03.05.06: Withdrawn

A withdrawn requirement creates a specific kind of audit risk: it looks like a missing control to anyone scanning a checklist, even though there is nothing to implement. For a CCO or GRC lead supporting CUI environments, the fastest path is to treat 03.05.06: withdrawn requirement as a documentation and traceability task. Your job is to ensure every place that expects a requirement entry (SSP, assessment workbook, control catalog, evidence tracker, POA&M logic) shows a consistent disposition.

Operationally, that means three things. First, anchor your position in the primary framework text and cite it correctly. Second, make the “withdrawn” status visible wherever your organization plans, tests, and reports controls, so no one creates an unnecessary control or a false POA&M item. Third, retain lightweight artifacts that prove this was a deliberate governance decision, not an oversight.

This page gives requirement-level implementation guidance for getting 03.05.06 into production quickly: applicability, steps, evidence, common audit questions, and a practical execution plan you can run with a small team. All framework references below point to NIST SP 800-171 Rev. 3. ¹

Regulatory text

Requirement: “NIST SP 800-171 Rev. 3 requirement 03.05.06 (Withdrawn).” ¹

What the operator must do with a “Withdrawn” requirement

Because the requirement is explicitly withdrawn, there is no control outcome to implement for 03.05.06. Your operational obligation is to:

1. Record the disposition (“Withdrawn”) in your control library/crosswalk for NIST SP 800-171 Rev. 3.
2. Prevent misinterpretation by assessors, internal audit, customers, and system owners by keeping the withdrawn status consistent across SSP/assessment artifacts.
3. Retain evidence that the requirement was reviewed and intentionally marked withdrawn in accordance with NIST SP 800-171 Rev. 3. ¹

Plain-English interpretation (what this means in practice)

• NIST included a placeholder identifier (03.05.06) but removed the underlying requirement in Rev. 3.
• You should not spend time designing, implementing, or testing a control to “satisfy” 03.05.06.
• You can still fail an audit if your documentation implies you missed a requirement. The common failure mode is a control matrix or SSP that leaves 03.05.06 blank, marks it “not implemented,” or creates a POA&M item that confuses stakeholders.

Treat 03.05.06 as a traceability requirement: your program needs a clean paper trail that the requirement is withdrawn and therefore not applicable. ¹

Who it applies to (entity and operational context)

This guidance applies when you are using NIST SP 800-171 Rev. 3 as the control baseline for:

• Federal contractors and subcontractors that handle Controlled Unclassified Information (CUI) in nonfederal systems.
• Any nonfederal organization operating systems that handle CUI and must align with NIST SP 800-171 requirements as flowed down via contract terms or program requirements. ¹

Operational contexts where “withdrawn” entries matter:

• SSP creation and maintenance for a CUI enclave or boundary-defined CUI system
• Customer or prime contractor questionnaires that still reference older checklists
• Internal audits that use generic control-testing scripts
• GRC tooling imports where a withdrawn requirement can show up as an “unassigned” control

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

Step 1: Confirm the authoritative baseline and lock the interpretation

• Confirm you are scoping to NIST SP 800-171 Rev. 3 and not mixing requirement lists from earlier revisions.
• Add a short statement to your compliance interpretation register: “03.05.06 is withdrawn in NIST SP 800-171 Rev. 3; no standalone control required.” ¹

Output: Interpretation note (one paragraph) tied to your NIST SP 800-171 Rev. 3 baseline.

Step 2: Update your control crosswalk/control library entry

In your control matrix (spreadsheet or GRC system), create/maintain the row for 03.05.06 with:

• Status/Disposition: Withdrawn
• Implementation: Not applicable (withdrawn)
• Rationale: Withdrawn per NIST SP 800-171 Rev. 3
• Control owner: GRC (for governance entries)
• Evidence pointer: Link to the interpretation note and baseline source record ¹

Practical tip: If your tooling requires a control object, create a “governance-only” control and mark it “Withdrawn / informational” so your dashboards don’t show a red gap.

Step 3: Align SSP language so assessors see consistency

In the SSP section where you describe requirement implementation, add an explicit entry for 03.05.06:

• “03.05.06 is withdrawn in NIST SP 800-171 Rev. 3; no implementation required for this system.” ¹

If you maintain a POA&M:

• Do not create a POA&M item for 03.05.06.
• If one exists from a legacy import, close it with the closure reason: “Withdrawn requirement in Rev. 3.” Keep the change log.

Step 4: Fix upstream/downstream references (where teams get tripped up)

Search and remediate references across:

• Assessment workbooks and test scripts
• Customer response templates
• Contract compliance matrices
• Control narratives reused from prior years

You are looking for three problematic patterns:

1. Blank row for 03.05.06
2. “Not implemented” status
3. A guessed control someone created to fill the gap

Replace with “Withdrawn (Rev. 3)” and a single source reference. ¹

Step 5: Put recurring evidence collection on autopilot

Even though 03.05.06 has no operational control evidence, you still want recurring governance evidence that your crosswalk remains accurate:

• Add “Withdrawn requirements review” to your annual control baseline review checklist.
• Re-validate after any major framework import, customer-driven mapping, or tool migration.

Where Daydream fits naturally: If you manage NIST SP 800-171 mappings across multiple systems and third parties, Daydream helps keep requirement status, policy mapping, and evidence pointers synchronized so withdrawn entries don’t show up as open gaps during reporting.

Required evidence and artifacts to retain

You are proving intentional non-applicability due to withdrawal, not control operation.

