03.05.10: Withdrawn

A withdrawn requirement is a trap for otherwise mature programs: teams carry forward old control IDs in policies, SSPs, POA&Ms, GRC tools, or third-party due diligence questionnaires, then lose time defending an apparent “gap” during an internal audit, customer review, or certification readiness effort. Requirement 03.05.10 in NIST SP 800-171 Rev. 3 is explicitly marked “Withdrawn,” which means the right operational outcome is not to build a new control, but to prove you have governance around standards changes and that your implementation maps to the active Rev. 3 requirements set. ¹

For a Compliance Officer, CCO, or GRC lead, the work is practical: confirm where 03.05.10 appears, update mappings, retire obsolete test steps, and preserve a clean decision record that an assessor can follow quickly. The goal is simple: no open POA&M items tied to withdrawn text, no stale policy references, and no control testing scripts that waste cycles on a non-requirement.

This page gives requirement-level implementation guidance you can execute immediately, including a step-by-step playbook, evidence to retain, and common audit hangups specific to withdrawn requirements.

Regulatory text

Excerpt (as provided): “NIST SP 800-171 Rev. 3 requirement 03.05.10 (Withdrawn).” ¹

Plain-English interpretation

• There is no active obligation under 03.05.10 in Rev. 3. You are not expected to design or operate a distinct control that “satisfies 03.05.10.”
• Your obligation is governance and traceability: your compliance documentation (SSP, control matrix, assessment procedures, POA&M, policies/standards) should reflect that 03.05.10 is withdrawn and should not be tested as a requirement. ¹

What the operator must do

1. Record the withdrawn status in your control library and compliance mappings.
2. Eliminate “orphaned” references to 03.05.10 across your program artifacts.
3. Ensure coverage is preserved by confirming whether your environment implemented a legacy control that still matters and, if so, map it to the correct current requirement(s) or treat it as a voluntary security control with a defined owner and evidence.

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Who it applies to

Entity scope

• Federal contractors and other organizations that must implement NIST SP 800-171 to protect Controlled Unclassified Information (CUI) in nonfederal systems. ¹
• Nonfederal systems handling CUI where NIST SP 800-171 Rev. 3 is used as the security requirements baseline. ¹

Operational context (where this shows up)

You will encounter 03.05.10 most often in:

• SSP and control matrices that were started under an earlier revision and carried forward.
• GRC platforms/control libraries with older requirement catalogs imported.
• Customer or prime contractor questionnaires that reference outdated requirement IDs.
• Internal audit scripts that still contain test steps for 03.05.10.

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

Step 1: Create an explicit “Withdrawn requirement” decision record

• Add an entry in your requirements register: “03.05.10 — Withdrawn in NIST SP 800-171 Rev. 3.” ¹
• Document the program decision: “No standalone control implemented; references removed; legacy intent mapped where applicable.”
• Assign an owner (usually GRC) responsible for maintaining withdrawn/retired requirement handling.

Output: Withdrawn Requirement Memo / decision log entry.

Step 2: Find every reference to 03.05.10 and classify it

Run a targeted search across:

• SSP
• Policies and standards
• POA&M
• Control test procedures
• Vendor/third-party security exhibits
• Training material
• Ticket templates and recurring evidence tasks

Create a simple table:

Location	Reference type	Action	Owner	Due date
SSP	Control mapping row	Remove/mark withdrawn	GRC	Next SSP update
Audit script	Test step	Retire test	Internal audit	Before next audit
Customer questionnaire template	Requirement list	Update template note	Sales/GRC	Before next renewal

Output: 03.05.10 Remediation Tracker.

Step 3: Determine whether you have a “legacy control” that still needs to exist

Even if the requirement is withdrawn, you may have implemented something historically aligned to it. Decide which of the following applies:

Decision matrix

• A. Purely administrative artifact: 03.05.10 appears only as a label in documents.
  Action: Remove/mark withdrawn and close out any related POA&M items as “not applicable due to withdrawal,” with citation. ¹
• B. Control exists and remains good security practice: You still want the behavior (for risk reduction), but it is not required under this ID.
  Action: Keep the control as supplemental (program choice) and map it to your internal control objective or another applicable requirement. Avoid claiming it “meets 03.05.10.”
• C. Control exists because a contract/customer still requires it: A prime or customer may contractually reference 03.05.10 even if Rev. 3 withdraws it.
  Action: Treat as a contract requirement. Add a contract obligation record and implement/attest to the contractual clause while also noting that the framework requirement is withdrawn in Rev. 3. ¹

Output: Mapping note showing whether the legacy control is removed, re-mapped, or maintained as contractual/supplemental.

Step 4: Update your SSP and control mapping to prevent assessment friction

Assessors want a clean story:

• In the SSP control table, replace 03.05.10 with “Withdrawn (Rev. 3)” and a short explanation.
• Remove it from any “implemented/not implemented” scoring logic so your dashboards don’t show an artificial gap.
• If your tooling cannot mark it withdrawn, mark it Not Applicable with a justification that includes the provided excerpt. ¹

Output: Updated SSP section + updated control mapping export.

Step 5: Adjust recurring evidence and testing

• Remove any scheduled evidence tasks whose only purpose was “03.05.10 evidence.”
• Update internal audit test scripts so sampling doesn’t include 03.05.10.
• If you maintain a supplemental control, keep evidence tasks but label them to your internal control ID, not the withdrawn requirement.

Output: Updated audit program / evidence calendar.

