03.07.03: Withdrawn

03.07.03 in NIST SP 800-171 Rev. 3 is a withdrawn requirement, so you do not implement a standalone control for it. You still must operationalize it by documenting the withdrawal, mapping any legacy implementations to current requirements, and retaining evidence that your 800-171 program tracks requirement changes and removes obsolete control claims. ¹

Key takeaways:

• Treat the 03.07.03: withdrawn requirement as a governance and scoping task, not a technical control build.
• Update your SSP/control crosswalk to show “withdrawn”, with rationale and replacement mapping if your program previously implemented it.
• Keep assessment-ready evidence that your program tracks NIST requirement changes and prevents “phantom compliance” claims. ¹

A withdrawn requirement is easy to mishandle because it creates a gap between “what we built” and “what we should claim.” For NIST SP 800-171 Rev. 3 requirement 03.07.03, NIST explicitly marks it as withdrawn, which means assessors should not expect a discrete control implementation tied to that identifier. ¹

Your job as a Compliance Officer, CCO, or GRC lead is to prevent two common failures: (1) teams continuing to test and report against an obsolete requirement, and (2) teams deleting evidence without preserving change history, creating audit friction and weakening your ability to explain how you maintain an accurate 800-171 baseline over time. This page gives requirement-level implementation guidance focused on fast operationalization: what to change in your SSP and control library, how to update mappings and test plans, what artifacts to retain, and what assessors typically question when they see “withdrawn” in the requirements set. ¹

Regulatory text

Requirement name: 03.07.03: Withdrawn
Regulatory excerpt: “NIST SP 800-171 Rev. 3 requirement 03.07.03 (Withdrawn).” ¹

Plain-English interpretation

• There is no active compliance obligation under the identifier 03.07.03 in Rev. 3 because NIST withdrew it. ¹
• Your operational obligation is therefore programmatic: keep your control baseline accurate, stop claiming coverage for 03.07.03 as if it were active, and ensure any previous control activity is either (a) mapped to another current requirement, or (b) reclassified as a security best practice outside the 800-171 requirement set. ¹

What an operator must do:

1. Mark 03.07.03 as withdrawn everywhere it appears (SSP, control matrix, test plan, evidence inventory). ¹
2. Eliminate “phantom” testing and compliance statements tied to 03.07.03.
3. Preserve traceability: if you previously built controls/evidence around 03.07.03, document what happened to them (mapped forward, retired, or treated as optional).

Who it applies to

Entity scope

• Federal contractors and other organizations operating nonfederal systems that handle CUI and align their CUI environment to NIST SP 800-171 Rev. 3. ¹

Operational context

• Applies to GRC and compliance operations responsible for:
  • System Security Plan (SSP) maintenance
  • Control framework mapping and control ownership
  • Assessment preparation (internal reviews, mock audits, external assessments)
  • Change management for security requirements and control baselines
• Also affects third-party governance when you flow down requirements. If your supplier language references 03.07.03 explicitly, you need to correct it to avoid imposing a dead requirement.

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

Step 1: Locate every mention of 03.07.03 in your compliance stack

Search across:

• SSP and any appendices
• Control library / control narratives
• Requirement-to-control crosswalks (including spreadsheets)
• Audit test scripts and sampling plans
• GRC tool requirement objects
• Contract templates / CUI addenda / supplier security exhibits

Deliverable: a short “03.07.03 touchpoints list” showing the system(s), document name, section, owner, and required change.

Step 2: Update the requirement status to “Withdrawn” and remove compliance claims

In each location:

• Replace the requirement text with a clear label: “Withdrawn in NIST SP 800-171 Rev. 3.” ¹
• Remove any “Implemented” / “Compliant” status that implies an active requirement.
• If your tooling forces a status, set it to a non-scoring category such as “Not Applicable – Withdrawn,” and document why.

Controls to implement here are governance controls: accurate scoping, correct representations, and clean assessment artifacts.

Step 3: Decide what to do with any legacy control activity tied to 03.07.03

Use this decision matrix:

Situation you find	Required action	Evidence to retain
You built a control specifically to satisfy 03.07.03	Re-map it to a current, applicable requirement if it genuinely supports that requirement; otherwise reclassify as “security best practice”	Mapping rationale; updated control narrative; updated test procedure
03.07.03 is in your SSP but never implemented	Mark as withdrawn; remove planned milestones tied to it	SSP change log; approval record
Your audit plan includes tests for 03.07.03	Retire the test case; update audit plan and sampling	Retired test case record; updated audit plan
Supplier contracts reference 03.07.03	Update template language; notify affected suppliers where needed	Contract redlines; executed amendments if applicable

Step 4: Update assessment workflows so the withdrawal doesn’t become an audit finding

Assessors often react to withdrawn items in two ways: they either ignore it (best case) or ask you to explain why it appears in your SSP or control matrix (common case). Prepare a standard response:

• “03.07.03 is withdrawn in NIST SP 800-171 Rev. 3. We track withdrawn requirements in our SSP as withdrawn to preserve traceability and prevent legacy test scripts from persisting.” ¹

Then operationalize that response:

• Add a “Withdrawn/Deprecated Requirements” section to your SSP appendix or control matrix notes.
• Add a control mapping governance check to your recurring compliance cadence: “Do any requirement IDs in our library show as withdrawn/deprecated in the governing version?”

Step 5: Set recurring evidence collection (so you can prove you manage withdrawals)

A withdrawn requirement is a governance test. Build a small, repeatable evidence set:

• A “requirements change log” entry for 03.07.03
• A current crosswalk export showing 03.07.03 marked withdrawn
• Meeting notes or ticket showing review and approval of changes
• Updated audit plan/test plan reflecting retirement of 03.07.03 tests

Daydream fit (earned, not forced): if you manage controls and evidence in Daydream, create a lightweight workflow that (a) tags 03.07.03 as withdrawn, (b) links it to the SSP section where it’s recorded as withdrawn, and (c) schedules an annual “framework drift” review so obsolete requirement objects do not reappear through templates or imports.

