03.07.02: Withdrawn

03.07.02 is a withdrawn requirement in NIST SP 800-171 Rev. 3, so you do not implement a technical or procedural control for it. You do need to operationalize it for audit readiness: document that it is withdrawn, remove any legacy testing steps tied to it, and keep a clear crosswalk showing what (if anything) replaced it in your control baseline ¹.

Key takeaways:

• Treat “03.07.02: withdrawn requirement” as a governance and evidence-management task, not a control to implement ¹.
• Update your SSP, control matrix, and assessment procedures so auditors see an intentional “withdrawn” disposition, not a gap ¹.
• Keep artifacts that prove you reviewed the withdrawal, de-scoped testing, and mapped any prior control to current requirements ¹.

Compliance teams get burned on withdrawn controls for a simple reason: assessors and internal auditors still expect to see the requirement accounted for. “Withdrawn” does not mean “ignore it.” It means the standard no longer requires you to implement or assess that specific requirement as written, but your compliance story must explain the disposition cleanly and consistently across your documentation set.

For a CCO, Compliance Officer, or GRC lead supporting NIST SP 800-171 Rev. 3 programs (often in support of CUI obligations in contractor environments), the practical goal is assessment hygiene. Your system security plan (SSP), control implementation statements, policies, and evidence library must show that 03.07.02 was reviewed and intentionally marked as withdrawn, with no orphaned procedures, tickets, or test scripts still referencing it ¹.

This page gives you requirement-level implementation guidance focused on speed: who owns the decision, what to change in your control baseline, what evidence to retain, and what auditors commonly challenge when they see “withdrawn” controls handled inconsistently.

Requirement: 03.07.02: withdrawn requirement (NIST SP 800-171 Rev. 3)

“Withdrawn” in this context means NIST SP 800-171 Rev. 3 includes the identifier 03.07.02 but explicitly indicates the requirement is withdrawn ¹. There is no control text to implement. Your job is to manage the lifecycle impact: remove it from active scope while preserving traceability for auditors and customers.

Plain-English interpretation

• You are not expected to implement a security requirement for 03.07.02 because it is withdrawn ¹.
• You are expected to document how your program handles the withdrawal: classification in your control inventory, assessment approach, and change management record that explains why it is not implemented or tested ¹.
• You must ensure no conflicting artifacts suggest it is still required (for example, a policy or procedure listing 03.07.02 as “planned,” a POA&M item to “implement 03.07.02,” or an assessor workbook step that still tests it).

Who it applies to

Entity types

• Federal contractors and other organizations operating nonfederal systems that handle CUI, where NIST SP 800-171 Rev. 3 is the governing control set ¹.

Operational contexts

• You maintain an SSP/control matrix aligned to NIST SP 800-171 Rev. 3 for a CUI boundary.
• You undergo internal audits, customer audits, or external assessments where assessors use requirement identifiers and expect every identifier to have a disposition.

Why auditors still care (risk implications)

Withdrawn requirements create a specific audit risk: documentation inconsistency. If one artifact says “withdrawn,” another says “planned,” and a third still tests it, auditors may not fail you on the technical control, but they can still raise findings for weak governance, poor configuration of the compliance baseline, or unreliable assessment procedures. This can also slow assessments because reviewers spend time reconciling contradictions.

Regulatory text

Excerpt / identification: “NIST SP 800-171 Rev. 3 requirement 03.07.02 (Withdrawn).” ¹

Operator interpretation: Because NIST marks 03.07.02 as withdrawn, your operational obligation is to (1) mark it withdrawn in your compliance baseline, (2) confirm it is not being tested or tracked as an open gap, and (3) maintain traceability showing you reviewed the withdrawal and updated documentation accordingly ¹.

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

Use the steps below to operationalize the 03.07.02: withdrawn requirement across policy, controls, and evidence without creating “phantom gaps.”

1) Assign an explicit disposition in your control inventory

• In your control matrix/GRC tool, set 03.07.02 status to Withdrawn ².
• Add a short rationale field: “Withdrawn in NIST SP 800-171 Rev. 3; no implementation or assessment required.” ¹
• Set ownership to your GRC/control owner anyway. Withdrawn controls still need a person accountable for the record.

2) Remove 03.07.02 from assessment procedures and test plans

• Search assessor workpapers, internal audit programs, and continuous control monitoring checklists for “03.07.02”.
• Delete the test step or mark it “Not applicable – Withdrawn,” and ensure the report template will not count it as a failure or exception.
• If you use Daydream (or any control platform) for recurring evidence collection, ensure no evidence task is scheduled for 03.07.02. Keep the mapping entry but with a withdrawn designation.

3) Update the SSP and any customer-facing security narratives

In your SSP/control implementation statements:

• List 03.07.02 as Withdrawn with a one-line note.
• Do not write an implementation narrative (avoid creating the impression there is text you must satisfy).
• If older SSP versions described an implementation, add a change note in your SSP revision history indicating the control is now withdrawn ¹.

4) Reconcile legacy mappings (Rev. 2 artifacts, old crosswalks, third-party questionnaires)

Most organizations have “control inheritance” from older mappings, questionnaires, or customer spreadsheets. Do a reconciliation pass:

• Identify any place 03.07.02 is mapped to a policy section, procedure, ticket, or tool configuration.
• Decide whether that underlying safeguard still matters for other requirements. If yes, remap the safeguard to the current applicable requirement(s) and remove the 03.07.02 tag.
• If the safeguard is obsolete, retire it through normal change control.

