03.10.03: Withdrawn

NIST SP 800-171 Rev. 3 requirement 03.10.03 is withdrawn, so you do not implement a standalone control for it. You still need to operationalize the outcome by (1) documenting “Withdrawn” in your SSP/control mapping, (2) confirming any legacy implementation is covered by other active requirements, and (3) retaining evidence that the withdrawal was assessed and governance remains intact. ¹

Key takeaways:

• Treat 03.10.03 as a documentation and scoping decision, not a technical implementation project. ¹
• Auditors will still expect SSP traceability, ownership, and evidence showing you handled the withdrawal intentionally. ¹
• If you previously implemented a “03.10.03” control, re-home it under the correct active requirement(s) and close the loop in your POA&M. ²

A “withdrawn” NIST SP 800-171 requirement creates a predictable governance problem: teams either ignore it completely (and then can’t explain the gap during an assessment) or keep building controls against a requirement that no longer exists (and then can’t defend why time and scope were spent there). Requirement 03.10.03 falls squarely into that category: the text is explicitly marked withdrawn, so you are not expected to implement it as written. ¹

For a Compliance Officer, CCO, or GRC lead, the operational task is to make the withdrawal auditable. That means your System Security Plan (SSP), control inventory, assessment procedures, and Plan of Action & Milestones (POA&M) must show: (1) you identified that 03.10.03 is withdrawn, (2) you confirmed whether any legacy control intent is already satisfied by other active requirements, and (3) you maintained clear ownership and evidence for whatever safeguards remain in your environment. ¹

This page gives requirement-level implementation guidance for handling “Withdrawn” correctly, with concrete steps, artifacts to retain, and the exam questions you should be ready to answer using NIST SP 800-171 Rev. 3 and NIST SP 800-171A. ^{1 2}

Regulatory text

Excerpt / requirement label: “NIST SP 800-171 Rev. 3 requirement 03.10.03 (Withdrawn).” ¹

Plain-English interpretation (what this means operationally)

• There is no current control requirement to implement for 03.10.03. “Withdrawn” means the requirement has been removed from the set and is not assessable as a standalone item in Rev. 3. ¹
• Your obligation shifts to governance and traceability. You must show your program noticed the withdrawal and handled it intentionally in your SSP, assessment approach, and POA&M hygiene. ¹
• Any real security objective previously associated with 03.10.03 still matters if it is captured elsewhere. Your job is to confirm whether legacy controls are now mapped to other active 800-171 Rev. 3 requirements or are out of scope and can be retired. ¹

Who it applies to (entity and operational context)

This guidance applies when you are using NIST SP 800-171 Rev. 3 as your compliance baseline, typically for:

• Federal contractors and subcontractors handling Controlled Unclassified Information (CUI) in nonfederal systems. ¹
• Any nonfederal organization that has contract, flow-down, or customer obligations requiring alignment to NIST SP 800-171 Rev. 3. ¹

Operationally, you will touch multiple teams because “withdrawn” impacts documentation and assessment scope:

• GRC/Compliance (SSP, control mapping, POA&M governance)
• System owners (system boundary and inheritance decisions)
• Security operations (evidence production and continuous monitoring outputs)
• Internal audit or assessment teams using NIST SP 800-171A-style objectives ²

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

Your goal is to make “Withdrawn” clean, explicit, and defensible.

Step 1: Record the requirement status in your control universe

1. In your control library/control register, create an entry for 03.10.03 with status Withdrawn (Rev. 3). ¹
2. Add a short rationale field: “Withdrawn in NIST SP 800-171 Rev. 3; not implemented as standalone requirement.” ¹
3. Assign an accountable owner (usually GRC) for maintaining the mapping decision and evidence trail. ¹

Why this matters: Assessors often reconcile your SSP/control list to the baseline. A missing identifier without explanation reads like an omission; a “Withdrawn” annotation reads like governance. ¹

Step 2: Update the SSP with an explicit “Withdrawn” handling statement

1. In the SSP control implementation section, list 03.10.03 and mark it Withdrawn. ¹
2. Add a short statement covering:
   • No implementation required for Rev. 3
   • If legacy safeguards exist, where they are mapped now (control IDs / other requirement numbers) ¹
3. Confirm system boundary: note whether any inherited controls or common controls are relevant, even if the original requirement is withdrawn. ¹

Step 3: Perform a “legacy control intent” check (don’t guess)

Even though 03.10.03 is withdrawn, your environment may still include procedures or tooling built for it (from older mappings, templates, or consultants).

