03.10.03: Withdrawn

A withdrawn control creates a specific kind of compliance failure: teams either keep implementing an obsolete requirement (wasting time and generating irrelevant evidence) or remove it without documenting why (creating a traceability gap in the SSP and control crosswalk). For a Compliance Officer, CCO, or GRC lead working under NIST SP 800-171 obligations for CUI, the operational goal is straightforward: your program must reflect Rev. 3 as written, and your documentation must show that you recognized 03.10.03 is withdrawn and handled it deliberately. (NIST SP 800-171 Rev. 3)

This page focuses on fast execution. You will (1) confirm where 03.10.03 appears in your current artifacts, (2) retire references cleanly, (3) map to the correct current requirements (or note “no replacement” where appropriate), and (4) tune evidence collection so assessors see a consistent, Rev. 3-aligned story. The highest-value output is a clean requirements traceability matrix and SSP entry that prevents assessor confusion and stops internal teams from chasing a requirement that no longer exists. (NIST SP 800-171 Rev. 3)

Target keyword: 03.10.03: withdrawn requirement

Regulatory text

Excerpt (as provided): “NIST SP 800-171 Rev. 3 requirement 03.10.03 (Withdrawn).” (NIST SP 800-171 Rev. 3)

What the operator must do

Because the requirement is explicitly withdrawn, your operational obligation is program accuracy and traceability, not implementing a specific security mechanism tied uniquely to 03.10.03. In practice, that means:

• Your SSP and control catalog should not claim a control is “implemented” to satisfy 03.10.03 as if it were active. (NIST SP 800-171 Rev. 3)
• Your requirements mapping should explicitly label 03.10.03 as withdrawn and show how your organization handled it (removed, mapped to another requirement, or marked “not applicable because withdrawn”). (NIST SP 800-171 Rev. 3)
• Your evidence plan should avoid collecting artifacts for a withdrawn requirement and instead align evidence to the current active requirements. (NIST SP 800-171 Rev. 3)

Plain-English interpretation (what this really means)

“Withdrawn” means NIST SP 800-171 Rev. 3 no longer expects organizations to meet a separate requirement numbered 03.10.03. The compliance task becomes: keep your program current, avoid obsolete obligations, and maintain defensible documentation that shows you are aligned to Rev. 3’s actual requirements set. (NIST SP 800-171 Rev. 3)

If you are assessed (internally, by a customer, or as part of a contract-driven review), auditors commonly test whether your SSP and traceability are coherent. A withdrawn requirement is a common place where incoherence shows up: spreadsheets still list it, policies still cite it, and evidence folders still have stale screenshots. Your job is to remove those inconsistencies in a controlled, reviewable way. (NIST SP 800-171 Rev. 3)

Who it applies to (entity + operational context)

This affects any organization that:

• Uses NIST SP 800-171 Rev. 3 as the basis for its CUI protection program, especially nonfederal systems handling CUI and federal contractors operating under flow-down requirements. (NIST SP 800-171 Rev. 3)

Operationally, it applies to:

• GRC/Compliance teams maintaining the SSP, control matrix, POA&M, and policy set.
• Security teams asked to “implement controls” based on outdated mappings.
• Internal audit and external assessors who reconcile your requirement inventory to Rev. 3 text. (NIST SP 800-171 Rev. 3)

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

Step 1: Find every place 03.10.03 appears

Search across:

• SSP requirement narratives and control implementation statements
• Control matrices / requirement crosswalks
• Policies and procedures (especially if they cite requirement numbers)
• Evidence registers, audit folders, ticket templates, and recurring tasks
• Customer security questionnaires where you mapped answers to 03.10.03

Output: A short “03.10.03 touchpoints list” with artifact name, location, owner, and proposed action (remove / update / map). (NIST SP 800-171 Rev. 3)

Step 2: Decide the correct treatment (withdrawn ≠ ignore)

Use this decision logic:

Scenario	Correct treatment	What to document
Your matrix lists 03.10.03 as active	Remove as an active requirement	“Withdrawn in Rev. 3; no standalone implementation required.” (NIST SP 800-171 Rev. 3)
Your policies cite 03.10.03	Update citations	Replace with the correct active requirement reference(s), or remove the numeric citation if not needed. (NIST SP 800-171 Rev. 3)
You created a control solely to satisfy 03.10.03	Re-evaluate necessity	Keep it if it supports other active requirements; otherwise retire it via change control.
You collect recurring evidence “for 03.10.03”	Re-map evidence	Map each artifact to the active requirement(s) it supports, or stop collecting it.

