra requirements.
Avoidance: Run a contract/flowdown check and capture written confirmation when revision language is unclear. (NIST SP 800-171 Rev. 3)

Mistake 4: Inconsistent story across SSP, matrix, and questionnaires

What happens: You answer “N/A” in one place and “Withdrawn” in another, and reviewers suspect weak governance.
Avoidance: Standardize the disposition phrase: “Withdrawn in NIST SP 800-171 Rev. 3.” Use it everywhere. (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 you should treat risk here as assessment and contractual nonconformance risk, not a standalone enforcement trend. (NIST SP 800-171 Rev. 3)

Practical risk implications you can manage:

• Assessment friction: Gaps in numbering or unexplained omissions slow assessments and can trigger expanded sampling. (NIST SP 800-171 Rev. 3)
• Representations risk: If you attest to following Rev. 3 but your artifacts look like a prior revision crosswalk, your customer may question your overall compliance posture. (NIST SP 800-171 Rev. 3)

Practical 30/60/90-day execution plan

Use phases to avoid making up time-to-complete claims while still giving operators a clear runbook.

Immediate (next working session)

• Add 03.02.03 to the control matrix as Withdrawn with the source citation. (NIST SP 800-171 Rev. 3)
• Add an SSP entry (or update existing) stating “Withdrawn in Rev. 3; no implementation required.” (NIST SP 800-171 Rev. 3)
• Open a tracking ticket for “Withdrawn requirements verification,” so this does not live only in someone’s head. (NIST SP 800-171 Rev. 3)

Near-term (after you stabilize documentation)

• Perform the contract/flowdown review for revision ambiguity and document outcomes. (NIST SP 800-171 Rev. 3)
• Standardize questionnaire response language for 03.02.03 and store it with your SSP references. (NIST SP 800-171 Rev. 3)
• Add a recurring governance check in your GRC workflow: withdrawn items remain present in exports and evidence packs. (NIST SP 800-171 Rev. 3)

Ongoing (business as usual)

• Re-validate withdrawn status whenever you update your SSP for a new customer, new CUI boundary, or a framework refresh. (NIST SP 800-171 Rev. 3)
• During internal audits, sample withdrawn items to confirm they are consistently represented across SSP, matrix, and customer response processes. (NIST SP 800-171 Rev. 3)

Frequently Asked Questions

If 03.02.03 is withdrawn, can I mark it “Not Applicable” and move on?

Mark it “Withdrawn,” not generic “N/A,” so an assessor can see you tracked the requirement ID and applied the framework disposition. Use the same language in your SSP and control matrix. (NIST SP 800-171 Rev. 3)

Do I need evidence for a withdrawn requirement?

Yes, but it’s documentation evidence, not technical logs. Keep the control matrix entry, SSP excerpt, and an approval/change record that shows who validated the withdrawn mapping. (NIST SP 800-171 Rev. 3)

A customer questionnaire asks, “How do you meet 03.02.03?” What should I answer?

State that 03.02.03 is withdrawn in NIST SP 800-171 Rev. 3, cite your SSP section, and offer to map any underlying customer concern to the relevant active requirements. Keep a copy of the response for audit traceability. (NIST SP 800-171 Rev. 3)

What if our contract references NIST SP 800-171 but doesn’t specify the revision?

Treat that as an obligation ambiguity. Confirm the required revision with the customer/prime in writing, then store that confirmation with your control mapping rationale. (NIST SP 800-171 Rev. 3)

Should we remove 03.02.03 from our GRC tool to reduce clutter?

No. Removing it creates the appearance of an untracked requirement. Keep it with a “Withdrawn” status and documentation-only evidence so exports remain complete. (NIST SP 800-171 Rev. 3)

How does Daydream help with a withdrawn requirement?

Daydream can keep 03.02.03 present in your control library, link it to your SSP narrative, and schedule lightweight documentation evidence so audits don’t stall on a missing requirement number. (NIST SP 800-171 Rev. 3)

Footnotes

1. NIST SP 800-171 Rev. 3