03.10.04: Withdrawn

A withdrawn control causes a specific kind of assessment failure: not a failed safeguard, but a traceability failure. Teams often carry forward spreadsheets, SSP control statements, and control test scripts from older mappings. If 03.10.04 appears as “not implemented,” “planned,” or “N/A” without explanation, an assessor can read it as confusion about the baseline rather than an intentional stance.

NIST SP 800-171 Rev. 3 marks 03.10.04 as withdrawn. That single word changes your job from engineering to governance: you must ensure your compliance system (SSP, POA&M, control library, evidence plan, and internal test approach) reflects that this item is no longer a requirement. ¹

This page gives requirement-level implementation guidance for a CCO, compliance officer, or GRC lead who needs to operationalize the withdrawn status quickly, keep documentation clean, and avoid self-inflicted findings during a CUI-focused assessment. It prioritizes what to change, who must sign off, and what artifacts to retain.

Regulatory text

Excerpt / status: “NIST SP 800-171 Rev. 3 requirement 03.10.04 (Withdrawn).” ¹

What an operator must do with a withdrawn requirement

Because the requirement is withdrawn, there is no control objective to implement or test for 03.10.04. Your operational obligation is to:

1. Record that it is withdrawn in your compliance mapping,
2. Remove it from any “must implement” or “gap” views, and
3. Show assessors a clean trace from the Rev. 3 requirement set to your SSP/POA&M so the absence of implementation evidence is expected and explained. ¹

A practical way to phrase it in your SSP/control catalog:

• “03.10.04 is withdrawn in NIST SP 800-171 Rev. 3; no standalone implementation required. Mapping retained for traceability.” ¹

Plain-English interpretation (what this means)

The 03.10.04: withdrawn requirement means you should not spend time building a technical or procedural control specifically to satisfy 03.10.04. Instead, you must ensure your program does not accidentally treat it as an unmet obligation.

In practice, “withdrawn” usually creates three real risks:

• Mapping drift: old control matrices still reference 03.10.04 and flag it as missing.
• Evidence debt: teams try to collect logs or screenshots for a control that no longer exists.
• Assessment confusion: assessors lose confidence in your baseline selection and traceability across SSP and POA&M. ¹

Who it applies to

Entity scope

This applies to:

• Federal contractors and
• Nonfederal organizations operating systems that handle CUI,
  when they are aligning their security program to NIST SP 800-171 Rev. 3. ¹

Operational context (where it shows up)

You will touch this requirement status when you manage:

• SSP requirement-to-control mapping and scoping statements
• POA&M creation rules (what becomes a gap vs. what is excluded)
• Control test procedures and internal assessment checklists
• Third-party/inherited controls where a provider’s attestation includes legacy references
• Tooling (GRC platforms, spreadsheets, ticketing) that auto-generates “open items”

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

Step 1: Confirm baseline and version control

• Confirm the organization is mapping against NIST SP 800-171 Rev. 3 for the in-scope system(s). ¹
• Identify every location where requirements are listed: SSP annexes, control library, internal audit checklist, customer flow-down matrix, and any third-party security exhibits.

Operator tip: Make one “source of truth” table that includes requirement ID, status (implemented / planned / N/A / withdrawn), and a short rationale.

Step 2: Update requirement traceability

• In your mapping, set 03.10.04 status to Withdrawn.
• Add a rationale field: “Withdrawn in NIST SP 800-171 Rev. 3.”
• Link the mapping entry to your SSP section that defines how you treat withdrawn items.

This aligns with the core execution expectation: map requirements to SSP control statements, owners, and system components, even when the mapping results in “withdrawn.” ¹

Step 3: Check for “ghost dependencies”

Withdrawn does not mean “ignore everything around it.” It means “don’t implement this specific requirement.” Do a targeted review to ensure:

• No internal control statement references 03.10.04 as authority text.
• No testing procedure includes a 03.10.04 test step.
• No POA&M item was opened solely to address 03.10.04.

If you find a POA&M item tied only to 03.10.04, close it with documented justification and closure approval.

Step 4: Clean up SSP and POA&M presentation

Update your SSP to prevent an assessor from misreading the absence of evidence as a miss:

• SSP: add a short “Withdrawn requirements handling” note in your methodology section.
• POA&M: ensure 03.10.04 does not appear as a finding, milestone, or planned remediation.

This is where teams often stumble: they keep “withdrawn” items in POA&M because the tooling auto-imports all requirement IDs.

Step 5: Define measurable criteria for what remains in-scope

A withdrawn requirement still creates a documentation obligation: your compliance process must show deliberate treatment and ongoing maintenance.

• Add a control operation criterion such as: “Compliance mapping is reviewed and updated when NIST SP 800-171 revisions are adopted; withdrawn items are labeled and excluded from POA&M.” ¹
• Set evidence expectations: change ticket, SSP revision history, mapping export, and approval record.

Step 6: Operationalize ownership and recurring review

Assign ownership to a named role (GRC lead, ISSO, compliance manager) for:

• Requirement mapping quality
• SSP updates
• POA&M governance

Then schedule recurring checks tied to your existing cadence (SSP review cycle, internal assessment cycle, or contract revalidation).