Step 6: Prepare a short “exam-ready” explanation

Write a one-paragraph script for auditors/customers:

• “03.05.10 is withdrawn in NIST SP 800-171 Rev. 3; we do not test it as a requirement. We identified legacy references, updated our SSP and control matrix, and retained a decision memo and change history to show traceability.” ¹

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Required evidence and artifacts to retain

Keep evidence tight and reviewable. Recommended artifacts:

1. Withdrawn requirement decision memo referencing the excerpt. ¹
2. Updated SSP/control matrix export showing 03.05.10 marked withdrawn or removed with justification. ¹
3. Change log (ticket IDs, document revision history, or approval records) proving you executed updates.
4. Search/remediation tracker listing every place 03.05.10 was found and resolved.
5. POA&M closure notes if any items were incorrectly tied to 03.05.10, including closure rationale and approver.
6. Contractual obligations register if a customer/prime still contractually cites 03.05.10, with the compensating implementation and reporting path.

If you run Daydream or another GRC workflow, store these as a single “withdrawn requirement package” so auditors can self-serve the trail without meetings.

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Common exam/audit questions and hangups

• “Show me how you satisfy 03.05.10.”
  Provide the excerpt showing it is withdrawn and your decision memo plus SSP mapping. ¹
• “Why is 03.05.10 marked ‘not implemented’ in your dashboard?”
  Fix the tooling logic. Withdrawn items should not be scored as gaps.
• “Your policy references 03.05.10; is your policy current?”
  Demonstrate policy maintenance cadence and the specific revision that removed the reference.
• “Does removing 03.05.10 reduce your security posture?”
  Explain whether any legacy control remains as supplemental and point to its current mapping and evidence set.

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Frequent implementation mistakes and how to avoid them

1. Leaving the control ID in templates and questionnaires
   Fix the source templates, not just one document. Otherwise the reference reappears during the next refresh cycle.
2. Closing POA&M items without documenting the basis
   Auditors accept “withdrawn” when you show the citation and an approval trail. Keep both. ¹
3. Marking it “not applicable” but still testing it
   Align your audit program with your SSP. Mixed signals create avoidable findings.
4. Assuming “withdrawn” means “ignore forever”
   Customers can still contractually demand behaviors. Treat those as contract obligations and track them separately from NIST requirement IDs.

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Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this specific withdrawn requirement, so you should treat the risk as assessment and contractual nonconformance, not direct “violation of 03.05.10.” The real exposure looks like:

• Failed assessments due to inconsistent artifacts (SSP says withdrawn; audit script tests it; POA&M lists it as open).
• Customer friction when outdated questionnaires create apparent gaps.
• Bid risk if your representations about NIST alignment include withdrawn IDs without explanation.

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Practical 30/60/90-day execution plan

First 30 days (stabilize and stop reintroducing the problem)

• Publish the withdrawn decision memo and add it to your control library entry for 03.05.10. ¹
• Run the reference search across SSP, POA&M, policy, test scripts, and third-party due diligence templates.
• Freeze new uses: update templates so teams can’t keep adding 03.05.10 back into scope.

Next 60 days (remediate artifacts and align testing)

• Update SSP/control matrix and get approvals captured in your document control process.
• Close or reclassify POA&M items tied to 03.05.10 with documented rationale. ¹
• Update internal audit procedures and evidence schedules so 03.05.10 is not part of routine sampling.

Next 90 days (institutionalize change management)

• Add a standards-change playbook step: “identify withdrawn/retired requirements and remove from scoring.”
• Train control owners and audit staff on how your program handles withdrawn requirements.
• In Daydream, set a recurring governance task to reconcile requirement catalogs against your SSP and templates when standards update.

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How Daydream fits (without adding noise)

Daydream is useful here when you need (1) a single control library source of truth, (2) evidence packaging for auditors, and (3) change tracking across SSP, mappings, and tests. The “withdrawn requirement package” approach prevents the repeat cycle where different teams fix different documents inconsistently.

Frequently Asked Questions

If 03.05.10 is withdrawn, do I have to do anything at all?

Yes. You must prevent it from appearing as an unaddressed requirement in your SSP, POA&M, testing scripts, and templates, and retain evidence that it is withdrawn in Rev. 3. ¹

Should I mark 03.05.10 as “Not Applicable” or remove it entirely?

Either can work if your tooling supports it consistently. The priority is to avoid scoring it as a gap and to keep a justification that cites the withdrawn status. ¹

What if a customer questionnaire still asks for 03.05.10?

Respond that it is withdrawn in NIST SP 800-171 Rev. 3 and provide your decision memo. If the customer insists contractually, track it as a contract requirement separate from the framework mapping. ¹

Could an assessor still write a finding for 03.05.10?

They should not assess a withdrawn requirement as a control deficiency. Findings are more likely if your artifacts conflict (for example, SSP says withdrawn but your audit program tests it). ¹

Do I need to keep evidence for a control that used to map to 03.05.10?

Keep evidence only if the underlying control remains in scope as a supplemental or contractual control. Otherwise retain the change history showing you retired the mapping and removed recurring evidence tasks.

How do I show “implementation” for a withdrawn requirement in a GRC tool?

Record it as withdrawn with a citation note, attach the decision memo, and link remediation tickets that removed references from SSP, templates, and tests. The “evidence” is the traceability package, not a control operation. ¹

Footnotes

1. NIST SP 800-171 Rev. 3