03.10.05: Withdrawn

03.10.05 is a withdrawn requirement in NIST SP 800-171 Rev. 3, so you do not implement a standalone control for it. You operationalize it by documenting that it is withdrawn, mapping it to “not applicable,” and keeping governance evidence that your crosswalk, SSP, and assessment artifacts reflect the withdrawal without leaving an unexplained gap. ¹

Key takeaways:

• Treat the 03.10.05: withdrawn requirement as a governance and traceability task, not a technical control. ¹
• Update your SSP/control matrix so assessors see an explicit “Withdrawn (N/A)” entry rather than a missing control. ¹
• Retain artifacts that prove your mapping decision, version awareness, and recurring review cadence for changes to NIST SP 800-171. ¹

A withdrawn control creates a predictable audit problem: teams either leave a hole in the control catalog (which looks like a miss) or they “inherit” an old control from a prior revision and keep operating it without confirming it still belongs. For 03.10.05: withdrawn requirement, the right move is neither. Your job is to show you are tracking NIST SP 800-171 Rev. 3 accurately and that your program documentation can withstand assessor scrutiny. ¹

For federal contractors and other nonfederal organizations handling CUI, NIST SP 800-171 is often a contractual and assessment anchor. Assessors and customers expect a complete control set trace, even when an item is withdrawn. That means you need a deliberate “not applicable because withdrawn” treatment with clear references, ownership, and evidence that you review framework changes and keep your SSP/control crosswalk current. ¹

This page is written for a CCO, Compliance Officer, or GRC lead who needs to operationalize 03.10.05: withdrawn requirement quickly: what to change in your control matrix, what to say in the SSP, what evidence to retain, and the audit questions you should expect.

Regulatory text

Excerpt (framework text): “NIST SP 800-171 Rev. 3 requirement 03.10.05 (Withdrawn).” ¹

What this means for an operator

• There is no current Rev. 3 requirement to implement under 03.10.05. “Withdrawn” indicates the requirement has been removed from the active set in this revision. ¹
• Your obligation shifts to documentation quality and assessment readiness. You must prevent “missing control” ambiguity by explicitly marking the requirement as withdrawn in your control listing and SSP/control implementation summary. ¹
• You still need to show traceability. Auditors and customers often compare your control matrix to the published list. If they see no entry for 03.10.05, they may interpret it as incomplete scoping or an omitted requirement. Your mapping must remove doubt. ¹

Where to confirm the source:

• NIST SP 800-171 Rev. 3 PDF: https://nvlpubs.nist.gov/nistpubs/SpecialPublications/NIST.SP.800-171r3.pdf ¹
• NIST SP 800-171 Rev. 3 landing page: https://csrc.nist.gov/pubs/sp/800/171/r3/final ¹

Plain-English interpretation (03.10.05: withdrawn requirement)

You are not expected to deploy a specific security practice labeled 03.10.05 in NIST SP 800-171 Rev. 3 because it no longer exists as an active requirement. You are expected to:

1. acknowledge the withdrawal in your governance artifacts, and
2. ensure your assessment package shows a complete, intentional mapping across all listed requirements, including withdrawn ones. ¹

Who it applies to

Entities

• Federal contractors that handle CUI in nonfederal systems. ¹
• Any nonfederal organization handling CUI where NIST SP 800-171 Rev. 3 is required by contract, flow-down, or customer requirement. ¹

Operational context

This comes up during:

• SSP development and maintenance (control descriptions must align to Rev. 3 requirement list). ¹
• Internal audits / readiness reviews (control catalog completeness checks). ¹
• Third-party assessments where an assessor walks the requirement list and expects a disposition for each identifier. ¹

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

Step 1: Identify where 03.10.05 appears (or should appear)

Check the following locations for either a gap (missing entry) or a legacy control:

• Control matrix / requirements traceability matrix
• SSP control implementation sections
• Policies/standards that cite NIST SP 800-171 control identifiers
• Audit scripts and evidence checklists ¹

Practical tip: A common place 03.10.05 gets “lost” is a spreadsheet that was copied forward from a prior revision. If your matrix is revision-agnostic, add a “Framework version” field. ¹

Step 2: Create an explicit disposition entry

In your control matrix, add a row for 03.10.05 with a disposition such as:

• Status: Withdrawn (Rev. 3)
• Applicability: Not applicable
• Rationale: Requirement withdrawn in NIST SP 800-171 Rev. 3
• Compensating controls: None (unless your contract imposes an equivalent obligation)
• Owner: GRC/Compliance (or Control Owner if your program requires assignment) ¹

This is the core operational deliverable for the 03.10.05: withdrawn requirement keyword: a visible, reviewable “N/A because withdrawn” mapping that prevents audit churn. ¹

Step 3: Update the SSP so the assessor doesn’t guess

In the SSP section that lists requirements and implementations:

• Include 03.10.05 in sequence.
• State “Withdrawn in NIST SP 800-171 Rev. 3; no implementation required.”
• Cross-reference your control matrix entry. ¹

If your SSP template forces an “implementation narrative,” keep it short and factual. Do not invent a replacement requirement.

Step 4: Verify contract/customer overlays

Even though the framework requirement is withdrawn, your contract may still:

• reference an older revision, or
• include an overlay that expects a practice similar to what 03.10.05 used to require.