Step 7: Make it assessor-ready (the “one-page proof”)

Prepare a short assessor-facing artifact:

• “Withdrawn Requirements Register” (can be a single row for 03.10.04)
• Fields: requirement ID, status, source version, rationale, last reviewed date, owner, and links to SSP revision

If you use Daydream to manage requirement mappings and evidence, this is the moment it pays off: you can keep the withdrawn status, SSP linkage, and POA&M exclusion logic in one workflow so it does not regress during future updates.

Required evidence and artifacts to retain

Keep artifacts that prove intentional treatment:

1. SSP revision history

• SSP section showing treatment of withdrawn requirements
• Change log entry referencing 03.10.04 status update

2. Requirement-to-control mapping export

• Row for 03.10.04 marked “Withdrawn”
• Rationale field populated with “Withdrawn in NIST SP 800-171 Rev. 3” ¹

3. POA&M evidence

• Proof that 03.10.04 is not tracked as an open item
• If it previously existed: closure record and approval

4. Governance evidence

• Control owner assignment
• Review/approval workflow record (ticket, meeting minutes, or sign-off)

Common exam/audit questions and hangups

Expect questions like:

• “Why is 03.10.04 missing from your SSP mapping?”
• “Show me how you determined it is withdrawn and how your program treats withdrawn items.” ¹
• “Do any of your internal controls or third-party attestations still cite 03.10.04?”
• “How do you prevent your POA&M process from creating gaps for withdrawn requirements?”

Hangup pattern: assessors get uncomfortable when the mapping is silent. “Withdrawn” must be explicit.

Frequent implementation mistakes (and how to avoid them)

1. Marking it ‘N/A’ without saying ‘withdrawn’
   Fix: use a distinct status “Withdrawn” and cite the Rev. 3 basis in the rationale. ¹

2. Keeping a legacy POA&M item open
   Fix: close it with documented justification; attach SSP mapping update.

3. Leaving test scripts in place
   Fix: remove test steps that request evidence for 03.10.04; document the script change.

4. Allowing tooling to re-import it as a gap
   Fix: implement an import rule: withdrawn items do not generate findings.

5. Not assigning ownership
   Fix: name an owner for baseline mapping quality and require approval for mapping changes.

Risk implications and why auditors care

Withdrawn requirements are a maturity signal. If your program cannot cleanly represent “withdrawn,” an assessor may suspect other mapping errors: wrong baseline, incomplete scoping, or weak SSP/POA&M governance. That can expand testing and increase scrutiny across adjacent controls. ¹

Practical 30/60/90-day execution plan

First 30 days (stabilize documentation)

• Identify all repositories where 03.10.04 appears (SSP, mapping sheets, test scripts, POA&M).
• Update mapping status to “Withdrawn” with rationale and owner.
• Remove 03.10.04 from POA&M intake logic and close any legacy items with approval.
• Publish an internal note: “Withdrawn requirements handling” plus where it is documented in the SSP.

Days 31–60 (make it repeatable)

• Add a lightweight control: “Requirement baseline changes trigger mapping review and SSP revision.”
• Update internal assessment checklist to exclude withdrawn requirements and require explicit documentation.
• Review third-party artifacts (SOC reports mappings, shared responsibility matrices) for any stray 03.10.04 references; document resolution.

Days 61–90 (assessor-readiness and durability)

• Build the one-page “Withdrawn Requirements Register” and store it with SSP evidence.
• Run an internal dry-run: ask a non-GRC stakeholder to explain why 03.10.04 has no evidence and see if they can point to the SSP statement.
• Add monitoring: whenever the requirement library is refreshed, verify withdrawn statuses persist.

Frequently Asked Questions

Do I need to implement any technical control for 03.10.04?

No. 03.10.04 is withdrawn in NIST SP 800-171 Rev. 3, so there is no standalone safeguard to implement for that ID. Your job is to document the withdrawal and keep SSP/POA&M mappings clean. ¹

Should 03.10.04 appear in the SSP at all?

Yes, usually as a mapping row marked “Withdrawn” with a short rationale. That prevents assessors from treating it as an omission and shows you are tracking the Rev. 3 baseline accurately. ¹

What if our GRC tool forces a status like Implemented/Not Implemented/N/A?

Use the closest available status (often “N/A”) but add an explicit rationale field that says “Withdrawn in NIST SP 800-171 Rev. 3.” Keep a separate withdrawn register if the tool cannot represent it directly. ¹

We have an open POA&M item for 03.10.04 from a prior assessment. Can we close it?

If it exists solely because of 03.10.04, close it with documented justification and approval, then link the closure to the updated SSP mapping. If the remediation work also supports other active requirements, keep the work item but re-map it to the correct requirement IDs.

How do I explain “withdrawn” to a customer or contracting officer who expects all requirements to be addressed?

Provide a short statement: “03.10.04 is withdrawn in NIST SP 800-171 Rev. 3; no control is required. We maintain traceability by documenting withdrawn items in our SSP mapping.” ¹

What evidence will an assessor accept for a withdrawn requirement?

They will look for documented traceability: a mapping entry marked “Withdrawn,” SSP language describing treatment of withdrawn items, and confirmation it does not generate POA&M gaps. Evidence is documentation-centric, not log-centric. ¹

Footnotes

1. NIST SP 800-171 Rev. 3