03.07.01: Withdrawn

03.07.01 is a withdrawn requirement in NIST SP 800-171 Rev. 3, so you do not implement a technical or procedural control for it. You do, however, need to document that it is withdrawn, confirm it has no inherited obligations in your contract or assessment scope, and retain evidence that your control set and SSP/POA&M mapping account for the withdrawal. ¹

Key takeaways:

• Treat 03.07.01: withdrawn requirement as a governance task: document status, scope impact, and mapping decisions. ¹
• Auditors commonly flag withdrawals when the SSP/control matrix is silent or inconsistent across artifacts. ¹
• Your deliverable is “assessment-ready traceability”: a clear crosswalk showing “Withdrawn” with a rationale and no orphaned procedures. ¹

Withdrawn controls create a specific kind of compliance risk: confusion risk. Teams waste cycles trying to “implement” something that no longer exists, or worse, they remove an older control and accidentally break a different, still-applicable requirement. For a CCO or GRC lead, the fastest path is to treat 03.07.01 as a documentation and scoping requirement: clearly mark it as withdrawn in your control inventory, explain what that means for your environment, and keep your evidence consistent across the SSP, POA&M, policies, and assessment artifacts. ¹

NIST SP 800-171 applies in operational contexts where you handle Controlled Unclassified Information (CUI) in nonfederal systems, commonly as a federal contractor or a subcontractor in the defense industrial base. ¹ Even though 03.07.01 is withdrawn, your assessors still expect you to show you managed it correctly: the control catalog should not have gaps, contradictions, or untracked changes. ¹

This page gives you requirement-level, operator guidance: what “withdrawn” means, who needs to care, how to update your governance artifacts, what evidence to retain, and how to avoid common assessment failures tied to withdrawn control identifiers.

Regulatory text

Requirement: “NIST SP 800-171 Rev. 3 requirement 03.07.01 (Withdrawn).” ¹

What the operator must do

Because the requirement is explicitly marked Withdrawn, the operator action is to:

1. Record that 03.07.01 is withdrawn in your control catalog/control matrix and in any system documentation that lists requirements. ¹
2. Validate scope and obligations: confirm that no contract language, customer overlay, or internal standard re-introduces a requirement under the same identifier or equivalent intent. ¹
3. Keep artifacts consistent so assessors can follow the trail from requirement listing → applicability decision → evidence plan without encountering a missing row, placeholder text, or an incorrect “implemented” claim. ¹

Plain-English interpretation (what “withdrawn” means in practice)

A withdrawn requirement is one NIST has removed from the active set for that revision. You should not create a new policy, procedure, or technical configuration “for 03.07.01.” Your obligation shifts to traceability and change control: demonstrate that your program noticed the withdrawal, updated mappings, and avoided unintended control regressions elsewhere.

For assessment readiness, “withdrawn” still needs a deliberate entry in your documentation. Silence reads like a gap.

Who it applies to

Entity scope

• Federal contractors and subcontractors operating nonfederal systems that process, store, or transmit CUI. ¹
• Any nonfederal organization that has adopted NIST SP 800-171 Rev. 3 as a contractual or customer-driven requirement set for CUI protection. ¹

Operational context where this comes up

• You maintain an SSP and POA&M for an environment that handles CUI. ¹
• You run a control matrix (often in GRC tooling) mapping NIST requirements to policies, procedures, and technical implementations.
• You are preparing for an internal audit, customer assessment, or third-party assessment where the assessor expects complete coverage of requirement identifiers, including withdrawn ones.

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

Step 1: Locate every place 03.07.01 appears

Search across:

• SSP requirement tables
• Control matrix / crosswalk spreadsheets
• Policy/control library
• POA&M entries
• Evidence repository tags
• Prior assessment reports and remediation trackers

Deliverable: a short list of “occurrence locations” you can attach to your change record.

Step 2: Set the official status to “Withdrawn” everywhere

In each artifact where NIST requirements are listed, set:

• Status: Withdrawn
• Applicability: Not applicable (withdrawn)
• Rationale: “Withdrawn in NIST SP 800-171 Rev. 3” ¹

Avoid free-text improvisation. Keep the wording consistent so auditors can reconcile documents quickly.

Step 3: Confirm there is no “hidden re-introduction” via overlays

Even if NIST withdrew it, your obligations can still come from:

• Contract clauses or customer security addenda that reference older revisions
• Prime contractor flow-down requirements
• Internal corporate standards that still list a legacy control

Action: add a short memo in your compliance file stating: “Reviewed contract/security addenda for references to 03.07.01 or equivalent; none found” (or document what you found and how you addressed it). Keep it factual.

Step 4: Make sure you didn’t orphan related procedures or tooling checks

Withdrawn does not mean “delete everything that sounds similar.” Do a quick sanity check:

• If you previously had a procedure mapped to 03.07.01, confirm it is either:
  • still needed for another active requirement, or
  • intentionally retired with an approved change record

This prevents a common failure mode: removing a control implementation that still supports other requirements.

Step 5: Update your evidence plan to prevent “missing evidence” findings

Assessors frequently test completeness. If your evidence calendar expects an artifact for every requirement ID, mark 03.07.01 as:

• “No evidence required (withdrawn)” with an owner sign-off

This aligns your recurring collection process with the withdrawn status. ¹

Step 6: Capture a lightweight management sign-off

Add approval from the control owner, ISSM/CISO delegate, or GRC lead confirming:

• Status is withdrawn
• Scope impact assessed
• No compensating control required

This sign-off is often the difference between “clean pass” and a drawn-out clarification cycle.