Minimum artifacts:

• Control crosswalk entry showing 03.05.06 = Withdrawn, with a rationale referencing NIST SP 800-171 Rev. 3. ¹
• SSP excerpt (or SSP change record) stating the requirement is withdrawn and requires no implementation. ¹
• Baseline/source record: a saved copy or reference to the NIST SP 800-171 Rev. 3 publication location your program uses. ¹
• Change log showing who updated the crosswalk/SSP and when (ticket, GRC workflow history, or document revision history)

Nice-to-have artifacts (reduce audit friction):

• A one-page “Withdrawn/Not Applicable Criteria” SOP defining when you can mark requirements withdrawn vs. not applicable vs. out of scope.
• A screenshot/export from your GRC tool showing 03.05.06 status and evidence link.

Common exam/audit questions and hangups

Auditors and customer assessors tend to ask:

• “Why is 03.05.06 not implemented?”
  • Correct response: “It’s withdrawn in NIST SP 800-171 Rev. 3; no control exists to implement.” ¹
• “Show me where this is documented in the SSP/control matrix.”
  • Provide the SSP excerpt plus the crosswalk row.
• “How do you ensure you didn’t miss other requirements?”
  • Show your baseline management process: version locking, periodic review, and tooling import controls.

Hangups that cause delays:

• The assessor is using an older checklist that expects a control narrative. Provide your baseline citation and offer a crosswalk view that explicitly shows “Withdrawn.” ¹
• Internal audit scripts auto-generate exceptions for any non-tested requirement. Adjust the script logic to treat “Withdrawn” as a closed condition.

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it happens	How to avoid it
Leaving 03.05.06 blank in the matrix	Spreadsheet templates don’t include withdrawn handling	Always include an explicit row with “Withdrawn” disposition and rationale 1
Marking it “Not implemented”	Teams treat every ID as an implementable control	Train control owners: withdrawn ≠ failed; update your status taxonomy
Creating a “filler control”	Pressure to show completeness to customers	Document withdrawal in SSP; do not invent controls not in the baseline 1
Opening a POA&M item	Legacy imports or automated gap scans	Close with “withdrawn” rationale; adjust scanner rules
Inconsistent language across SSP, POA&M, and tool	Multiple owners, no baseline governance	Assign GRC as the single owner for withdrawn entries and require a change ticket

Risk implications and assessment readiness

03.05.06 doesn’t introduce direct security risk because it has no implementable requirement in Rev. 3. The risk is programmatic:

• A customer, prime, or assessor may interpret a gap as noncompliance if your artifacts don’t clearly show “Withdrawn.”
• Confusion can waste assessment time and create avoidable corrective actions that distract from real CUI control gaps.

Your control objective is clean traceability: anyone reviewing your NIST SP 800-171 Rev. 3 implementation should see that 03.05.06 was intentionally addressed as withdrawn. ¹

Practical 30/60/90-day execution plan

No sourced timelines are provided for this requirement, so use phases instead of day counts.

Immediate (next sprint)

• Add/verify 03.05.06 row in the control crosswalk: “Withdrawn,” rationale, evidence pointer. ¹
• Update SSP language and revision history to reflect the withdrawn disposition. ¹
• Remove/close any legacy POA&M items tied to 03.05.06 with a documented closure reason.

Near-term

• Update assessment procedures and internal audit scripts to treat “Withdrawn” as a non-testable, closed condition.
• Run a document search across customer templates and compliance workbooks to eliminate “not implemented” references.
• Add a baseline governance check: framework version lock + withdrawn requirement handling.

Ongoing

• Reconfirm withdrawn mapping after any framework/library updates in your GRC tool.
• During annual SSP maintenance, verify 03.05.06 still shows as withdrawn and that no new artifacts introduced contradictions.
• If third parties contribute to your CUI environment (MSPs, cloud providers), ensure your shared responsibility matrix does not assign them an obligation for 03.05.06.

Frequently Asked Questions

If 03.05.06 is withdrawn, can an assessor still write a finding?

They can raise a documentation issue if your SSP/control matrix makes it look missing. Prevent that by explicitly labeling it “Withdrawn” everywhere the requirement list appears. ¹

Should I mark 03.05.06 as “Not Applicable” or “Withdrawn” in my GRC tool?

Prefer “Withdrawn” if your tool supports it, because it is more precise. If the tool only supports “Not Applicable,” set it to NA and add “Withdrawn in NIST SP 800-171 Rev. 3” in the rationale field. ¹

Do I need evidence for a withdrawn requirement?

You need governance evidence, not operational evidence. Keep the crosswalk row, SSP statement, and change record showing you intentionally treated it as withdrawn. ¹

What if a customer checklist still expects a narrative control description for 03.05.06?

Provide a short statement: “Withdrawn in NIST SP 800-171 Rev. 3; no implementation required,” and reference your SSP/crosswalk entry. Avoid inventing a compensating control that is not part of the baseline. ¹

Could 03.05.06 reappear in a future revision?

Frameworks can change across revisions, so manage this through baseline governance. If you adopt a new revision, re-run your crosswalk and update dispositions based on the new primary text. ¹

How do I keep withdrawn entries from showing up as red gaps on executive dashboards?

Adjust your control status taxonomy and reporting logic so “Withdrawn” is excluded from implementation gap metrics. Keep the supporting rationale attached so reporting remains traceable. ¹

Footnotes

1. NIST SP 800-171 Rev. 3