1. Search your governance repository for “03.10.03” and related narrative:
   • SSP prior versions
   • Policies/standards
   • Control test scripts
   • GRC tickets and POA&M items
2. For each finding, decide one of three dispositions:
   • Re-map: The safeguard supports an active Rev. 3 requirement; re-map it there.
   • Retain as good practice: Keep it as an internal control (non-baseline) with an owner and evidence expectations.
   • Retire: It’s redundant or irrelevant; formally decommission it with approval and record retention. ¹

Step 4: Align your assessment approach (NIST SP 800-171A)

1. In your assessment plan or test workbook, mark 03.10.03 as Not Applicable – Withdrawn with a reference to the Rev. 3 status. ¹
2. Ensure no test steps remain that try to “score” or “pass/fail” 03.10.03 as if it were active.
3. If your assessor expects traceability, include a short crosswalk note: “Withdrawn; any relevant safeguards tested under [active requirement IDs]” and list those IDs if known. ²

Step 5: Clean up POA&M items tied to 03.10.03

1. Identify POA&M entries referencing 03.10.03.
2. For each entry:
   • If work is still needed for security, reassign the POA&M item to the correct active requirement(s).
   • If the item exists only to satisfy 03.10.03, close it as “Requirement withdrawn” with closure approval.
3. Document closure validation: who approved, what evidence supports closure, and where the residual risk (if any) is tracked. ¹

Step 6: Set evidence expectations anyway (because auditors will ask)

Even for a withdrawn requirement, assessors ask “show me” questions about your governance process. Build a small evidence packet:

• SSP snippet showing “Withdrawn”
• Crosswalk/mapping memo
• POA&M clean-up record
• Assessment plan notation ²

Required evidence and artifacts to retain

Use an “audit packet” mindset. You want a reviewer to validate your decision in minutes.

Artifact	What it should show	Owner
SSP control entry for 03.10.03	Marked “Withdrawn” with a short rationale and any re-mapping notes	GRC / System Owner 1
Control mapping / crosswalk note	Where legacy safeguards moved (if applicable) and why	GRC 1
POA&M update log	Items closed or reassigned; approvals and closure validation	GRC 1
Assessment plan/test workbook note	“Not Applicable – Withdrawn” and references	Assessment lead 2
Change record (ticket/minutes)	Decision history, participants, effective date	GRC 1

Practical tip: If you run Daydream, store these artifacts as a single control “evidence bundle” tied to the SSP entry, so the withdrawal decision and the supporting records travel together during reviews.

Common exam/audit questions and hangups

Expect these questions from internal audit, customers, or third-party assessors:

1. “Why is 03.10.03 missing from your SSP?”
   Fix: Don’t omit it. Include it and label it “Withdrawn.” ¹

2. “Show me where the control objective went.”
   Fix: Provide a crosswalk note: “Withdrawn; legacy safeguards mapped to [X/Y]” or “No longer required; retained as internal control.” ¹

3. “Do you still run a process/tool that used to satisfy 03.10.03?”
   Fix: Have the disposition list and ownership ready, including retirement approvals if you removed anything. ¹

4. “How did you ensure assessment completeness under 800-171A?”
   Fix: Show your test plan marks it “Not Applicable – Withdrawn,” and that relevant safeguards are tested elsewhere. ²

Frequent implementation mistakes and how to avoid them

Mistake 1: Dropping the requirement ID entirely

Why it fails: It looks like an SSP gap.
Avoid it: Keep the row, mark it “Withdrawn,” and add the rationale. ¹

Mistake 2: Treating “Withdrawn” as “we don’t need documentation”

Why it fails: Assessments depend on traceability and current documentation for CUI environments. ¹
Avoid it: Retain a lightweight evidence packet and a governance decision record.

