03.11.03: Withdrawn

NIST SP 800-171 Rev. 3 requirement 03.11.03 is withdrawn, so you do not implement a control “for 03.11.03.” Your job is to (1) document that it is withdrawn, (2) confirm no contractual or assessment overlay still expects the older intent, and (3) keep your SSP/POA&M and evidence model clean so assessors see deliberate scoping, not a missed control. ¹

Key takeaways:

• Treat “Withdrawn” as a scoping decision you must document, not as a gap to remediate. ¹
• Update your SSP and crosswalks to show “Withdrawn” explicitly and prevent assessors from hunting for nonexistent evidence. ¹
• Validate downstream obligations (contract clauses, customer requirements, CUI flows) so a withdrawn control doesn’t reappear through a different requirement set. ¹

A withdrawn requirement is a common source of wasted work and audit friction. Teams either (a) keep implementing a legacy control because “it used to be there,” or (b) ignore it and end up with an assessor asking why the SSP has a blank line. For 03.11.03, NIST SP 800-171 Rev. 3 explicitly marks the requirement as withdrawn, which means there is no current control objective to satisfy under that identifier. ¹

Operationally, you still need a defensible posture: your documentation should show you intentionally recognized the withdrawal, confirmed whether any contract or customer overlay still expects a related safeguard, and ensured other requirements cover the underlying risk where relevant. That last point matters because “withdrawn” does not mean “risk disappeared”; it means “this specific requirement label is not in force in Rev. 3.” ¹

This page gives you requirement-level implementation guidance for scoping 03.11.03: what to change in the SSP, how to treat POA&M entries, what evidence to keep, and the exam questions you can expect. It’s written for a CCO, compliance officer, or GRC lead who needs to operationalize the withdrawal cleanly, fast, and without creating assessment debt. ¹

Regulatory text

Regulatory excerpt: “NIST SP 800-171 Rev. 3 requirement 03.11.03 (Withdrawn).” ¹

Plain-English interpretation

• What it means: There is no active requirement to implement under the identifier 03.11.03 in NIST SP 800-171 Rev. 3. ¹
• What an operator must do anyway: You must document the withdrawal in your compliance mapping (SSP, control crosswalks, assessment workbook) and confirm your program does not treat it as an unaddressed gap. Assessors still expect traceability from the requirement list to your implementation narrative. ¹

Why “Withdrawn” still needs operational handling

Withdrawn requirements routinely cause:

• False POA&M items that never close because there is no testable control.
• Control-owner confusion (“Who owns 03.11.03?”).
• Assessment delays when an assessor asks for evidence against an identifier that should be marked non-applicable due to withdrawal. ¹

Your objective is a clean, reviewable compliance record that shows deliberate scoping.

Who it applies to

This guidance applies to:

• Nonfederal organizations operating systems that handle CUI and are aligning to NIST SP 800-171 Rev. 3. ¹
• Federal contractors and subcontractors whose contracts, customer flow-downs, or internal policy require implementation of NIST SP 800-171 controls for CUI environments. ¹

Operational context where this comes up:

• SSP development or refresh for a CUI enclave or boundary system.
• Internal readiness reviews aligned to NIST SP 800-171A assessment methods. ²
• Control crosswalk maintenance (NIST 800-171 to internal policies, ISO 27001 mappings, or customer questionnaires).

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

Step 1: Make an explicit scoping entry for 03.11.03

Create a record in your control register or requirements matrix with:

• Requirement ID: 03.11.03
• Status: Withdrawn ¹
• Implementation: Not applicable; requirement withdrawn
• Rationale: Quote the withdrawal line from the standard. ¹

Operator tip: Don’t leave the row blank. A blank reads like “missed.”

Step 2: Update the SSP so assessors can’t misinterpret the gap

In your System Security Plan (SSP):

• Add a short control statement entry for 03.11.03: “Withdrawn in Rev. 3; no implementation required.”
• Ensure the SSP section where 03.11.03 would have appeared has an explicit reference to withdrawal (not “TBD,” not “planned”). ¹

If you use Daydream or another GRC system, implement this as a requirement mapping note tied directly to the SSP control narrative so it prints cleanly in exports.

Step 3: Remove (or prevent) POA&M items tied to 03.11.03

Review open findings and POA&M rows:

• If an item exists solely because “03.11.03 is missing,” close it as invalid due to withdrawal.
• If the POA&M item points to a real security weakness, re-home it to the correct active requirement(s) and keep the remediation. ¹

Closure discipline: Document closure validation (who approved the closure, when, and what basis) so you can explain why it disappeared from the POA&M. ¹

Step 4: Confirm you are not bound by an overlay that resurrects the requirement

Even if NIST withdrew the requirement, your contract/customer may:

• Reference an older revision,
• Call out a requirement by legacy numbering,
• Require an outcome that used to be captured under 03.11.03. ¹

Actions:

• Check contract language, customer security addenda, and flow-down requirements for explicit references to 03.11.03 or older control families.
• If you find one, document how you satisfy the intent through current Rev. 3 requirements and your existing control set, or negotiate an update with the customer. Keep the correspondence. ¹

Step 5: Align assessment procedures to avoid “phantom testing”

If your internal audit or assessor workbook is modeled on NIST SP 800-171A:

• Mark 03.11.03 as Withdrawn and remove test steps.
• Ensure testers do not request artifacts for it.
• Add a note pointing to the Rev. 3 withdrawal reference. ^{2 1}

Step 6: Put ongoing governance in place

Withdrawals create drift when templates are reused.

