03.04.09: Withdrawn

03.04.09 is a withdrawn requirement in NIST SP 800-171 Rev. 3, so you do not implement a standalone control for it. You operationalize it by documenting that it is withdrawn, confirming no contractual or assessment overlay still expects it, and mapping any prior implementation to the current applicable requirements so your SSP, POA&M, and evidence set stay internally consistent. (NIST SP 800-171 Rev. 3)

Key takeaways:

• Treat “03.04.09: withdrawn requirement” as a governance task: document disposition, don’t build a new control. (NIST SP 800-171 Rev. 3)
• Update crosswalks, SSP/control inventory, and assessment narratives to prevent “missing control” findings caused by stale mappings. (NIST SP 800-171 Rev. 3)
• Preserve an audit trail showing how legacy references were handled, especially if your contracts, customers, or tools still reference 03.04.09. (NIST SP 800-171 Rev. 3)

Withdrawn requirements create a predictable kind of audit pain: teams keep old spreadsheets, ticket templates, and policies that still list the requirement, then an assessor asks for “evidence,” or your own internal reviewers flag a “gap” that is not real. For 03.04.09, NIST SP 800-171 Rev. 3 explicitly labels it withdrawn, which means your job is to keep your compliance system accurate and assessment-ready rather than to implement technical safeguards that no longer exist as written. (NIST SP 800-171 Rev. 3)

For a CCO, compliance officer, or GRC lead, the operational goal is clarity: (1) prove you know it is withdrawn, (2) show where it used to map (if it ever did in your environment), and (3) ensure your current control set covers the underlying intent through the right, still-applicable requirements. This page gives you a requirement-level playbook: scope and applicability, step-by-step implementation actions, required artifacts, exam questions, common mistakes, and a practical execution plan you can hand to your team without rewriting it. (NIST SP 800-171 Rev. 3)

Target keyword: 03.04.09: withdrawn requirement

Regulatory text

Excerpt / status: “NIST SP 800-171 Rev. 3 requirement 03.04.09 (Withdrawn).” (NIST SP 800-171 Rev. 3)

Operator meaning (what you must do)

Because the requirement is withdrawn, there is no current NIST SP 800-171 Rev. 3 control objective to implement under the identifier “03.04.09.” Your obligation is governance and documentation:

• Record that 03.04.09 is withdrawn in your control library and mapping tables. (NIST SP 800-171 Rev. 3)
• Ensure your System Security Plan (SSP) and any customer-facing mappings do not claim implementation of a requirement that no longer exists. (NIST SP 800-171 Rev. 3)
• Where 03.04.09 appears in contracts, questionnaires, or inherited templates, document the disposition: withdrawn, and mapped to current applicable requirements (or “no longer applicable” with rationale). (NIST SP 800-171 Rev. 3)

Plain-English interpretation

“03.04.09: withdrawn requirement” means NIST removed that specific requirement from the current revision, so you should not be building or testing a dedicated control for it. Your risk is administrative and assessment-related: stale references can cause confusion, mis-scoring, or a perception that your program is not aligned to the current framework text. (NIST SP 800-171 Rev. 3)

Who it applies to (entity and operational context)

This guidance applies to:

• Nonfederal organizations operating systems that handle Controlled Unclassified Information (CUI) where NIST SP 800-171 Rev. 3 is the governing security requirements baseline. (NIST SP 800-171 Rev. 3)
• Federal contractors and subcontractors whose customers require NIST SP 800-171 alignment and who must maintain SSP/POA&M-style artifacts for review. (NIST SP 800-171 Rev. 3)

Operationally, you will touch this requirement status in:

• Your SSP requirement-by-requirement narratives and control implementation statements. (NIST SP 800-171 Rev. 3)
• Control mappings/crosswalks (e.g., to NIST SP 800-53, ISO 27001, or customer control lists) where an old mapping might still include 03.04.09. (NIST SP 800-171 Rev. 3)
• Third-party and supplier flow-down documentation when a prime or customer questionnaire includes legacy requirement IDs. (NIST SP 800-171 Rev. 3)

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

Step 1: Find every reference to 03.04.09

Search across:

• SSP, POA&M, policies, standards, procedures
• Control matrix/crosswalk spreadsheets
• GRC tool control library and test procedures
• Evidence request lists and audit binders
• Third-party security exhibits, contract addenda, customer questionnaires

Deliverable: a short “03.04.09 reference register” listing location, owner, and disposition (remove, replace, map, or annotate). (NIST SP 800-171 Rev. 3)

