03.05.09: Withdrawn

03.05.09 is a withdrawn requirement in NIST SP 800-171 Rev. 3, so you do not implement a technical or procedural control for it. You do, however, need to operationalize the “withdrawn” status: document the withdrawal, prevent teams from implementing a ghost control, and show assessors a clean crosswalk to whatever requirement(s) replaced or absorbed the intent. ¹

Key takeaways:

• Treat the 03.05.09: withdrawn requirement as a governance task: document, crosswalk, and keep your SSP/control matrix consistent. ¹
• “Withdrawn” does not mean “ignore”; it means “do not claim implementation,” and “do not leave an unmapped hole” in your assessment artifacts. ¹
• Your pass/fail outcome depends on evidence quality: show the assessor where 03.05.09 went and what you do instead, with approvals and version history. ¹

Compliance teams lose time (and credibility) when a control catalog contains placeholders that no longer exist. The operational risk is simple: you either waste effort implementing something that is not required, or you leave an “unexplained gap” that triggers avoidable assessor questions. Requirement pages for withdrawn items should be short on theory and heavy on execution: what to do in your GRC system, how to update your System Security Plan (SSP), what to show an auditor, and how to prevent the withdrawn item from reappearing in future evidence cycles.

For 03.05.09, NIST SP 800-171 Rev. 3 explicitly labels it “Withdrawn.” ¹ That single word drives your actions: you will not design or operate a new control specifically to satisfy 03.05.09. Your job is to (1) record the withdrawal, (2) map the requirement to “Withdrawn” in your control matrix, (3) identify any successor requirement(s) in your chosen baseline, and (4) retain artifacts that prove your mapping and your governance decisions. ¹

Requirement: 03.05.09: withdrawn requirement (NIST SP 800-171 Rev. 3)

What it means operationally: NIST SP 800-171 Rev. 3 lists requirement 03.05.09 as withdrawn. ¹ You should not build a standalone control to “implement 03.05.09.” You should treat it as a documentation and traceability requirement inside your compliance program.

Why withdrawn requirements still matter in audits

Even when withdrawn, the identifier (03.05.09) can persist in:

• legacy SSPs and POA&Ms,
• imported control libraries in your GRC tool,
• customer flow-down matrices and contract exhibits,
• third-party assessments that reference older mappings.

Assessors and customers will ask, “Why is this missing?” Your goal is to answer in one sentence and one screenshot: “It’s withdrawn in Rev. 3; here is the crosswalk and our governance approval.”

Regulatory text

Excerpt / status: “NIST SP 800-171 Rev. 3 requirement 03.05.09 (Withdrawn).” ¹

Operator interpretation:

• There is no control objective to satisfy under 03.05.09 in Rev. 3. ¹
• Your obligation is to keep your compliance artifacts accurate: mark it withdrawn, remove implementation claims, and document what requirement(s) you satisfy instead if the concept was moved elsewhere. ¹

Plain-English interpretation

Plain English: 03.05.09 is not an active requirement anymore. Don’t implement it, don’t test it, and don’t attest to it. Keep a clean paper trail that shows you noticed the withdrawal and updated your control mapping and SSP accordingly. ¹

Who it applies to (entity and operational context)

This applies to any organization using NIST SP 800-171 Rev. 3 as a contractual or program requirement, including:

• Federal contractors and subcontractors handling Controlled Unclassified Information (CUI) in nonfederal systems. ¹
• Nonfederal organizations operating systems that process, store, or transmit CUI and must align to NIST SP 800-171 Rev. 3 for customer requirements. ¹

Operationally, it applies to:

• the SSP owner (typically Security/GRC),
• the control library owner (GRC platform admin or compliance ops),
• the audit liaison (the person answering assessor questions),
• the system owner for the CUI environment (to ensure SSP accuracy).

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

Step 1: Confirm scope and baseline

1. Confirm the system(s) in scope for NIST SP 800-171 Rev. 3 and where 03.05.09 appears in your artifacts (SSP, control matrix, policies, POA&M). ¹
2. Confirm that your baseline is Rev. 3, not Rev. 2 or a mixed catalog in your tooling. ¹

Practical tip: If your GRC platform imported a generic “800-171” library, validate that it is explicitly Rev. 3 and that it contains the withdrawal flag for 03.05.09. ¹

Step 2: Update your control mapping (control matrix / crosswalk)

1. In your control matrix, set 03.05.09 to a status such as “Withdrawn (Rev. 3)”. ¹
2. Add a short rationale note: “Withdrawn in NIST SP 800-171 Rev. 3; no implementation required.” ¹
3. Add a cross-reference field:
   • If your program maintains an internal crosswalk, point to the successor requirement(s) you believe now covers the intent.
   • If you cannot identify a successor confidently, explicitly record: “No direct successor identified; withdrawn requirement; reviewed and approved by GRC.”

Daydream fit (earned): This is where Daydream helps most in practice: keeping the requirement-to-control mapping, policy references, and recurring evidence tasks synchronized so withdrawn items do not keep resurfacing in audit prep.

Step 3: Clean up implementation claims (SSP, narratives, and evidence requests)

1. SSP: Remove any “implemented” narrative that references 03.05.09. Replace it with: “Withdrawn in Rev. 3; not applicable as a requirement.” ¹
2. Procedures/runbooks: If any procedure was written “to satisfy 03.05.09,” re-title and re-scope it to the correct active requirement (or retire it if redundant).
3. Evidence cadence: Stop collecting recurring evidence “for 03.05.09” as a standalone request. Tie evidence to active requirements only.

