03.07.03: Withdrawn

NIST SP 800-171 Rev. 3 requirement 03.07.03 is withdrawn, so you do not implement a standalone control for it. You must treat it as a documentation and traceability task: confirm the withdrawal, map any legacy Rev. 2/early Rev. 3 references to current requirements, and update your SSP, assessment scope, and POA&M so assessors see a clean, current control baseline ¹.

Key takeaways:

• You don’t “comply” with 03.07.03; you prove you recognized it was withdrawn and removed it from scope ¹.
• The operational work is SSP/POA&M hygiene: crosswalk, traceability, and evidence that nothing material fell through the cracks ¹.
• Auditors will test whether your control set is current and whether gaps are still governed and tracked ².

Withdrawn requirements create an avoidable failure mode in NIST SP 800-171 programs: teams keep a “ghost control” in the SSP, keep collecting irrelevant evidence, or (worse) assume the withdrawn item means the underlying security objective no longer matters. For a CCO or GRC lead, the goal is simpler and more defensible: maintain a current baseline, demonstrate traceability from requirements to implementation, and prevent scope confusion during assessment.

NIST SP 800-171 Rev. 3 lists 03.07.03 as “Withdrawn” ¹. That status changes your job from engineering a safeguard to running change control across your compliance system: governance artifacts, control mappings, assessment procedures, and remediation tracking. If you are supporting a CUI environment for federal contracting, your assessor will care that your SSP accurately reflects what is required now, that your POA&M is current, and that you can explain any historical references to 03.07.03 without hand-waving ².

This page gives you requirement-level implementation guidance for operationalizing “Withdrawn” so you can close out ambiguity quickly and keep assessments clean.

Regulatory text

Excerpt: “NIST SP 800-171 Rev. 3 requirement 03.07.03 (Withdrawn).” ¹

Plain-English interpretation

• There is no active requirement to implement under 03.07.03. “Withdrawn” means NIST removed this item from the Rev. 3 requirement set ¹.
• Your compliance obligation is operational: ensure your internal compliance baseline reflects the current NIST SP 800-171 Rev. 3 requirements, and that your documentation does not claim compliance to a control that no longer exists ¹.
• Assessments still expect strong program hygiene: clear SSP statements, objective evidence, and POA&M governance for what remains in scope ².

Who this applies to (entity + operational context)

This guidance applies if you are:

• A federal contractor or subcontractor operating nonfederal systems that handle Controlled Unclassified Information (CUI) and using NIST SP 800-171 Rev. 3 as the control baseline ¹.
• A CCO, GRC lead, ISSO/ISSM, or control owner responsible for maintaining the System Security Plan (SSP), Plan of Action & Milestones (POA&M), assessment readiness, and change control across security documentation ².
• A team migrating from older internal mappings (for example, inherited spreadsheets, templates, or third-party GRC content) that still references 03.07.03.

Operationally, “withdrawn” matters most in these moments:

• Preparing for an internal assessment using NIST SP 800-171A methods ².
• Updating the SSP after architecture changes, tool changes, or control redesign.
• Responding to customer questionnaires or flowdown clauses where the customer expects a clean alignment to Rev. 3 requirements ¹.

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

1) Confirm the withdrawal and freeze the baseline

1. Record the authoritative status: capture the excerpt showing 03.07.03 is “Withdrawn” in your compliance repository ¹.
2. Set your baseline: document that your program is aligned to NIST SP 800-171 Rev. 3 and that withdrawn requirements are treated as non-applicable by definition ¹.

Operator tip: Don’t rely on tribal knowledge. Make the withdrawal status a controlled reference in the same place you store your SSP and assessment materials.

2) Identify where 03.07.03 appears in your environment

Work through these common locations:

• SSP control list and control narratives
• Control matrix/crosswalks (Rev. 2 to Rev. 3 mappings, customer mappings)
• Assessment scripts and test procedures (especially if based on older templates) ²
• POA&M entries (open items tied to 03.07.03)
• Evidence folders and recurring evidence tasks

Deliverable: a short “impact list” of every artifact that references 03.07.03, including document name, owner, and remediation action.

3) Decide the disposition: remove, remap, or retain as historical

Use a simple decision matrix:

If 03.07.03 is referenced in…	Do this	Evidence you keep
SSP requirement list	Remove it from the in-scope requirement inventory; add a note in change log	SSP revision history; change ticket
SSP narrative	Replace with correct current requirement mapping or delete narrative if it was solely for 03.07.03	Redlined SSP; approval record
POA&M item	Close as “withdrawn requirement” only if the gap is truly tied only to 03.07.03; otherwise remap to the correct active requirement	POA&M update; closure rationale; validation notes
Test procedure	Remove the test step or rewrite it to test the correct active requirement 2	Updated test script; version control

Key control objective: nothing security-relevant disappears just because the requirement label disappeared. If your old 03.07.03 control narrative described a real safeguard, you either keep that safeguard under a different active requirement or document why it is out of scope.

4) Update ownership, implementation criteria, and recurring evidence for the active set

Even though 03.07.03 is withdrawn, assessors still evaluate whether your in-scope requirements are implemented and evidenced ². Do three things across the remaining mapped requirements:

• Assign an accountable control owner for each requirement statement in the SSP ¹.
• Define measurable implementation criteria (what “implemented” means in your environment) and what evidence proves operation ².
• Set evidence collection into a repeatable cadence (for example, triggered by system change, monthly ops review, quarterly access review). Treat cadence as a governance choice you can defend; don’t guess what an assessor wants.

If you use Daydream, this is where it helps: you can attach requirement-to-SSP statements, bind each statement to systems and owners, and run a living evidence checklist so withdrawn items don’t linger in task queues.