• Add a checklist item to your SSP annual refresh: “Validate withdrawn requirements remain marked withdrawn; confirm contract overlays unchanged.”
• Add a control library maintenance step: “Update mappings when NIST revisions change requirement status.” ¹

Required evidence and artifacts to retain

You’re not collecting operational security logs for a withdrawn requirement. You’re retaining scoping and governance evidence:

1. SSP excerpt showing 03.11.03 marked “Withdrawn” with a brief rationale. ¹
2. Requirements-to-controls crosswalk (spreadsheet or GRC export) with 03.11.03 labeled withdrawn. ¹
3. POA&M change log showing closure or reassignment decisions for any 03.11.03-related items, including approver. ¹
4. Contract/overlay review memo (one page is fine) stating whether any customer obligations still reference the withdrawn requirement and how you handled it. ¹
5. Assessment workbook configuration (or screenshot/export) showing 03.11.03 excluded from testing due to withdrawal. ²

Common exam/audit questions and hangups

Expect questions like:

• “Where is your implementation for 03.11.03?”
  Best answer: “It’s withdrawn in Rev. 3; here is the SSP and mapping note reflecting that.” ¹
• “Why did you close this POA&M item?”
  Provide the closure rationale and the Rev. 3 reference; show any re-homed remediation if the risk remains. ¹
• “Are you sure your contract references Rev. 3?”
  Produce the contract clause or your overlay review memo; if ambiguous, show your written clarification with the customer. ¹

Hangups to anticipate:

• Assessors working from older checklists.
• Internal control owners insisting on “checking the box” anyway, creating unnecessary scope and evidence burden.

Frequent implementation mistakes and how to avoid them

Mistake	Why it hurts	Better approach
Leaving 03.11.03 blank in the SSP	Looks like an omission	Add an explicit “Withdrawn in Rev. 3” statement 1
Keeping a POA&M row open forever	Creates artificial noncompliance	Close as invalid due to withdrawal or remap to an active requirement 1
Treating withdrawal as permission to ignore the underlying risk	Risk may still exist under other requirements	Identify where the risk is addressed elsewhere in your control set and document the mapping 1
Failing to review contract/customer overlays	You may still be assessed against older language	Document overlay review and resolution path 1
Allowing assessment teams to test it anyway	Wastes time and confuses results	Update test procedures aligned to NIST SP 800-171A 2

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so this page does not list specific cases.

Practically, the risk is assessment credibility: withdrawn requirements become “process failures” when documentation is messy. That can cascade into broader assessor skepticism about SSP accuracy, control boundaries, and POA&M discipline, which are central to CUI protection assessments under NIST SP 800-171 programs. ¹

Practical 30/60/90-day execution plan

First 30 days (Immediate cleanup)

• Update the SSP entry for 03.11.03 to “Withdrawn” with the cited rationale. ¹
• Update your control crosswalk/control library so all exports show the withdrawn status.
• Sweep POA&M for any items keyed to 03.11.03; close or remap with documented approvals. ¹

By 60 days (Assessment alignment)

• Update internal audit/assessment procedures so 03.11.03 is excluded from test scripts and evidence requests. ²
• Run a tabletop with the assessment team: show the withdrawn entry, where it appears in the SSP, and the evidence packet you’ll provide if asked.

By 90 days (Sustainment)

• Add “withdrawn requirements review” to your SSP refresh checklist and change-management process for templates.
• Validate contract and customer overlays for revision references; store the memo in the same repository as the SSP and POA&M. ¹
• If you use Daydream, configure a standard “Withdrawn requirement” workflow: auto-mark as non-testable, require SSP note, and block POA&M creation unless a mapped active requirement is selected.

Frequently Asked Questions

If 03.11.03 is withdrawn, can we delete it from our SSP?

Keep it as an explicit entry labeled “Withdrawn” so your SSP stays traceable to the requirement list. Deleting it often creates assessor questions and makes crosswalks harder to reconcile. ¹

Do we need any technical controls or logs for a withdrawn requirement?

No control operation evidence is required for a withdrawn identifier. Retain scoping evidence: SSP note, mapping status, and any POA&M closure or reassignment record. ¹

What if our customer contract still references 03.11.03?

Treat it as a contract interpretation issue, not a NIST issue. Document the reference, propose an updated mapping to current Rev. 3 requirements, and keep written customer agreement or guidance. ¹

Should we keep remediation work we started because of 03.11.03?

If the work addresses a real weakness, keep it and map it to an active requirement or internal risk treatment item. If it only exists to satisfy the withdrawn identifier, stop and close it with a documented rationale. ¹

How do assessors test a withdrawn requirement under NIST SP 800-171A?

They should not test it; your assessment workbook should mark it withdrawn and exclude procedures. If an assessor requests evidence, provide the Rev. 3 withdrawal reference and your SSP entry. ^{2 1}

How do we prevent withdrawn requirements from reappearing in templates?

Put the withdrawn status in your control library “source of truth” and require a refresh step whenever you update SSP templates or assessment scripts. Centralizing this in a GRC system reduces drift across teams. ¹

Footnotes

1. NIST SP 800-171 Rev. 3

2. NIST SP 800-171A