03.08.08: Withdrawn

03.08.08 is a withdrawn requirement in NIST SP 800-171 Rev. 3, so you do not implement a standalone control for it. You still must operationalize it in your compliance program by recording the withdrawal, mapping it to “not applicable (withdrawn),” and retaining evidence that your scope, SSP, and assessment artifacts reflect the current revision. (NIST SP 800-171 Rev. 3)

Key takeaways:

• Treat 03.08.08: withdrawn requirement as a documentation and governance task, not a technical implementation task. (NIST SP 800-171 Rev. 3)
• Update your SSP/control matrix so assessors see a clear “Withdrawn per Rev. 3” disposition with traceable rationale. (NIST SP 800-171 Rev. 3)
• Keep clean evidence that your team tracks standard changes and prevents “phantom controls” from lingering in procedures and tooling. (NIST SP 800-171 Rev. 3)

A withdrawn control is a common exam trap. Teams either (a) keep implementing a requirement that no longer exists, or (b) delete it without leaving an audit trail, which creates confusion during assessments, customer inquiries, or internal control testing. For NIST SP 800-171 Rev. 3, 03.08.08 is explicitly marked “Withdrawn”. (NIST SP 800-171 Rev. 3)

For a Compliance Officer, CCO, or GRC lead, the job is not to guess what the requirement “used to mean.” Your job is to make sure your program artifacts reflect the current text, your scoping is consistent, and your assessors can follow your logic in a single pass. That means updating your control inventory, SSP narratives, any inherited mappings, and your evidence plan so nobody asks for implementation proof of a requirement that NIST removed.

This page gives you requirement-level, operator-ready guidance to close out 03.08.08: withdrawn requirement cleanly, prevent it from resurfacing in policies and tickets, and keep your NIST SP 800-171 Rev. 3 posture assessment-ready. (NIST SP 800-171 Rev. 3)

Regulatory text

Excerpt (framework text): “NIST SP 800-171 Rev. 3 requirement 03.08.08 (Withdrawn).” (NIST SP 800-171 Rev. 3)

Operator interpretation (what you must do)

Because NIST marks 03.08.08 as Withdrawn, there is no control objective to implement and no technical/administrative safeguard to test under that identifier. Your obligation is governance-based:

• Do not claim implementation of 03.08.08 as if it were an active requirement.
• Do not leave gaps in your control catalog that make assessors suspect missing coverage.
• Document the withdrawal in your SSP/control matrix with a clear disposition and citation to Rev. 3. (NIST SP 800-171 Rev. 3)

If you are supporting a customer, prime contractor, or assessor, your artifacts must make it obvious that you are aligned to the current revision and that the requirement is intentionally not implemented because it no longer exists. (NIST SP 800-171 Rev. 3)

Plain-English interpretation of the requirement

03.08.08: withdrawn requirement means: “This requirement is not in force in Rev. 3, so we will not build or test a control for it; we will maintain proof that we tracked the change and updated our compliance mapping accordingly.” (NIST SP 800-171 Rev. 3)

Withdrawn does not mean:

• “Ignore the whole control family.”
• “Delete anything related without review.”
• “Assume your environment is compliant by default.”

It means your compliance system should treat it as a controlled exception state: withdrawn per the authoritative framework text. (NIST SP 800-171 Rev. 3)

Who it applies to (entity and operational context)

This guidance applies to organizations that align to NIST SP 800-171 Rev. 3 for protecting Controlled Unclassified Information (CUI) in nonfederal systems, including:

• Federal contractors and subcontractors handling CUI.
• Nonfederal organizations operating information systems that store, process, or transmit CUI and are required by contract or flowdown to meet NIST SP 800-171. (NIST SP 800-171 Rev. 3)

Operationally, this is owned by:

• GRC / Compliance (control catalog, SSP, assessment readiness).
• Security leadership (ensuring old tickets or tools aren’t chasing obsolete requirements).
• Internal audit / assurance (testing plans and evidence requests).
• Procurement / third-party risk when flowdowns or supplier scorecards reference old control IDs.

