03.04.07: Withdrawn

NIST SP 800-171 Rev. 3 requirement 03.04.07 is withdrawn, so you do not implement a technical or procedural control for it. You must operationalize the withdrawal by (1) documenting the requirement as “Not Applicable (Withdrawn),” (2) mapping any legacy implementation to the superseding/related requirements you do follow, and (3) retaining evidence that your scoping and traceability are correct for assessments. ¹

Key takeaways:

• Treat 03.04.07: withdrawn requirement as a governance and evidence task, not a control build task. ¹
• Update your SSP/control matrix so auditors see a clean “Withdrawn” disposition with traceable rationale and references. ¹
• If you previously implemented something for 03.04.07, either keep it as a compensating/internal control or rationalize it into the correct Rev. 3 requirement(s).

A withdrawn requirement is a common failure point in real assessments because teams either ignore it entirely (leaving an unexplained gap in the control matrix) or spend time “implementing” something that the framework no longer asks for. For 03.04.07: withdrawn requirement, the right move is to show disciplined requirements management: a clear status, clear rationale, and clear mapping to what you do implement.

For a Compliance Officer, CCO, or GRC lead supporting NIST SP 800-171 obligations for Controlled Unclassified Information (CUI) in nonfederal systems, the practical goal is assessment readiness. Your assessor should be able to open your System Security Plan (SSP) and traceability matrix and immediately understand: (1) you recognized that 03.04.07 is withdrawn, (2) you did not claim compliance with a non-existent requirement, and (3) any related practices are accounted for elsewhere in your control set. The requirement text itself is short, so your execution quality is measured by documentation hygiene and the strength of your artifacts. ¹

Regulatory text

Excerpt / requirement status: “NIST SP 800-171 Rev. 3 requirement 03.04.07 (Withdrawn).” ¹

What the operator must do with “Withdrawn”

Because the requirement is explicitly withdrawn, there is no affirmative control action to implement under 03.04.07 itself. Your job is to:

1. Represent the requirement accurately in your governance artifacts (SSP, control matrix, POA&M).
2. Preserve traceability so an assessor can see why it is marked withdrawn and confirm you did not miss a required control.
3. Handle legacy controls: if your program previously mapped a control to 03.04.07 (from earlier revisions or internal control catalogs), decide whether to keep it as an internal requirement or map it to the correct Rev. 3 requirement(s). ¹

---

Plain-English interpretation

03.04.07: withdrawn requirement means: “This control item is no longer part of the NIST SP 800-171 Rev. 3 requirement set, so you should not design, test, or claim implementation against it.” ¹

In practice, assessors still expect to see it listed in your control baseline if your organization tracks requirements by ID. What they want is a clean disposition: “Withdrawn (NIST SP 800-171 Rev. 3), no implementation required,” plus cross-references if your internal controls or tooling still contain artifacts tied to that identifier.

---

Who it applies to (entity and operational context)

This applies to:

• Federal contractors and subcontractors that must meet NIST SP 800-171 requirements for protecting CUI in nonfederal systems. ¹
• Any organization handling CUI in a nonfederal environment and using NIST SP 800-171 Rev. 3 as the control baseline for the CUI boundary. ¹

Operationally, it applies to your GRC program mechanics:

• SSP authorship and maintenance
• Control libraries and control-to-requirement mappings
• Assessment readiness packages (evidence binders, audit trails)
• Tooling configuration (GRC platforms, spreadsheets, ticketing workflows)

---

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

Step 1: Update your control baseline and matrix entry

In your control matrix (or requirements traceability matrix):

• Keep the row for 03.04.07 if your template expects sequential IDs.
• Set Status to: Withdrawn (or Not Applicable – Withdrawn by NIST in Rev. 3).
• Add Rationale: “Requirement withdrawn in NIST SP 800-171 Rev. 3; no control implementation required.” ¹

Execution tip: Don’t delete the row. Deleting creates an unexplained gap that assessors flag as a scoping defect.

Step 2: Record the authoritative reference

Attach or reference the source where the withdrawal is stated:

• Point to the NIST SP 800-171 Rev. 3 publication and/or landing page in your evidence binder. ¹

Step 3: Search your environment for legacy dependencies

Run a targeted search across:

• Policies and standards (look for “03.04.07” strings)
• SSP text
• Test procedures
• Internal audit workpapers
• Jira/ServiceNow control tickets
• Training materials

If you find mentions, decide:

• Retire the reference (preferred), or
• Re-map it to the correct requirement(s) you currently follow, or
• Keep as internal control (optional) if it reduces risk, but remove claims that it satisfies 03.04.07.

Step 4: Normalize POA&M and assessment narratives

If 03.04.07 appears in your POA&M:

• Close it as “Not Applicable (Withdrawn)” with a short closure note and reference.
• Preserve the audit trail showing who approved closure and when.

Step 5: Establish a recurring “withdrawn requirements hygiene” check

Add a control to your GRC operating rhythm:

• When you adopt a new revision, run a delta review: withdrawn, added, renumbered, merged.
• Update SSP/control matrices accordingly.
• Create a short memo or change log entry for the revision update.