Step 4: Document governance approval and version history

1. Create a short governance record (ticket, change request, or control review memo) capturing:
   • the decision to mark 03.05.09 as withdrawn,
   • the artifact changes made (SSP/control matrix),
   • approver names/roles,
   • effective date and impacted systems. ¹
2. Preserve revision history in your document repository (or in your GRC change log).

Step 5: Prepare an assessor-ready “one-page answer”

Build a small “assessor packet” entry for 03.05.09:

• screenshot/export of the requirement row showing “Withdrawn (Rev. 3),”
• link to the SSP section reflecting the withdrawn status,
• the governance approval record,
• any crosswalk notes to successor requirements.

This reduces live Q&A and prevents inconsistent answers from different stakeholders.

Required evidence and artifacts to retain

Keep artifacts that prove accurate interpretation and disciplined configuration management:

• Control matrix entry for 03.05.09 showing “Withdrawn (Rev. 3).” ¹
• SSP excerpt where 03.05.09 is marked withdrawn/not applicable due to withdrawal, with document version and date. ¹
• Change ticket / approval record for the update (who approved, what changed, when).
• Crosswalk note to successor requirement(s), if your program maintains successor mappings.
• Evidence request inventory showing that no periodic evidence is being requested solely for 03.05.09.

Common exam/audit questions and hangups

Assessors tend to focus on traceability and consistency:

• “Why is 03.05.09 missing from your SSP/control matrix?”
  Expectation: it is present and labeled withdrawn. ¹
• “Show me where Rev. 3 indicates it is withdrawn.”
  Expectation: point to the Rev. 3 requirement list showing “Withdrawn.” ¹
• “What control addresses the original intent?”
  Expectation: a reasoned crosswalk or documented decision that no successor is needed.
• “Do you still collect evidence for it?”
  Expectation: no standalone evidence collection; evidence aligns to active requirements.

Frequent implementation mistakes and how to avoid them

Mistake	Why it hurts	How to avoid it
Deleting 03.05.09 entirely from the control matrix	Creates an unexplained gap; triggers assessor questions	Keep the row, mark it “Withdrawn (Rev. 3)” with a citation note. 1
Marking it “Not Applicable” without saying “Withdrawn”	“N/A” can look like scoping avoidance	Use explicit language: “Withdrawn in Rev. 3.” 1
Continuing to test/collect evidence for 03.05.09	Wastes effort and confuses control ownership	Retire the evidence task or re-map it to an active requirement.
Letting different artifacts disagree (SSP says withdrawn; GRC tool says implemented)	Signals weak governance	Perform a controlled update across SSP, control matrix, and evidence plan with one approval record.
No crosswalk rationale	Leaves the assessor to guess what you did	Write one paragraph explaining where the intent is covered or why no successor applies.

Enforcement context and risk implications

No public enforcement cases were provided for this specific requirement in the source catalog. Your risk is still real but indirect: misstatements in compliance representations and assessment friction. A withdrawn control that is still claimed as “implemented” can undermine confidence in your SSP accuracy and change management discipline, which can expand audit scope and create follow-up findings.

Practical 30/60/90-day execution plan

First 30 days: Get clean and consistent

• Inventory every place 03.05.09 appears (SSP, policies, control matrix, POA&M, evidence tasks). ¹
• Update the control matrix row to “Withdrawn (Rev. 3)” and add a short rationale. ¹
• Update SSP language to remove any implementation claim and replace with withdrawn notation. ¹
• Create a single change record with approver sign-off.

Next 60 days: Crosswalk and stabilize operations

• Decide whether you will maintain a formal “withdrawn/superseded requirement crosswalk” as a program artifact.
• Re-map any procedures/evidence tasks that were mistakenly tied to 03.05.09.
• Train control owners and the audit liaison on the standard response for withdrawn items.

By 90 days: Build repeatability

• Add a recurring control library hygiene check: validate that withdrawn/superseded requirements remain correctly labeled after library updates.
• Add a pre-assessment checklist item: “All withdrawn requirements are explicitly labeled, not deleted.”
• If you use Daydream, configure the requirement mapping and evidence schedule so withdrawn items cannot generate evidence requests or appear as “missing” during readiness reviews.

Frequently Asked Questions

Do we need to implement anything for the 03.05.09: withdrawn requirement?

No. NIST SP 800-171 Rev. 3 lists 03.05.09 as withdrawn, so there is no control to implement for that identifier. Your task is to document the withdrawal and keep mappings and SSP text consistent. ¹

Should we delete 03.05.09 from our control spreadsheet and SSP?

Don’t delete it if you expect an assessor to reconcile requirement numbering. Keep it present and label it “Withdrawn (Rev. 3)” with a short rationale note and change record. ¹

What if a customer or third party assessor asks for evidence for 03.05.09?

Provide the Rev. 3 reference showing it is withdrawn, plus your control matrix/SSP excerpt that records the withdrawn status. If they are working from an older baseline, ask them to confirm which revision governs the engagement. ¹

How do we handle tooling that forces every requirement into “implemented/not implemented”?

Create a third status such as “Withdrawn” (preferred) or document “Withdrawn (Rev. 3)” in the requirement notes field and exclude it from test plans and evidence workflows. Preserve screenshots/exports that show the configuration.

Do we need a POA&M item for a withdrawn requirement?

No, unless your artifacts currently claim implementation and you need a tracked action to correct the documentation. Treat the cleanup as a governance remediation, then close it once SSP/control matrix updates are approved.

What evidence is enough to prove we handled 03.05.09 correctly?

Auditors usually accept a consistent trail: the requirement marked withdrawn in your control matrix, the SSP updated to match, and a change record showing who approved the updates and when. ¹

Footnotes

1. NIST SP 800-171 Rev. 3