03.03.09: Withdrawn

A withdrawn requirement creates a predictable audit failure mode: someone exports a legacy checklist, sees “03.03.09” in a library, and raises a finding because there is “no implementation evidence.” Your job, as the Compliance Officer/CCO/GRC lead, is to make it easy for an assessor (and your own stakeholders) to see that there is nothing to implement, and that you actively manage changes in the NIST SP 800-171 control set.

For NIST SP 800-171 Rev. 3, requirement 03.03.09 is explicitly marked “Withdrawn.” ¹ That means your operational obligation is to (1) confirm you are working from the correct revision, (2) update your control inventory and assessment procedures so the requirement is not expected as an active control, and (3) preserve traceable documentation that explains the status.

This page gives requirement-level guidance you can execute quickly: who owns the decision, what to change in your SSP and control mapping, what evidence to retain, and how to handle assessor questions without creating new scope or “compensating controls” for something NIST removed.

Regulatory text

Excerpt / status: “NIST SP 800-171 Rev. 3 requirement 03.03.09 (Withdrawn).” ¹

What the operator must do

Because the requirement is withdrawn, the “do” is not a security configuration. The requirement for operators is administrative and evidentiary:

1. Mark 03.03.09 as Withdrawn/Not Applicable in your compliance mapping (SSP, control matrix, GRC tool).
2. Ensure no assessment procedure expects evidence for 03.03.09 in your internal test plans, POA&M templates, or third-party assessment prep packages.
3. Retain proof that you are using NIST SP 800-171 Rev. 3 as your source of truth and that you perform change management on requirement updates. ¹

If you do nothing, teams often fail audits because the assessor cannot tell whether you missed the control or intentionally scoped it out.

Plain-English interpretation (what “withdrawn” means in practice)

“Withdrawn” means NIST removed the requirement from the active set in this revision. You should not invent a new control to “cover it.” You should not maintain a fake artifact to satisfy a nonexistent requirement. Instead, treat it like a standards lifecycle event: update your baseline, keep your mapping clean, and be ready to explain the status in one sentence with a citation.

For serious operators, the main risk is process integrity. Auditors test whether your compliance program reliably tracks what is required, what changed, and what you chose not to implement (and why). A withdrawn requirement is a simple way for an auditor to see whether your program is disciplined.

Who it applies to (entity and operational context)

This guidance applies to:

• Nonfederal organizations handling Controlled Unclassified Information (CUI) in nonfederal systems that must align to NIST SP 800-171. ¹
• Federal contractors and subcontractors where NIST SP 800-171 requirements are flowed down through contract terms or supplier requirements. ¹

Operational contexts where this comes up:

• You maintain an SSP and POA&M for a CUI environment.
• You run a GRC/control library that contains multiple revisions or crosswalks.
• You are preparing for an internal readiness review or an external assessment, and someone is using an outdated spreadsheet/control checklist.

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

Step 1: Confirm your source baseline is Rev. 3

• Update your internal “authoritative sources” register to point to the Rev. 3 publication and landing page. ¹
• Ensure your control library explicitly identifies the revision (Rev. 3) for the NIST SP 800-171 requirement set. ¹

Step 2: Update your control inventory and applicability logic

In your SSP/control matrix (or Daydream control mapping), set:

• Control/requirement ID: 03.03.09
• Status: Withdrawn
• Applicability: Not Applicable (Withdrawn in Rev. 3)
• Rationale: “Requirement is withdrawn in NIST SP 800-171 Rev. 3; no implementation required.” ¹
• Reference: link or citation to the Rev. 3 source in your internal bibliography. ¹

Step 3: Remove it from test plans and evidence requests

Hunt down anywhere your program might still request artifacts:

• Internal audit workpapers
• Control testing scripts
• Evidence request lists used for supplier/third-party attestation support
• “Control owner” tasking lists

Update templates so they do not ask for evidence tied to 03.03.09. Keep a redlined template revision or change log entry that shows you cleaned it up.

Step 4: Add a “withdrawn requirement handling” procedure

This is a small SOP that prevents recurrence:

• How you detect requirement changes (new revision release, updated mapping).
• Who approves applicability decisions (GRC lead + system owner is typical).
• How you update SSP/control matrix, GRC tool, and test plans.
• Where you store citations and decision logs. ¹

Keep it short. One page is enough if it is concrete.

Step 5: Record the decision in your POA&M governance (as “no action”)

Do not create a POA&M item to “fix” 03.03.09. Create, at most, a governance note in your tracking system:

• “03.03.09 withdrawn; no remediation task. Mapping updated.” This prevents open items from accumulating around non-requirements.

Step 6: Operationalize in Daydream (if you use it)

Daydream fits naturally here as a control-mapping and evidence hub:

• Map 03.03.09: withdrawn requirement to “Withdrawn/Not Applicable” in your control set.
• Attach the citation reference and your internal decision record.
• Schedule recurring review of requirement status when the framework revision or contract scope changes. ¹

Required evidence and artifacts to retain

Assessors usually want to see that you (a) knew it was withdrawn and (b) updated your program accordingly.