Step 6: Package evidence for assessors

Create a small evidence packet named “Withdrawn Requirements” containing:

• Your matrix entry for 03.04.07
• The reference excerpt/source pointer
• Your internal approval/change record
• Any re-mapping notes for legacy controls

Where Daydream fits naturally: If you track NIST SP 800-171 in Daydream, treat 03.04.07 as a governed “Withdrawn” requirement state with a required evidence attachment and an owner task for revision-change signoff. That prevents drift when templates, spreadsheets, and teams change.

---

Required evidence and artifacts to retain

Minimum artifacts that usually satisfy an assessor for 03.04.07: withdrawn requirement:

1. SSP excerpt showing 03.04.07 listed as Withdrawn / Not Applicable, with rationale.
2. Control matrix / requirements traceability matrix row for 03.04.07 showing status and reference.
3. Change log or ticket showing when and why you updated the status (include approver).
4. Source reference to NIST SP 800-171 Rev. 3 (PDF or landing page link captured in your evidence index). ¹
5. Legacy mapping memo (if needed): brief note showing where any prior 03.04.07-aligned practice now lives (new requirement ID, internal control ID, or retired).

---

Common exam/audit questions and hangups

Assessors and auditors tend to probe the same failure modes:

• “Why is 03.04.07 missing from your SSP/control matrix?”
  Hangup: You removed it instead of marking it withdrawn, so they can’t reconcile completeness.

• “Show me where NIST says it is withdrawn.”
  Hangup: You marked it withdrawn but have no reference in the evidence package. ¹

• “Did you re-map any inherited or legacy controls that used to satisfy 03.04.07?”
  Hangup: Your internal policy still cites the old ID, which implies your program is not aligned to Rev. 3.

• “Do you have a revision change management process?”
  Hangup: Withdrawn items are symptoms; the root issue is that your governance can’t keep up with updates.

---

Frequent implementation mistakes and how to avoid them

Mistake	Why it fails in practice	Avoid it by doing this
Deleting 03.04.07 from the matrix	Creates an unexplained gap that looks like incomplete scoping	Keep the row; set status to Withdrawn with rationale
Claiming “Compliant” for 03.04.07	You can’t be compliant with a withdrawn requirement; it signals weak QA	Use “Withdrawn / N/A” and cite Rev. 3 1
Leaving old policy/control text referencing 03.04.07	Confuses assessors and can expand assessment scope	Run a doc search; re-map references to current requirements
Turning withdrawal into a POA&M item	Creates noise and implies a gap exists	Close items as Withdrawn with approval notes
No evidence of the decision	Auditors assess the process, not your intent	Keep a small evidence packet and change log

---

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this specific requirement.

Risk still exists, but it is assessment risk and contractual performance risk, not a “failure to implement 03.04.07” risk. A withdrawn requirement becomes a finding when:

• Your SSP/control matrix cannot be reconciled to the framework IDs you claim to follow.
• Your evidence pack looks copy-pasted from another revision and you cannot explain deltas.
• Your team spends time testing phantom controls while real gaps remain elsewhere.

Treat withdrawn requirements as a signal to tighten configuration management for compliance artifacts.

---

Practical 30/60/90-day execution plan

First 30 days (stabilize)

• Update SSP and control matrix to list 03.04.07: withdrawn requirement as Withdrawn/N.A. with rationale. ¹
• Create the “Withdrawn Requirements” evidence packet with source references and approvals. ¹
• Run a document search for “03.04.07” and open cleanup tasks for any findings.

Days 31–60 (clean up and re-map)

• Remove or update policy/standard references that cite 03.04.07.
• If you had a legacy control mapped to 03.04.07, decide: retire, re-map to current requirement(s), or keep as internal-only. Document the decision.
• Update internal audit test scripts so they don’t test 03.04.07.

Days 61–90 (operationalize)

• Add a formal “framework revision delta review” step to your compliance change management process.
• Train control owners and SSP authors on how your program handles withdrawn/added requirements.
• In Daydream (or your GRC tool), enforce a required field for “Disposition rationale + source reference” on any Withdrawn/N.A. requirement entry to prevent silent drift.

---

Frequently Asked Questions

If 03.04.07 is withdrawn, should we remove it from our SSP?

Keep it listed if your SSP template expects full traceability by requirement ID. Mark it “Withdrawn/N.A.” and cite NIST SP 800-171 Rev. 3 so assessors can reconcile completeness. ¹

Can an assessor still ask for evidence for 03.04.07?

They can ask for evidence that you correctly handled the withdrawal. Provide your matrix entry, rationale, and the source reference showing it is withdrawn. ¹

What if our internal policy still references 03.04.07?

Treat it as documentation debt. Update the policy to remove the old ID or re-map the statement to the correct current requirement(s), and keep a change record for audit trail.

Should we keep the technical control we built for an older version of 03.04.07?

If it reduces risk and doesn’t conflict with current requirements, you can keep it as an internal control. Just avoid claiming it satisfies 03.04.07 and re-map it to current controls or your internal standard.

How do we show “compliance” with a withdrawn requirement in a customer questionnaire?

Answer with “Not Applicable – Withdrawn in NIST SP 800-171 Rev. 3” and offer to share your SSP excerpt/control matrix entry that documents the disposition. ¹

What’s the simplest way to prevent withdrawn items from reappearing as findings next year?

Put withdrawn requirements into the same evidence cadence as active ones: required rationale, required source reference, and a periodic review tied to framework revision management.

Footnotes

1. NIST SP 800-171 Rev. 3