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

1) Confirm your baseline and freeze the “withdrawn” decision

• Confirm you are operating against NIST SP 800-171 Rev. 3 as your stated baseline in policy, SSP, or contractual commitments. (NIST SP 800-171 Rev. 3)
• Record a formal control disposition for 03.08.08: “Withdrawn (Rev. 3)” with the framework citation. (NIST SP 800-171 Rev. 3)

Deliverable: a one-line entry in your control matrix that an assessor can accept without follow-up.

2) Update your control catalog and mappings (SSP, crosswalks, tool configs)

Where 03.08.08 commonly appears:

• SSP control tables and narratives
• Control-to-policy mapping sheets
• Crosswalks to other frameworks (internal mappings, customer mappings)
• GRC tool control libraries and test procedures
• POA&M templates that still list legacy items

Action:

• Set the status to Withdrawn (or “Not Applicable – Withdrawn”) and link the rationale to the Rev. 3 text. (NIST SP 800-171 Rev. 3)
• Remove any test steps that attempt to validate implementation of 03.08.08.
• Keep the identifier present (do not delete it silently) so your numbering and traceability remain intact.

3) Search-and-clean operational content to prevent “phantom controls”

Run a targeted search for “03.08.08” across:

• Policies and standards
• Procedures / runbooks
• Evidence checklists
• Audit request lists
• Training materials
• Third-party questionnaires and templates

Action:

• Replace references with either (a) the correct current requirement (if your content meant something else), or (b) a note that it is Withdrawn per Rev. 3. (NIST SP 800-171 Rev. 3)

One common mistake is leaving a procedure step that cites the withdrawn ID even after you mark the control withdrawn in the SSP. Auditors notice inconsistencies faster than teams expect.

4) Reconcile contractual and customer-driven requirements

Even if NIST withdrew the control, a customer or prime may still ask about it because they:

• use older templates,
• haven’t updated their scorecards,
• or are mixing revisions across suppliers.

Action:

• Prepare a standard response: “03.08.08 is withdrawn in NIST SP 800-171 Rev. 3; we track it as withdrawn in our SSP/control matrix.” (NIST SP 800-171 Rev. 3)
• If the customer contract explicitly references a different revision, escalate internally and treat it as a contract interpretation/scoping issue, not a security control gap.

5) Add “withdrawn requirements” to your change management cadence

Treat this as a control governance pattern:

• Track withdrawn items in a revision log (what changed, when you updated artifacts, who approved).
• Ensure future updates don’t reintroduce the requirement through copied templates.

If you use Daydream, this is where it helps: set 03.08.08 to a “Withdrawn” state in your requirement library, attach the Rev. 3 citation, and schedule recurring evidence that your SSP/control matrix stays aligned through annual reviews. (NIST SP 800-171 Rev. 3)

Required evidence and artifacts to retain

Keep evidence that demonstrates both correct interpretation and program hygiene:

1. Control matrix / control inventory entry

• 03.08.08 disposition: “Withdrawn (Rev. 3)”
• Rationale field referencing the framework excerpt. (NIST SP 800-171 Rev. 3)

2. SSP excerpt or SSP revision history

• Shows 03.08.08 is withdrawn and not implemented
• Shows review/approval metadata (change ticket, approver, date)

3. Mapping/crosswalk artifacts

• Any crosswalks to internal policies or other frameworks updated to prevent dangling references

4. Search-and-remediation proof

• A change ticket, PR, or document history showing old references were removed or annotated

5. Assessment readiness package

• “Withdrawn requirements list” or appendix that an assessor can scan quickly

Common exam/audit questions and hangups

Expect these questions and prepare crisp answers:

• “Where is the evidence for 03.08.08?”
  Answer: “It is withdrawn in Rev. 3; our SSP marks it withdrawn and we retain the citation and change record.” (NIST SP 800-171 Rev. 3)

• “Why is it missing from your control list?”
  Hangup: Deleting the row makes it look like you missed a requirement. Keep it listed with a withdrawn status.

• “Which control replaced it?”
  If you don’t have an authoritative mapping, don’t guess. State it is withdrawn and point to your current baseline. (NIST SP 800-171 Rev. 3)

• “How do you manage standard updates?”
  Show your revision log, governance cadence, and approval trail for SSP/control library updates.