Action:

• Review contract language and customer security addenda for explicit control identifiers and version references.
• If there is a mismatch, document a decision: “We comply to Rev. 3; customer requires Rev. X mapping; provide crosswalk.” ¹

Step 5: Put “withdrawn requirements governance” into your recurring process

Add a lightweight governance step to your compliance calendar:

• Monitor NIST SP 800-171 revision updates and refresh your crosswalk when the standard changes.
• Require a reviewer to sign off that “withdrawn” items are still accurately marked as withdrawn and not reintroduced accidentally. ¹

Where Daydream fits naturally: if you manage multiple customers and assessment packages, Daydream can track requirement dispositions, keep your SSP/control matrix aligned to NIST SP 800-171 Rev. 3, and produce a clean audit trail showing why 03.10.05 is marked withdrawn rather than missing.

Required evidence and artifacts to retain

Maintain a small, audit-friendly packet tied to 03.10.05:

1. Control matrix entry showing 03.10.05 status = Withdrawn / N/A, with rationale. ¹
2. SSP excerpt (or control implementation summary) that lists 03.10.05 with the same disposition language. ¹
3. Framework reference: a saved copy or link register pointing to NIST SP 800-171 Rev. 3 as your authoritative version. ¹
4. Change log / governance record showing when you updated the matrix/SSP to reflect Rev. 3 and who approved it. ¹
5. Contract version analysis memo (if applicable) documenting any customer references to older revisions and your crosswalk approach. ¹

Common exam/audit questions and hangups

Expect these lines of questioning:

• “Why is 03.10.05 missing from your control list?”
  Fix: It should not be missing; it should be present and marked withdrawn. ¹

• “Show me where in your SSP you address 03.10.05.”
  Fix: Provide the SSP excerpt and point to your matrix. ¹

• “What process do you have to track framework revisions and withdrawn items?”
  Fix: Provide your compliance calendar entry, change log, and version-controlled crosswalk. ¹

• “Are you sure your contract is tied to Rev. 3?”
  Fix: Show the contract clause/version reference and, if needed, your customer-specific mapping. ¹

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it causes trouble	Better approach
Deleting 03.10.05 from the matrix entirely	Assessors read it as an omission	Keep the row, mark it Withdrawn / N/A, cite Rev. 3 1
Keeping an old control narrative from a prior revision	Creates conflicting requirements and wasted evidence work	Remove legacy text; replace with a short withdrawn statement 1
Marking it “N/A” without stating “Withdrawn”	“N/A” can look like scoping avoidance	Say “Withdrawn in Rev. 3” explicitly 1
No version governance	Future updates reintroduce confusion	Add version fields and a documented review workflow 1
Ignoring customer overlays	Contract misalignment becomes a finding	Do a contract-to-framework version check and document the outcome 1

Enforcement context and risk implications

No public enforcement cases were provided for this specific requirement in the source catalog. Practically, the risk is indirect: a withdrawn requirement can still generate assessment findings if your documentation looks incomplete, inconsistent, or out of date relative to NIST SP 800-171 Rev. 3. Those findings can cascade into customer friction, delayed approvals, or a broader review of your SSP quality. ¹

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

You asked for fast operationalization; use phases so you can move without inventing timelines.

Immediate (next few weeks)

• Add 03.10.05 to your control matrix with “Withdrawn (Rev. 3)” and a clear rationale. ¹
• Update the SSP to include the same disposition language. ¹
• Open a change ticket and capture approval in your GRC workflow. ¹

Near-term (next couple of months)

• Perform a “withdrawn/changed requirements sweep” across your NIST SP 800-171 library so other withdrawn items (if any in your broader mapping) are treated consistently. ¹
• Review key contracts/customer addenda for version references and document deltas and crosswalk decisions. ¹

Ongoing (steady state)

• Add a recurring review step to confirm your requirement list matches NIST SP 800-171 Rev. 3 and that withdrawn items remain correctly labeled. ¹
• Keep your evidence packet current: matrix export, SSP excerpt, and change log entry. ¹

Frequently Asked Questions

What does “03.10.05: withdrawn requirement” mean in practice?

It means NIST SP 800-171 Rev. 3 no longer defines an active requirement under 03.10.05. Treat it as a documentation and traceability task: keep the identifier in your matrix and SSP, marked “Withdrawn (N/A).” ¹

Do I need a compensating control for 03.10.05?

Not for NIST SP 800-171 Rev. 3 itself, because the requirement is withdrawn. Only define a compensating control if your contract, customer overlay, or internal policy still expects the underlying behavior. ¹

Will an assessor flag us if we don’t show 03.10.05 anywhere?

They might, because missing identifiers often look like incomplete scoping. Prevent that by including 03.10.05 with an explicit withdrawn disposition in your matrix and SSP. ¹

How should we word the SSP entry for 03.10.05?

Keep it short and factual: “03.10.05 is withdrawn in NIST SP 800-171 Rev. 3; no implementation required.” Cross-reference the control matrix row for traceability. ¹

Our customer references an older revision. What should we do with 03.10.05?

Document the version mismatch, then provide a crosswalk that shows how your Rev. 3 program maps to the customer’s stated requirement set. Keep the decision record with the contract file and SSP appendix. ¹

What evidence should we keep to prove we handled the withdrawn requirement correctly?

Retain the matrix row, SSP excerpt, a version reference to NIST SP 800-171 Rev. 3, and a change log showing who approved the update. This is usually enough to resolve audit questions quickly. ¹

Footnotes

1. NIST SP 800-171 Rev. 3