Step 3: Update the SSP and requirement crosswalk

Make the SSP assessor-friendly:

• In the requirements table/crosswalk, include an entry for 03.10.03 with status Withdrawn and a short rationale. (NIST SP 800-171 Rev. 3)
• Remove any “Implemented/Planned” language tied only to 03.10.03.
• If your SSP format forces a response, use consistent language such as: “Withdrawn in NIST SP 800-171 Rev. 3; no implementation statement required beyond documentation of withdrawal.” (NIST SP 800-171 Rev. 3)

Step 4: Clean up control ownership and evidence routines

Most teams have recurring evidence collection (monthly access reviews, quarterly vulnerability summaries, incident tabletop records). If any of those tasks reference 03.10.03:

• Update the task description to reference the active requirement(s) it supports.
• Update evidence naming conventions so auditors do not see “03.10.03” in filenames/folders.
• Re-train control owners briefly: “03.10.03 is withdrawn; stop tagging work to it.” (NIST SP 800-171 Rev. 3)

Step 5: Record the change like an auditor would expect

Treat this as controlled documentation maintenance:

• Create a change ticket or memo that logs what changed, why, who approved it, and the effective date.
• Keep before/after snapshots for key governance artifacts (SSP crosswalk, control matrix).
  This closes the gap where an assessor asks, “Why is this requirement missing from your matrix?” and you can answer with a clean, referenced decision record. (NIST SP 800-171 Rev. 3)

Step 6: Add a standing control: “Withdrawn requirement governance”

To prevent recurrence:

• Add a small governance procedure: “Monitor NIST SP 800-171 revisions and update mappings; label withdrawn requirements explicitly.”
• Bake it into your annual policy review or compliance calendar so withdrawn items do not drift back into scope.

Daydream (as a practical workflow) fits naturally here because it can track requirement status, map requirements to controls, and manage recurring evidence requests so withdrawn requirements stop generating busywork and audit noise.

Required evidence and artifacts to retain

You are proving correct handling, not technical implementation. Retain:

1. Requirements mapping / control matrix showing 03.10.03 marked as withdrawn and not treated as an active requirement. (NIST SP 800-171 Rev. 3)
2. SSP excerpt(s) where the withdrawn status is documented consistently. (NIST SP 800-171 Rev. 3)
3. Change record (ticket, memo, or CAB minutes) documenting the update and approvals.
4. Policy/procedure redlines or revision history if you removed/updated citations to 03.10.03.
5. Evidence register update showing that evidence collection is mapped to active requirements, not 03.10.03.

Common exam/audit questions and hangups

Expect these questions and have short, consistent answers:

• “Why isn’t 03.10.03 implemented?”
  “It is withdrawn in NIST SP 800-171 Rev. 3; we document withdrawal and map our controls to the active requirements.” (NIST SP 800-171 Rev. 3)

• “Where is 03.10.03 in your SSP?”
  Show the crosswalk entry labeled “Withdrawn,” plus the change record. (NIST SP 800-171 Rev. 3)

• “You referenced 03.10.03 in Policy X last year. Why did it change?”
  Provide revision history and the governance decision record.

• “Do any controls depend on 03.10.03?”
  Your answer should be: “Controls are mapped to active requirements; any inherited practice remains because it supports [active requirement(s)], not because of 03.10.03.”

Frequent implementation mistakes (and how to avoid them)

Mistake 1: Leaving 03.10.03 in the control matrix as “N/A”

Why it fails: “N/A” looks like scoping judgment, not a standards change.
Fix: Use “Withdrawn (Rev. 3)” explicitly and keep a one-line rationale. (NIST SP 800-171 Rev. 3)

Mistake 2: Collecting evidence for a withdrawn requirement

Why it fails: It signals your program is not aligned to the current framework, and it wastes operator time.
Fix: Re-map evidence to active requirements and update folder structures and ticket templates.