Step 2: Set the official disposition in your control library

Create a control library entry (or update the existing one) with:

• Status: Withdrawn per NIST SP 800-171 Rev. 3
• Implementation: Not applicable as a standalone requirement
• Handling rule: Do not test; do not collect evidence; maintain mapping note
• Owner: GRC/Compliance (so it does not get assigned to IT as a “missing control”)

Tip for serious operators: Keep the withdrawn entry visible (do not delete it) so legacy artifacts can be explained during an assessment without guesswork. (NIST SP 800-171 Rev. 3)

Step 3: Update SSP language to prevent assessment confusion

In the SSP requirement narrative section where 03.04.09 would otherwise appear:

• Replace any prior implementation statement with: “Withdrawn in NIST SP 800-171 Rev. 3; no standalone implementation required.” (NIST SP 800-171 Rev. 3)
• If your SSP format requires a control response, add a short rationale and point to the current revision citation. (NIST SP 800-171 Rev. 3)

Step 4: Repair crosswalks and downstream mappings

If you map NIST SP 800-171 to other frameworks (NIST SP 800-53, ISO, CIS, customer controls):

• Mark 03.04.09 as withdrawn and remove it from scoring logic.
• If an older mapping linked 03.04.09 to a current internal control, decide whether that internal control still stands on its own merit. If it does, keep the internal control but map it to the correct current NIST SP 800-171 Rev. 3 requirement(s). (NIST SP 800-171 Rev. 3)

Step 5: Normalize evidence collection and testing plans

Update your audit/test plan so the team does not waste cycles:

• Remove 03.04.09 from quarterly evidence requests and internal audit scripts.
• If an external auditor asks for evidence, provide the withdrawal citation and your mapping note rather than inventing artifacts. (NIST SP 800-171 Rev. 3)

Step 6: Handle contractual and third-party spillover

If a customer, prime, or third party due diligence questionnaire still references 03.04.09:

• Respond with: “Withdrawn in NIST SP 800-171 Rev. 3” and attach a short mapping explanation or excerpt reference. (NIST SP 800-171 Rev. 3)
• Offer an alternative: “We meet the current NIST SP 800-171 Rev. 3 requirements applicable to our CUI environment; see SSP section [X].” (NIST SP 800-171 Rev. 3)

Step 7: Governance: approve and version the change

Run the withdrawal handling through your change control:

• Update the control catalog version
• Record approver (CCO/GRC lead)
• Note effective date and impacted documents

Daydream (as a practical resolution): track the withdrawn status as a control record with an owner, link it to SSP sections and questionnaires, and schedule periodic mapping reviews so withdrawn items do not reappear in evidence requests after tool migrations.

Required evidence and artifacts to retain

Keep artifacts that prove correct handling, not “control operation”:

• Control library entry showing 03.04.09 marked withdrawn and not tested. (NIST SP 800-171 Rev. 3)
• SSP excerpt where the requirement is labeled withdrawn with a short rationale. (NIST SP 800-171 Rev. 3)
• Crosswalk/mapping change log (before/after or version history) showing removal from scoring and reassignment of any mappings. (NIST SP 800-171 Rev. 3)
• Reference register documenting where 03.04.09 appeared and what you changed. (NIST SP 800-171 Rev. 3)
• Customer/prime communication template for legacy questionnaires citing the withdrawal. (NIST SP 800-171 Rev. 3)
• Change approval record (ticket, memo, or GRC workflow evidence). (NIST SP 800-171 Rev. 3)

Common exam/audit questions and hangups

Assessors and internal auditors tend to probe these areas:

1. “Why is 03.04.09 missing from your SSP?”
   Your answer: it is withdrawn in Rev. 3; show the SSP note and control library status. (NIST SP 800-171 Rev. 3)

2. “Your crosswalk shows 03.04.09 mapped to Control X. Where is the evidence?”
   Explain that the mapping is legacy; provide the updated mapping and version history. (NIST SP 800-171 Rev. 3)

3. “Are you following Rev. 2 or Rev. 3?”
   This question appears when documents disagree. Make the revision choice explicit in SSP headers, control matrices, and contractual responses. (NIST SP 800-171 Rev. 3)

4. “How do you ensure withdrawn items don’t re-enter your control set?”
   Point to your change management and periodic control catalog review cadence, plus tooling rules that block withdrawn controls from evidence campaigns. (NIST SP 800-171 Rev. 3)

