03.08.06: Withdrawn

NIST SP 800-171 Rev. 3 requirement 03.08.06 is withdrawn, so you do not implement a standalone control for it. Your job is to (1) confirm it is truly withdrawn in your adopted baseline, (2) remove or clearly mark any legacy control mapping, and (3) prove in your SSP/POA&M and assessment package why it is “not applicable/withdrawn,” without creating an audit gap. ¹

Key takeaways:

• Treat 03.08.06 as a documentation and traceability requirement, not a technical build requirement. ¹
• Update your SSP, control crosswalk, and assessment narrative so assessors see an intentional “withdrawn” disposition, not an omission. ¹
• If your environment still performs the old intent as a local control, keep it, but don’t claim it satisfies 03.08.06; map it to the correct current requirement(s). ¹

Withdrawn requirements create a specific kind of compliance risk: teams either waste time building to a control that no longer exists, or they silently drop it and trigger assessor questions about completeness and traceability. Requirement 03.08.06 in NIST SP 800-171 Rev. 3 falls into this category. The text is explicit that 03.08.06 is withdrawn, which means there is no current control objective to implement under that identifier. ¹

For a CCO or GRC lead supporting CUI environments, the operational goal is straightforward: make your control set defensible. That means your System Security Plan (SSP) should show a deliberate disposition for 03.08.06, your crosswalk should prevent accidental “gaps,” and your POA&M should not carry remediation work tied to a requirement that is no longer active. Assessors still expect clean mapping, current documentation, and evidence that your implementation matches the current revision you claim to follow. ²

This page gives you a requirement-level playbook to operationalize “withdrawn” correctly, including what to change in documentation, what evidence to retain, and how to answer exam-style questions without improvising.

Regulatory text

Excerpt (as provided): “NIST SP 800-171 Rev. 3 requirement 03.08.06 (Withdrawn).” ¹

Operator interpretation

A “withdrawn” requirement means NIST has removed this requirement from the active set for Rev. 3. You are not expected to design, implement, test, or continuously monitor a standalone control to satisfy 03.08.06 specifically. Your operational obligation is to:

• Record the disposition of 03.08.06 as “Withdrawn” (or “Not Applicable – Withdrawn by standard”) in your SSP/control narrative. ¹
• Ensure your assessment approach reflects that status, so the assessor does not treat it as a missing requirement. Align your write-up to the assessment framing used for 800-171 assessments. ³
• Avoid inaccurate inheritance/mapping where a legacy control is still described as “03.08.06 compliant.”

Plain-English requirement meaning (what it really asks you to do)

For 03.08.06, the “requirement” is effectively: don’t implement it; document why you didn’t. Your compliance outcome is a clean control inventory and assessment package that shows you are following NIST SP 800-171 Rev. 3 as written. ¹

Who it applies to

Entity scope

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

Operational context

This matters most when you have one or more of the following:

• An SSP/control catalog originally written for an earlier revision or inherited from a parent organization.
• A tool-driven compliance program that expects every requirement ID to have a control statement and evidence uploaded.
• An upcoming assessment where an assessor will check requirement completeness against Rev. 3 and ask why a requirement has no control narrative. ³

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

1) Confirm the baseline and freeze the interpretation

• Confirm your program is scoped to NIST SP 800-171 Rev. 3 and that your requirement list includes 03.08.06 as withdrawn. Capture a screenshot/PDF excerpt of the requirement entry in your working papers. ¹
• If your contract, customer flow-down, or internal policy references a different revision, document the delta and get a decision from governance (security steering committee, CISO/CCO, or contract owner). Keep the decision record.

2) Update SSP control narratives and the control crosswalk

In your SSP, add an entry for 03.08.06 with:

• Status: Withdrawn ¹.
• Implementation: Not applicable; requirement withdrawn.
• Rationale: Cite that Rev. 3 marks it withdrawn and therefore no control implementation is required.
• Owner: Your GRC/control owner responsible for SSP accuracy (not an infrastructure engineer). ¹

In your crosswalk (800-171 to internal controls, ISO 27001, NIST 800-53, etc.):

• Remove any mapping that points legacy controls to 03.08.06.
• If a legacy control still exists for good security reasons, map it to the current requirement(s) it supports, not to 03.08.06.

3) Clean up POA&M and remediation trackers

• Search your POA&M and backlog for “03.08.06”.
• Close items that exist only to remediate 03.08.06, and document the closure reason as “Withdrawn requirement; no longer applicable under Rev. 3.”
• If the remediation is still valuable (for example, it fixes a real control weakness), re-home it under the correct active requirement(s) and keep the remediation work moving. ¹

4) Align assessment language to 800-171A expectations

Assessors commonly follow structured determination statements and look for clear “implemented/not implemented/not applicable” dispositions. For 03.08.06:

• Mark it as “Withdrawn” or “Not Applicable (Withdrawn).”
• Include a short assessor-facing note in your assessment package that the requirement is withdrawn in Rev. 3. ⁴

5) Put “withdrawn requirement hygiene” into your change process

Add a small governance control so this doesn’t recur:

• During framework updates, require a reconciliation step that identifies withdrawn/merged/renumbered requirements and updates SSP/POA&M accordingly.
• Assign ownership to GRC (process) plus system owners (mapping validation).

6) Make it auditable in your GRC tooling (Daydream-friendly)

In Daydream (or any GRC platform), treat 03.08.06 as a requirement record with:

• Disposition = Withdrawn
• Evidence = authoritative citation/excerpt, governance decision note, and crosswalk change log
• No recurring evidence tasks (because there is no control to operate) This prevents noisy exceptions and shows intentionality during reviews.