Mistake 3: Retiring a control with no impact analysis

Why it fails: A control originally built for 03.10.03 might now support other requirements, customer commitments, or internal risk appetite.
Fix: Perform a quick dependency check: where else is the control referenced (SSP, policies, customer commitments), then decide keep/retire.

Mistake 4: Updating the SSP but not the policy set (or vice versa)

Why it fails: Auditors compare artifacts. Inconsistency is what they write up.
Fix: Run the same “find all references” search across SSP, policies, and evidence plans.

Risk implications and enforcement context

No public enforcement cases were provided in the source catalog for this specific requirement, and NIST SP 800-171 itself is a standard used to satisfy contractual and program requirements rather than a standalone enforcement statute. (NIST SP 800-171 Rev. 3)

Your real risk is downstream:

• Assessment risk: assessors question the reliability of your mapping if they see withdrawn requirements treated as active.
• Contractual risk: customers may treat inaccurate SSPs or control representations as a performance issue.
• Operational risk: teams waste time building artifacts for requirements that no longer exist, while missing gaps in active requirements.

Practical 30/60/90-day execution plan

First 30 days (stabilize and stop churn)

• Inventory every reference to 03.10.03: withdrawn requirement across SSP, matrices, policies, procedures, and evidence trackers.
• Update the requirement crosswalk and SSP entry to explicitly label “Withdrawn” with a short rationale. (NIST SP 800-171 Rev. 3)
• Freeze new work items tagged to 03.10.03; redirect owners to active requirement mappings.

Days 31–60 (align the operating system)

• Re-map recurring evidence tasks so nothing is generated “for 03.10.03.”
• Update policy citations and templates; publish revised versions with tracked revision history.
• Train control owners and internal audit on the new mapping so questionnaires and interviews stay consistent.

Days 61–90 (make it durable)

• Add a light governance control: periodic standards mapping review that catches withdrawn/renumbered requirements before audits.
• Run an internal “mini-assessment” walk-through: pick a sample of controls and confirm no evidence folders or tickets still reference 03.10.03.
• If you use Daydream or another GRC system, encode the withdrawn status in the requirement library so it cannot be assigned evidence requests going forward.

Frequently Asked Questions

If 03.10.03 is withdrawn, can I delete it from my SSP entirely?

Usually you should keep a placeholder row or note that explicitly says “Withdrawn” to prevent confusion during reviews. The goal is traceability to NIST SP 800-171 Rev. 3, not pretending the requirement never existed. (NIST SP 800-171 Rev. 3)

Do I need compensating controls for a withdrawn requirement?

No compensating control is required solely because it is withdrawn. If you remove a practice that also supports active requirements, document the impact analysis and maintain coverage elsewhere.

Auditors keep asking what replaced 03.10.03. What should I say?

Start with the fact pattern: it is marked withdrawn in NIST SP 800-171 Rev. 3. If your internal mapping shows related active requirements, show that crosswalk; otherwise document “no direct replacement identified” and keep your mapping consistent. (NIST SP 800-171 Rev. 3)

We already built a procedure around 03.10.03. Should we retire it?

Only retire it after you confirm it does not support any other active NIST SP 800-171 Rev. 3 requirements, contractual commitments, or internal risk decisions. If it still provides value, keep the procedure and re-map it to the correct active requirements.

How do I prevent withdrawn requirements from reappearing in questionnaires and spreadsheets?

Control your “system of record” for requirements mapping and require teams to pull requirement IDs from there. If you use Daydream, set 03.10.03 to “Withdrawn” so it cannot be selected for evidence or control mapping.

What’s the minimum evidence I should keep to prove I handled this correctly?

Keep the updated SSP/crosswalk entry showing “Withdrawn,” plus a change record showing when and why you updated your mapping. That pair answers most assessor follow-ups. (NIST SP 800-171 Rev. 3)