5) Close or reclassify open POA&M items tied to 03.07.02

Common problem: a lingering POA&M item called “Implement 03.07.02.” Handle it cleanly:

• If the only driver is 03.07.02, close the item with closure reason “Withdrawn requirement; no longer applicable” and attach the withdrawal citation ¹.
• If the remediation is still needed for another requirement, retitle and relink the POA&M item to the correct requirement identifier(s).

6) Build a “withdrawn requirements register” for audit speed

Create a small register (spreadsheet or GRC report) listing:

• Requirement ID
• Status (Withdrawn)
• Standard/version reference
• Date reviewed
• Approver
• Artifacts updated (SSP section, control matrix entry, test procedure change) This prevents last-minute confusion during assessments.

Required evidence and artifacts to retain

Auditors typically want to see that “withdrawn” was handled systematically. Keep:

• Control matrix / GRC export showing 03.07.02 marked “Withdrawn” with the citation and date ¹.
• SSP excerpt or SSP control table row showing 03.07.02 = Withdrawn, plus SSP revision history entry if you previously described it.
• Assessment procedure change record (ticket, pull request, or document revision log) removing 03.07.02 test steps.
• POA&M updates: closure notes or remapped items if 03.07.02 appeared in remediation tracking.
• Crosswalk memo (one page) explaining how you treated withdrawn requirements and confirming 03.07.02 has no active control implementation requirements ¹.

Common exam/audit questions and hangups

Expect these lines of questioning:

1. “Why is 03.07.02 not implemented?”
   Answer: “It is withdrawn in NIST SP 800-171 Rev. 3; our control baseline marks it withdrawn, and we do not assess it.” Provide the citation and your register entry ¹.

2. “Where is this reflected in the SSP and test plans?”
   Show the SSP row and the assessment procedure revision log.

3. “Your policy references 03.07.02. Why?”
   This is a hangup that creates unnecessary findings. Remove the reference or remap the statement to the correct active requirement.

4. “How do you ensure withdrawn requirements don’t create gaps in your program?”
   Show your withdrawn requirements register and change management process.

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it causes findings	How to avoid it
Leaving 03.07.02 as “Not implemented” instead of “Withdrawn”	“Not implemented” reads like a control failure	Use an explicit withdrawn status and cite the standard 1.
Continuing to collect evidence for 03.07.02	Wastes time and creates contradictory artifacts	Disable evidence tasks; keep only the withdrawn mapping record.
Closing POA&M items without documentation	Auditors see unsubstantiated scope changes	Attach a memo and citation showing withdrawal 1.
Allowing multiple versions of the truth (SSP says withdrawn, audit plan still tests it)	Leads to governance/process findings	Run a quarterly search across templates and workpapers for the identifier and clean it up.
Treating “withdrawn” as “deleted everywhere”	Can break traceability during customer review	Keep the row in your matrix with status “Withdrawn,” rather than removing it entirely.

Practical execution plan (30/60/90-day)

Because timelines and durations are planning guidance (not factual claims), use this as an execution cadence you can adapt.

First 30 days (stabilize documentation)

• Update control inventory/control matrix entry for 03.07.02 to “Withdrawn” with citation ¹.
• Update SSP to show withdrawn status.
• Remove 03.07.02 from internal audit programs and assessment procedures.
• Search and clean policy/procedure references that cite 03.07.02.

Next 60 days (reconcile remediation and tooling)

• Review POA&M and ticketing for any items linked to 03.07.02; close or remap.
• Update third-party/customer security questionnaires templates and crosswalks.
• In Daydream or your GRC system, ensure recurring evidence workflows do not request artifacts for 03.07.02, but retain the withdrawn mapping for traceability.

By 90 days (operationalize as a repeatable pattern)

• Publish a withdrawn requirements register and attach it to your audit binder.
• Add a control in your compliance change management process: “New standard version impact review,” including a check for withdrawn identifiers ¹.
• Run an internal readiness review: confirm no tests, metrics, or dashboards flag 03.07.02 as a gap.

How Daydream fits (without adding process overhead)

If you manage NIST SP 800-171 control mappings in Daydream, treat 03.07.02 as a mapped requirement with a “Withdrawn” disposition, no evidence requests, and a standing citation note. This keeps your audit export coherent while preventing recurring evidence tasks from firing for a control you should not be implementing ¹.

Frequently Asked Questions

If 03.07.02 is withdrawn, can we just delete it from our control matrix?

Keep it listed with a “Withdrawn” status so an assessor can reconcile identifiers quickly. Deleting it often creates questions about whether you missed it ¹.

Should we mark 03.07.02 as “Not applicable” instead of “Withdrawn”?

“Withdrawn” is clearer and more defensible because it matches the standard’s labeling. “Not applicable” can imply scoping judgment rather than a change in the framework ¹.

What evidence do we show an auditor for a withdrawn requirement?

Provide the SSP/control matrix row marked “Withdrawn,” the citation to the standard, and a revision log showing you removed test steps. That package shows intentional handling rather than an untracked omission ¹.

Our older SSP (Rev. 2 era) had an implementation narrative for 03.07.02. Is that a problem?

It becomes a problem if the narrative still appears in current SSPs or customer packets. Move it to version history and clearly state the requirement is withdrawn in Rev. 3 ¹.

Do withdrawn requirements affect CUI safeguarding obligations?

The withdrawal means this specific requirement identifier is not part of the Rev. 3 requirement set. Your CUI safeguarding obligations still exist through the rest of NIST SP 800-171 requirements that remain in force ¹.

How do we prevent this from recurring when standards update?

Add a standard-update checklist step: identify added/changed/withdrawn identifiers, update the control matrix, and reconcile test plans and POA&M entries. Keep a withdrawn requirements register to speed future audits ¹.

Footnotes

1. NIST SP 800-171 Rev. 3

2. standard