Required evidence and artifacts to retain

Keep artifacts that prove governance discipline and traceability:

1. SSP change record

   • Redline or version diff showing 03.07.03 marked “Withdrawn.”
   • Approval/attestation (ticket, change request, meeting minutes).

2. Updated control crosswalk / control matrix

   • Entry for 03.07.03 set to “Withdrawn,” with notes referencing the Rev. 3 status. ¹

3. Legacy mapping memo (one page is enough)

   • If you had a legacy control, document whether it was:
     • mapped to another active requirement, or
     • retained as best practice outside the 800-171 requirement set, or
     • retired.

4. Audit/test plan updates

   • Retired test procedures or updated workpapers showing 03.07.03 removed from the test universe.

5. Third-party artifacts (if applicable)

   • Updated supplier security exhibit templates (redlines).
   • Communications to suppliers if the requirement was previously flowed down.

Common exam/audit questions and hangups

Expect questions like:

• “Why is 03.07.03 in your SSP if it is withdrawn?”
  Good answer: traceability plus proof you don’t claim it as active.

• “Show me where you track changes between versions and prevent outdated requirements from being tested.”
  Provide your requirements change log, ticketing evidence, and updated test plan.

• “Did you remove any security capability because the requirement was withdrawn?”
  Be ready to show that you evaluated the legacy capability and decided to retain it as best practice or mapped it elsewhere, based on risk.

Hangup to avoid: an assessor seeing “Implemented” next to 03.07.03. That reads like you are assessing against the wrong baseline.

Frequent implementation mistakes and how to avoid them

1. Deleting 03.07.03 everywhere without leaving a trace

• Fix: keep the entry but label it withdrawn, or retain a historical appendix. Auditors dislike unexplained disappearances.

2. Leaving orphaned tests and evidence requests

• Fix: remove 03.07.03 from audit scripts, evidence trackers, and GRC task lists. Otherwise teams keep collecting meaningless evidence.

3. Accidentally flowing down 03.07.03 to third parties

• Fix: update templates and standard exhibits. Your third-party governance should reflect the same baseline you claim internally.

4. Mapping a legacy 03.07.03 control to a random active requirement

• Fix: only remap when the control objective truly aligns. If it doesn’t, mark it as best practice and keep it out of your 800-171 scoring narrative.

Enforcement context and risk implications

No public enforcement cases are provided for this specific withdrawn requirement in the supplied sources.

Your real risk is representation risk: claiming compliance to a requirement set while using an outdated or internally inconsistent baseline. That shows up as:

• inconsistent SSP vs. test plan,
• confused control ownership,
• time wasted during assessments,
• weakened credibility during customer or government reviews.

Treat “withdrawn” as a maturity test: can you demonstrate clean configuration control over your compliance baseline? ¹

Practical 30/60/90-day execution plan

You asked for speed. Use phases below and execute them as a mini change-control project.

First 30 days (Immediate stabilization)

• Identify all mentions of 03.07.03 across SSP, crosswalks, and test plans.
• Update SSP/control matrix to mark 03.07.03 as withdrawn with a short note referencing Rev. 3. ¹
• Retire audit test steps and evidence requests tied to 03.07.03.
• Open and close a formal change ticket with approvals.

Days 31–60 (Normalize and prevent recurrence)

• Publish a one-page “withdrawn requirements handling” SOP: how you label them, where you record them, who approves changes.
• Review third-party templates and flowdowns; remove 03.07.03 references.
• Train control owners and internal audit on the new baseline so nobody tests against 03.07.03 out of habit.

Days 61–90 (Make it assessment-ready)

• Run a mini “framework drift” check: confirm no other withdrawn/deprecated IDs exist in your system.
• Produce an assessor-ready evidence packet:
  • SSP diff
  • crosswalk export
  • retired test plan record
  • mapping memo for any legacy controls
• If you use Daydream (or any GRC tool), automate recurring exports/screenshots for evidence so the withdrawal handling is easy to prove during reviews.

Frequently Asked Questions

Do we need to implement anything for the 03.07.03: withdrawn requirement?

No standalone control is required because the requirement is withdrawn in NIST SP 800-171 Rev. 3. Your job is to document the withdrawal, remove compliance claims, and keep traceable records. ¹

Should we delete 03.07.03 from our SSP and control matrix?

Prefer marking it “Withdrawn” rather than deleting it, unless your SSP format forbids it. Keeping a labeled record avoids confusion and supports traceability during assessments. ¹

What if we previously built a control specifically for 03.07.03?

Evaluate whether that control supports any current, applicable requirement; if yes, remap it with a written rationale. If not, keep it as a security best practice or retire it through normal change control.

How do we handle this in a GRC tool that requires a status for every requirement?

Use a non-scoring category like “Withdrawn” or “Not Applicable – Withdrawn” and attach the Rev. 3 excerpt to the requirement record. Then ensure no tests or evidence tasks remain tied to it. ¹

Could an assessor still ask about 03.07.03?

Yes, if it appears in your artifacts or historical workpapers. Be ready with a short explanation, plus evidence that you updated the SSP, crosswalk, and audit plan to reflect withdrawal. ¹

Does “withdrawn” mean we should remove the underlying security practice from our environment?

Not automatically. Decide based on risk and system needs; many teams keep the capability as best practice even when it no longer maps to an active requirement.

Footnotes

1. NIST SP 800-171 Rev. 3