Retain:

• SSP/control matrix excerpt showing 03.03.09 marked “Withdrawn / Not Applicable,” with rationale and citation. ¹
• Framework source register entry pointing to NIST SP 800-171 Rev. 3 as authoritative. ¹
• Change log or ticket showing you updated templates/control library to remove testing/evidence requests for 03.03.09.
• Applicability decision record (meeting notes, approval in GRC tool, or signed control applicability memo).
• Assessment prep pack note that lists withdrawn requirements and how they’re handled (one table is enough).

A simple artifact set beats a long narrative. Auditors prefer clarity.

Common exam/audit questions and hangups

Expect these, and pre-answer them in your SSP annex or assessment binder:

1. “Where is the evidence for 03.03.09?”
   Response: “03.03.09 is withdrawn in NIST SP 800-171 Rev. 3; we mark it Withdrawn/Not Applicable in our SSP and do not test it.” ¹

2. “Are you sure you’re using the current revision?”
   Show your authoritative-source register and the citation you used. ¹

3. “Did you implement an equivalent control anyway?”
   Avoid speculative equivalency. If you already do related practices elsewhere, state that separately, but keep 03.03.09 as withdrawn.

4. “How do you manage requirement changes over time?”
   Produce your short SOP and the change ticket(s) for this update.

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it creates risk	How to avoid it
Leaving 03.03.09 “open” in the control matrix	Triggers “missing control” findings	Mark Withdrawn/Not Applicable with a citation and rationale. 1
Creating a “compensating control” artifact	Adds unnecessary scope and confusion	Don’t build controls for withdrawn items; document status instead. 1
Keeping evidence request lists from older revisions	Causes churn and delays during audits	Update templates and keep a change log entry that shows the cleanup.
No documented lifecycle process	Auditor doubts the integrity of your baseline	Maintain a lightweight “framework change management” SOP and decision log.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this specific requirement. Practically, the risk is indirect: a withdrawn requirement can still produce negative outcomes if your contracting customer, prime, or assessor interprets “no evidence” as noncompliance. The control is withdrawn, but your governance and audit-readiness must be defensible and traceable to NIST SP 800-171 Rev. 3. ¹

Practical execution plan (30/60/90)

You asked for speed. This plan is built for minimal disruption and clean audit posture.

First 30 days (stabilize the baseline)

• Update SSP/control matrix: 03.03.09 marked Withdrawn/Not Applicable with rationale and citation. ¹
• Update GRC/control library status so it does not appear as “missing.”
• Remove 03.03.09 from evidence request lists and internal test scripts.
• Create a single decision record (ticket or memo) approved by GRC lead + system owner.

Next 60 days (harden the process)

• Publish a short SOP for handling withdrawn/added/changed requirements in NIST SP 800-171 updates. ¹
• Train control owners and internal auditors on “withdrawn means no evidence” so it doesn’t reappear in requests.
• Run an internal “mock evidence pull” and confirm no one asks for 03.03.09 artifacts.

By 90 days (make it repeatable)

• Add a recurring control library review trigger tied to framework revision changes or contract scope updates.
• In Daydream (or your GRC tool), attach the withdrawn status and decision record as standing evidence for future assessments. ¹
• Confirm third parties supporting your CUI environment are not being asked for irrelevant 03.03.09 evidence in flow-down questionnaires.

Frequently Asked Questions

If 03.03.09 is withdrawn, can an assessor still score us down for it?

A competent assessment should not require implementation evidence for a withdrawn requirement, but they can still flag your program if your mapping looks incomplete. Prevent that by marking it Withdrawn/Not Applicable with a clear citation to NIST SP 800-171 Rev. 3. ¹

Should we keep legacy controls that were previously mapped to 03.03.09?

Keep any controls that reduce risk or are required elsewhere, but remap them to the correct active requirement(s) or to an internal control objective. Don’t keep 03.03.09 as an active requirement in your baseline. ¹

What’s the minimum evidence package for a withdrawn requirement?

Your SSP/control matrix entry showing “Withdrawn,” plus a decision record or change ticket, is usually enough. Include the citation to NIST SP 800-171 Rev. 3 in the entry. ¹

How should we represent 03.03.09 in a POA&M?

Don’t open remediation work for a withdrawn item. If your tooling requires an entry, record it as Withdrawn/Not Applicable with no action and reference your baseline decision. ¹

We have a customer still asking about 03.03.09. What do we do?

Ask what revision their requirement list is based on and provide your mapping showing it is withdrawn in Rev. 3. If the customer contractually requires an older revision, treat that as a contract scope issue and document the contractual basis separately. ¹

How do we prevent withdrawn items from resurfacing in third-party due diligence requests?

Standardize your evidence request lists and questionnaires to the correct NIST SP 800-171 revision and keep them under version control. In Daydream, keep a single control mapping source so teams don’t export outdated spreadsheets. ¹

Footnotes

1. NIST SP 800-171 Rev. 3