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it happens	How to avoid it
Deleting 03.04.09 entirely	Teams “clean up” the catalog and lose the audit trail	Keep an entry marked “Withdrawn,” with a short rationale and citation. (NIST SP 800-171 Rev. 3)
Treating it as “not implemented”	GRC templates force a status field	Use “Withdrawn” or “Not applicable (withdrawn)” and exclude from scoring/testing. (NIST SP 800-171 Rev. 3)
Creating a compensating control	Fear of gaps drives extra work	Map the underlying practice to current applicable requirements, not to a withdrawn ID. (NIST SP 800-171 Rev. 3)
Letting third parties dictate your baseline	Customers copy legacy checklists	Respond with the withdrawal citation and your current Rev. 3 mapping. (NIST SP 800-171 Rev. 3)
Evidence chaos after tool changes	Old requirement IDs re-import	Add a validation rule in your GRC workflow: withdrawn controls cannot be added to test plans. (NIST SP 800-171 Rev. 3)

Enforcement context and risk implications

No public enforcement cases were provided for this specific requirement in the source materials. Practically, the risk is indirect: a withdrawn requirement can still trigger negative assessment outcomes if your artifacts conflict, your crosswalk implies a missing control, or a customer interprets inconsistency as weak governance. Treat this as an assurance and trust issue tied to your CUI protection posture under NIST SP 800-171 Rev. 3. (NIST SP 800-171 Rev. 3)

Practical execution plan (30/60/90)

The plan below is outcome-driven; adjust sequencing to match your assessment calendar and contract deadlines.

First 30 days (stabilize the record)

• Identify all 03.04.09 references across SSP, POA&M, crosswalks, and evidence lists. (NIST SP 800-171 Rev. 3)
• Update the control library to mark 03.04.09 as withdrawn, not tested, not scored. (NIST SP 800-171 Rev. 3)
• Patch the SSP narrative with a clear withdrawal statement and citation reference. (NIST SP 800-171 Rev. 3)

By 60 days (fix downstream dependencies)

• Update crosswalks and remove 03.04.09 from any automated compliance scoring or evidence campaigns. (NIST SP 800-171 Rev. 3)
• Publish a standard response snippet for customer/prime questionnaires that cite the withdrawn requirement. (NIST SP 800-171 Rev. 3)
• Train control owners and internal auditors: withdrawn means “document and map,” not “implement.” (NIST SP 800-171 Rev. 3)

By 90 days (prevent regression)

• Add a governance check in your control-catalog change process: withdrawn requirement IDs are blocked from new tests and evidence requests. (NIST SP 800-171 Rev. 3)
• Run a mock assessment question set focused on “withdrawn/legacy requirement handling” to validate staff responses and artifact availability. (NIST SP 800-171 Rev. 3)
• If you use Daydream, configure a recurring review task that flags withdrawn requirements present in questionnaires, spreadsheets, or imported control sets, then routes them for remediation.

Frequently Asked Questions

If 03.04.09 is withdrawn, can an assessor still ask about it?

An assessor can ask why it is absent or why it appears in legacy artifacts. Your job is to show it is withdrawn in NIST SP 800-171 Rev. 3 and provide your documented disposition and updated mappings. (NIST SP 800-171 Rev. 3)

Should we keep 03.04.09 in our SSP at all?

Keep an entry if your SSP template enumerates requirement IDs, but label it “Withdrawn” with a short rationale. That prevents “missing requirement” confusion during reviews. (NIST SP 800-171 Rev. 3)

A customer questionnaire still lists 03.04.09. What should we answer?

Respond that it is withdrawn in NIST SP 800-171 Rev. 3 and provide the SSP section that states your Rev. 3 alignment. If the customer insists on a control statement, give a mapping note to the applicable current requirements rather than inventing evidence. (NIST SP 800-171 Rev. 3)

Do we need a POA&M item for 03.04.09?

No, not for the withdrawn requirement itself. Create a POA&M item only if you discover a real control gap in the current applicable requirements while cleaning up the mapping. (NIST SP 800-171 Rev. 3)

We previously built a control tied to 03.04.09. Should we remove it?

Do not remove a security control solely because the requirement is withdrawn. Re-evaluate the control against current NIST SP 800-171 Rev. 3 requirements and your risk decisions, then remap it and keep or retire it through normal change control. (NIST SP 800-171 Rev. 3)

What evidence is “enough” for a withdrawn requirement?

Keep proof of correct governance: control library status, SSP note, updated crosswalk, and a change log showing you removed it from testing/evidence campaigns. You are evidencing alignment to Rev. 3 text, not operational performance of a withdrawn control. (NIST SP 800-171 Rev. 3)