5) Run an assessor-style sanity check (NIST SP 800-171A lens)

Use NIST SP 800-171A concepts to validate readiness:

• Can you show the SSP statement for each in-scope requirement? ²
• Can you produce objective evidence tied to that statement? ²
• Are gaps tracked with risk context and closure validation? ²

For 03.07.03 specifically, your “test” is documentary:

• Show that 03.07.03 is withdrawn ¹.
• Show it does not appear as an implemented/in-scope control in your SSP and testing scope.
• Show any historical items were remapped or dispositioned with approvals.

Required evidence and artifacts to retain

Keep a tight evidence packet so withdrawal does not become a debate during audit:

1. Authoritative citation excerpt showing “03.07.03 (Withdrawn)” ¹.
2. SSP change log entry documenting removal/remapping, with date, approver, and rationale.
3. Crosswalk/mapping update: where old references were mapped to current requirement IDs (or removed).
4. POA&M updates:
   • closure rationale if closed due to withdrawal,
   • remapping notes if the gap persists under a different requirement,
   • validation evidence if marked complete.
5. Assessment procedure updates (test plan / scripts) reflecting current scope ².
6. Governance ticket (change request) linking all edits and approvals in one chain.

Common exam/audit questions and hangups

Expect questions like:

• “Why is 03.07.03 missing from your SSP control set?”
  Your answer: it is withdrawn in Rev. 3, and your baseline is Rev. 3 ¹.
• “You closed a POA&M item mapped to 03.07.03. How did you ensure the underlying risk is addressed?”
  Provide the remap or explain why no active requirement applies, then show compensating controls or scoping rationale.
• “What changed in your environment when you removed it?”
  Correct response: documentation scope changed; security architecture changes only if the control was truly unnecessary or duplicated elsewhere, with documented risk acceptance if applicable.
• “Show objective evidence for the related requirement(s) you remapped to.”
  This is where NIST SP 800-171A-aligned evidence discipline matters ².

Frequent implementation mistakes (and how to avoid them)

1. Leaving 03.07.03 in the SSP as ‘Implemented’
   Fix: remove it and keep a revision note that it is withdrawn ¹.

2. Closing POA&M items without confirming remap
   Fix: require a closure checklist: “withdrawn-only?” and “if not, map to active requirement.”

3. Treating “withdrawn” as “ignore the underlying control objective”
   Fix: review any legacy narrative/evidence tied to 03.07.03, then decide whether it belongs under another requirement or under internal policy.

4. Evidence sprawl (teams keep collecting artifacts “just in case”)
   Fix: tie each evidence artifact to an in-scope SSP statement and owner. Archive the rest.

Risk implications and enforcement context

No public enforcement cases were provided for this requirement in the source catalog, so don’t expect a regulator to cite “03.07.03” directly. The real risk is second-order: scope confusion and credibility loss in customer-driven assessments. If your documentation shows withdrawn requirements as active, assessors may question the reliability of your SSP and POA&M governance ². That can expand testing, slow reviews, and surface additional findings.

Practical execution plan (30/60/90 days)

Use this as a pragmatic rollout pattern. Treat timeboxes as targets; adjust to your assessment calendar.

First 30 days (stabilize and clean scope)

• Capture withdrawal proof and file it with your NIST baseline references ¹.
• Inventory every mention of 03.07.03 across SSP/POA&M/testing/evidence.
• Submit and approve a single change ticket that governs edits end-to-end.
• Remove 03.07.03 from the SSP requirement list and update crosswalks.

Days 31–60 (remap and harden evidence)

• For each legacy reference, decide: remove vs. remap to an active requirement.
• Update POA&M entries and ensure closure includes rationale and validation.
• Update assessment scripts so test steps align to the active requirement set ².
• Confirm each in-scope requirement has an owner, implementation criteria, and evidence expectations.

Days 61–90 (prove operational readiness)

• Run an internal “tabletop assessment” using your updated SSP and NIST SP 800-171A-style evidence prompts ².
• Spot-check evidence for a sample of requirements to ensure artifacts are current, attributable, and reproducible.
• Lock the control baseline for your next assessment cycle and train control owners on what changed (withdrawn item removed; mappings updated).

Frequently Asked Questions

If 03.07.03 is withdrawn, do I need to document anything at all?

Yes. Document that it is withdrawn and show you removed it from your SSP/control inventory while preserving traceability in your change log ¹.

Can I mark 03.07.03 as “N/A” in the SSP instead of removing it?

You can, but removal plus a clear change record is usually cleaner. If you keep it as “N/A,” label it explicitly as “Withdrawn in Rev. 3” and ensure it does not trigger evidence tasks ¹.

We have open POA&M items tied to 03.07.03. Can we close them immediately?

Close only if the gap is purely tied to the withdrawn identifier. If the gap represents a real control deficiency, remap it to the correct active requirement and keep it governed until validated ².

What will an assessor check related to a withdrawn requirement?

Expect checks for baseline currency and documentation integrity: current SSP, coherent mappings, and objective evidence for what remains in scope ².

Does “withdrawn” mean NIST decided the security practice is unnecessary?

It only means the requirement label is not part of Rev. 3. Review what your legacy control narrative was doing, then determine whether it belongs under another active requirement or under internal policy ¹.

How should we handle third-party questionnaires that still ask about 03.07.03?

Respond with a short statement that 03.07.03 is withdrawn in NIST SP 800-171 Rev. 3, provide the citation, and offer the current requirement(s) you use to cover the underlying practice if applicable ¹.

Footnotes

1. NIST SP 800-171 Rev. 3

2. NIST SP 800-171A