Step 7: Operationalize in your GRC workflow (Daydream-friendly)

If you manage NIST requirements in Daydream, treat 03.07.01 as a governance record:

• Create/retain the requirement entry with status = Withdrawn
• Attach the decision memo and SSP excerpt
• Configure recurring evidence tasks to exclude withdrawn requirements but preserve the audit trail (policy mapping + rationale)

That setup keeps your assessment package coherent without generating busywork.

Required evidence and artifacts to retain

Minimum set (keep together in one “03.07.01 withdrawn” folder or GRC object):

• Control matrix/requirements crosswalk showing 03.07.01 marked Withdrawn ¹
• SSP excerpt (or requirements applicability table) showing Withdrawn + rationale ¹
• Decision memo / ticket documenting review of contractual overlays and the outcome
• Change record (optional but strong) showing updates made and who approved them
• Evidence plan entry stating “no evidence required; withdrawn,” with owner sign-off

Common exam/audit questions and hangups

Expect these and prepare one-page answers with your artifacts attached:

1. “Why is 03.07.01 missing from your SSP/control matrix?”
   Hangup: a missing row looks like incomplete coverage. Fix by listing it and marking it withdrawn. ¹

2. “Show me evidence for 03.07.01.”
   Answer: “Withdrawn in Rev. 3; no implementation required; here is the SSP/control matrix entry and decision memo.” ¹

3. “Did you remove any controls because it was withdrawn?”
   Hangup: assessors worry you broke another control. Show your impact review and cross-mapping results.

4. “Are you sure your contract doesn’t require an older revision?”
   Provide the contract/addendum review note (no editorializing, just findings).

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails in assessment	How to avoid it
Deleting 03.07.01 from the matrix	Creates an apparent gap	Keep the row; mark Withdrawn with rationale 1
Marking it “Implemented” with placeholder evidence	Looks like you don’t understand the standard	Use “Withdrawn; no evidence required” 1
Retiring a procedure without checking cross-maps	Can break another active requirement	Re-map the procedure to active requirements or retire via change control
Inconsistent wording across SSP/POA&M/matrix	Triggers reconciliation questions	Standardize the same status label and rationale everywhere
No contract overlay review	Leaves an obligation gap if older revision is flowed down	Document your review and outcome in a memo/ticket

Enforcement context and risk implications

No public enforcement cases were provided for this specific withdrawn requirement in the supplied sources. Practically, the risk is indirect: incomplete or inconsistent documentation can contribute to adverse assessment outcomes, customer findings, or remediation burdens tied to CUI protection obligations under NIST SP 800-171 programs. ¹

Practical 30/60/90-day execution plan

30 days: Stabilize documentation

• Inventory all references to 03.07.01 across SSP, matrix, POA&M, and evidence trackers.
• Update each artifact to show “Withdrawn” with a consistent rationale. ¹
• Create a single decision memo/ticket capturing contract overlay review results and approvals.

60 days: Normalize processes and prevent recurrence

• Update your evidence collection workflow to exclude withdrawn requirements while preserving traceability.
• Run a mini “mapping QA” on adjacent requirements to confirm no orphaned controls.
• Train control owners: withdrawn IDs stay in the matrix, but with “no evidence required.”

90 days: Audit-proof and automate

• Add a recurring governance check: when NIST revision mappings change, update SSP/matrix and log an approval.
• If you use Daydream, standardize a “Withdrawn requirement” workflow object: status, rationale, approver, and linked artifacts.
• Perform an internal mock review: can an auditor follow the chain in under an hour without emailing you for clarification?

Frequently Asked Questions

Do I need to implement anything for 03.07.01: withdrawn requirement?

No. The requirement is explicitly withdrawn in NIST SP 800-171 Rev. 3, so you don’t implement a control for it. You document the withdrawn status and retain mapping evidence that explains why no control/evidence exists. ¹

Should 03.07.01 remain in our SSP and control matrix?

Yes, keep it listed to prevent an apparent gap in coverage. Mark it “Withdrawn” with a short rationale so the assessor can reconcile your requirement inventory. ¹

What’s the best evidence to show an auditor for a withdrawn requirement?

Provide the SSP/control matrix line item showing “Withdrawn,” plus a decision memo or ticket showing you validated contractual overlays and approved the status. Tie those artifacts to your evidence plan entry stating no evidence is required. ¹

What if our prime contractor references an older NIST SP 800-171 revision that had different requirements?

Treat that as a contractual overlay and document it explicitly. Keep a written determination of which revision governs and whether any legacy requirement needs to be met outside Rev. 3’s baseline. ¹

Can we delete old procedures that were mapped to 03.07.01?

Only after confirming the procedure is not supporting other active requirements. If you retire it, document the change, update cross-maps, and keep the retirement record to avoid creating an audit gap.

How do I handle 03.07.01 in Daydream or another GRC tool?

Keep a requirement record marked “Withdrawn,” attach the SSP excerpt and decision memo, and configure workflows so it doesn’t generate recurring evidence tasks. The goal is clean traceability without busywork. ¹

Footnotes

1. NIST SP 800-171 Rev. 3