Frequent implementation mistakes and how to avoid them

Mistake	Why it hurts	How to avoid it
Silently deleting 03.08.08 from the SSP/control list	Creates numbering gaps and triggers assessor suspicion	Keep the identifier with status “Withdrawn (Rev. 3)” and rationale (NIST SP 800-171 Rev. 3)
Implementing a “best guess” control	Wastes effort and can create contradictory procedures	Do not implement withdrawn items; focus on active requirements (NIST SP 800-171 Rev. 3)
Leaving references in procedures and evidence checklists	Audits find inconsistencies and stale controls	Run a targeted search and clean/annotate every reference
Letting customers enforce old templates	Drives churn and false findings	Use a standard response, escalate contract revision mismatches

Enforcement context and risk implications

No public enforcement cases were provided for this specific requirement in the source catalog. Your practical risk is assessment friction and contractual disputes, not direct enforcement tied to 03.08.08 itself.

Where teams get hurt:

• An assessor flags “missing control” because the withdrawn status is undocumented.
• A prime contractor scorecard marks you noncompliant because their template is outdated.
• Internal audit reports a finding because evidence requests still reference 03.08.08.

Treat the control as a documentation quality gate: if you can’t show you tracked a withdrawn requirement, assessors may question whether you track more meaningful changes. (NIST SP 800-171 Rev. 3)

Practical 30/60/90-day execution plan

First 30 days (stabilize the record)

• Set 03.08.08 status to Withdrawn (Rev. 3) in your control inventory and SSP. (NIST SP 800-171 Rev. 3)
• Create a change ticket with approval and attach the excerpt citation. (NIST SP 800-171 Rev. 3)
• Remove or annotate 03.08.08 references in procedures, evidence checklists, and audit request templates.

By 60 days (eliminate recurrence)

• Update crosswalks and customer/third-party questionnaires so they don’t ask for 03.08.08 evidence.
• Add a “withdrawn requirements” line item to your annual SSP review checklist.
• Train control owners and internal audit on how withdrawn items are represented in artifacts.

By 90 days (assessment-ready hardening)

• Run a tabletop “assessor walk-through” of your SSP section covering withdrawn items.
• Validate that your GRC tool, testing scripts, and POA&M templates don’t generate tasks for 03.08.08.
• Package a short assessor memo: baseline version, withdrawn list, and how you govern revisions. (NIST SP 800-171 Rev. 3)

Frequently Asked Questions

What does “03.08.08: withdrawn requirement” mean for my compliance scope?

It means there is no active Rev. 3 requirement to implement under that identifier. Your scope task is to record it as withdrawn in your SSP/control matrix with the Rev. 3 citation. (NIST SP 800-171 Rev. 3)

Should I remove 03.08.08 from my SSP entirely?

Don’t remove it silently. Keep the row and mark it “Withdrawn (Rev. 3)” so assessors can reconcile numbering and see intentional disposition. (NIST SP 800-171 Rev. 3)

Do I need evidence for a withdrawn requirement?

You don’t need technical evidence of implementation. You do need governance evidence: the SSP/control inventory entry, the rationale citing Rev. 3, and the change record showing you updated artifacts. (NIST SP 800-171 Rev. 3)

A customer questionnaire still asks how we meet 03.08.08. What do I answer?

Respond that 03.08.08 is withdrawn in NIST SP 800-171 Rev. 3 and provide your SSP excerpt or control matrix entry showing the withdrawn status. Escalate if the contract mandates a different revision. (NIST SP 800-171 Rev. 3)

What if our internal policies still reference 03.08.08?

Treat it as a documentation defect. Update the policy/procedure reference to the correct current control (if applicable) or annotate that the requirement is withdrawn per Rev. 3. (NIST SP 800-171 Rev. 3)

How should a GRC tool represent withdrawn requirements?

Keep the requirement in the library with a “Withdrawn” status, disable testing/evidence tasks tied to it, and link the authoritative citation. This preserves traceability and prevents “phantom” audit requests. (NIST SP 800-171 Rev. 3)