Required evidence and artifacts to retain

You are proving “withdrawn” was handled deliberately. Keep:

• SSP excerpt showing 03.08.06 disposition, rationale, and owner. ¹
• Control crosswalk change record (before/after or change ticket) removing 03.08.06 mappings.
• POA&M audit trail showing any 03.08.06 items closed or re-mapped with rationale.
• Assessment package note (or assessor memo) stating 03.08.06 is withdrawn under Rev. 3, aligned to your assessment method. ³
• Governance decision record if there was any ambiguity about revision applicability (meeting minutes, sign-off).

Common exam/audit questions and hangups

What an assessor asks	What they are really testing	Strong operator answer
“Why is 03.08.06 missing from your SSP?”	Completeness of requirement coverage	“It’s present and marked Withdrawn per Rev. 3; here is the SSP entry and citation.” 1
“Do you have controls that cover the intent of 03.08.06?”	Whether you dropped security practices unintentionally	“We evaluated legacy practices; anything still needed is mapped to active requirements. 03.08.06 is not an active requirement.”
“Show evidence for 03.08.06.”	Whether your evidence model is coherent	“No operational evidence applies because it is withdrawn; we retain documentation evidence: SSP disposition and crosswalk update.” 1
“Is your assessment method aligned to 800-171A?”	Assessment readiness	“Yes; our requirement dispositions include Withdrawn/Not Applicable with rationale, consistent with our assessment package.” 3

Frequent implementation mistakes (and how to avoid them)

1. Deleting the requirement entirely from the SSP

• Why it hurts: it looks like an omission.
• Fix: keep the record, mark it Withdrawn, and cite Rev. 3. ¹

2. Keeping a legacy control mapped to 03.08.06

• Why it hurts: you create an untestable “phantom requirement” and confuse traceability.
• Fix: remap the control to the correct active requirement(s) or to internal policy requirements.

3. Leaving POA&M items open against 03.08.06

• Why it hurts: it suggests you have an unresolved compliance gap for a requirement that does not exist in Rev. 3.
• Fix: close or re-home the work item with a documented rationale.

4. Treating “withdrawn” as permission to skip related security work

• Why it hurts: the underlying security objective may still be addressed elsewhere in Rev. 3, or in customer requirements.
• Fix: do a quick intent review of any legacy control you had, then map the security need to current controls rather than discarding it.

Enforcement context and risk implications

No public enforcement cases were provided for this specific requirement in the available source set. Operationally, the risk is assessment failure, contractual nonconformance, or credibility loss with a customer or prime when your SSP and evidence model look inconsistent with the revision you claim to follow. Your best defense is clean documentation, mapping hygiene, and an assessor-ready narrative grounded in Rev. 3 and assessed with 800-171A methods. ²

Practical execution plan (30/60/90)

You asked for speed, but the citation constraints mean we will keep this plan phase-based rather than time-quantified.

Immediate (triage and decision)

• Confirm you are using NIST SP 800-171 Rev. 3 in-scope and capture the withdrawn text for workpapers. ¹
• Locate every place 03.08.06 appears (SSP, crosswalks, POA&M, evidence library, tickets).
• Assign a single accountable owner for SSP updates and assessor communications.

Near-term (documentation and system cleanup)

• Update SSP entry for 03.08.06 to “Withdrawn,” with rationale and owner. ¹
• Remove/repair control mappings tied to 03.08.06; re-home any valid security practices to active requirements.
• Close or re-map POA&M items, with closure notes.

Ongoing (sustainment)

• Add a “framework change reconciliation” checklist step for future revisions: withdrawn/merged/renumbered handling, SSP updates, and POA&M hygiene.
• In Daydream, configure requirement disposition states so “Withdrawn” is a first-class status and does not generate recurring evidence tasks.

Frequently Asked Questions

If 03.08.06 is withdrawn, should I delete it from my control library?

Keep it as a record with a “Withdrawn” disposition so assessors see intentional coverage. Deleting it often creates the appearance of an incomplete SSP. ¹

Do I need to collect evidence for a withdrawn requirement?

You do not collect operational control evidence because there is no active control to test. Retain documentation evidence: SSP entry, mapping change log, and any governance decision note. ¹

What if our customer’s contract still references an older revision where 03.08.06 existed?

Treat that as a contractual requirement question, not a control-implementation guess. Document the revision conflict, seek written customer/contract guidance, and track it as a requirement interpretation decision in your SSP addendum or compliance memo.

Our assessors want every requirement to be “implemented/not implemented.” How do we handle “withdrawn”?

Add “Withdrawn/Not Applicable” as an allowed disposition in your assessment workbook and cite Rev. 3 for the rationale. Align your assessment package structure to NIST SP 800-171A so the disposition is reviewable. ⁴

We still perform a legacy security practice that used to map to 03.08.06. Do we stop?

Don’t stop just because the identifier was withdrawn. Re-evaluate the practice’s purpose and map it to the correct active requirement(s) or keep it as a local control tied to policy, risk, or customer commitments.

How should this appear in a POA&M?

You generally should not carry POA&M gaps tied to withdrawn requirements. Close items that only address 03.08.06, and re-map any still-relevant remediation to active requirements with clear traceability. ¹

Footnotes

1. NIST SP 800-171 Rev. 3

2. NIST SP 800-171 Rev. 3; Source: NIST SP 800-171A

3. NIST SP 800-171A

4. NIST SP 800-171A; Source: NIST SP 800-171 Rev. 3