Mistake 3: Leaving orphaned POA&M items

Why it fails: It signals weak remediation governance and undermines your closure discipline. ¹
Avoid it: Re-map or close, then document closure validation.

Mistake 4: Continuing to test it as if it were active

Why it fails: You waste assessment time and can confuse customers who expect Rev. 3 alignment. ¹
Avoid it: Update your assessment scripts to reflect the withdrawn status, referencing NIST SP 800-171A testing structure. ²

Risk implications (what can go wrong)

A withdrawn requirement rarely creates direct technical risk; it creates assurance risk:

• Scope confusion: Teams implement controls against non-requirements while missing active ones.
• Assessment friction: Reviewers spend time reconciling inconsistencies between SSP, POA&M, and test plans.
• Change control weaknesses: If your program can’t explain a withdrawn control cleanly, customers question whether you track changes to the baseline at all. ¹

Practical execution plan (30/60/90-day)

You asked for speed. This is the path that reduces audit friction quickly without inventing timelines tied to external sources.

First 30 days (stabilize documentation and scope)

• Update SSP: add 03.10.03 entry marked “Withdrawn,” with owner and rationale. ¹
• Update control library/control register with the same status.
• Sweep repositories for “03.10.03” references; compile a disposition list.
• Freeze any new engineering work tied only to “03.10.03” until re-mapped.

Days 31–60 (re-map legacy safeguards and clean POA&M)

• Re-map any legacy “03.10.03” safeguards to active requirements where applicable; record mapping notes. ¹
• Close or reassign POA&M items; capture approval and closure validation. ¹
• Update assessment plan/test workbook to “Not Applicable – Withdrawn.” ²

Days 61–90 (harden the evidence trail and keep it current)

• Package “withdrawn requirement evidence bundle” in your GRC system (SSP snippet, crosswalk memo, POA&M actions, assessment note).
• Add a baseline-change checklist item: “Identify withdrawn/added requirements; update SSP/control mapping and assessment scripts.”
• Run a tabletop review with the system owner and assessor lead: “If a customer asks, can we explain this in five minutes with artifacts?”

Frequently Asked Questions

If 03.10.03 is withdrawn, can an assessor still fail us for it?

They should not assess it as a standalone Rev. 3 requirement because it is explicitly withdrawn. They can still flag weak governance if your SSP and assessment materials don’t reflect the withdrawal cleanly. ¹

Should we remove controls we built for 03.10.03 in earlier programs?

Only after you determine whether those safeguards support other active requirements or internal risk decisions. Retire controls through change management, with an approval record and an updated SSP mapping. ¹

How do we document “Withdrawn” in the SSP without creating confusion?

Keep the requirement listed, mark it “Withdrawn,” and add a one-paragraph rationale plus any re-mapping references. That gives reviewers a clear reconciliation path. ¹

What evidence is “enough” for a withdrawn requirement?

A minimal packet: SSP entry, mapping note, assessment plan notation, and POA&M clean-up record (if applicable). The standard is clarity and traceability, not volume. ¹

Do we need to update our NIST SP 800-171A assessment procedures for withdrawn items?

Yes. Mark the item “Not Applicable – Withdrawn” in your test plan so your assessment scope matches Rev. 3 and you don’t run obsolete procedures. ²

How can Daydream help with a withdrawn requirement?

Use Daydream to keep the SSP statement, ownership, mapping decision, and the supporting evidence bundle attached to the requirement entry. That reduces back-and-forth during customer reviews and assessments because the rationale and artifacts stay in one place.

Footnotes

1. NIST SP 800-171 Rev. 3

2. NIST SP 800-171A