03.11.03: Withdrawn

03.11.03 is a withdrawn requirement in NIST SP 800-171 Rev. 3, so you do not implement a standalone control for it. You must operationalize the withdrawal by documenting the status in your SSP, mapping any legacy control content to the current applicable requirements, and proving your control traceability and POA&M governance still cover the underlying security outcomes. ¹

Key takeaways:

• Treat “03.11.03: withdrawn requirement” as a governance task: document withdrawal, mapping, and assessor-ready traceability. ¹
• Don’t delete legacy material blindly; crosswalk it to current requirements or explicitly justify retirement with impact analysis.
• Your audit risk is “missing coverage” and “confused evidence,” not failure to meet a control that no longer exists.

A withdrawn requirement creates a common failure mode during NIST SP 800-171 assessments: teams either (1) keep implementing an outdated control and can’t explain how it maps to the current standard, or (2) remove it and accidentally create a coverage gap where the security objective still exists elsewhere. For a CCO or GRC lead, the fastest path is to treat 03.11.03 as a documentation and traceability requirement: your SSP should clearly indicate the control is withdrawn, your control crosswalk should show where any legacy intent is now addressed, and your POA&M should reflect any true gaps with ownership and closure evidence.

NIST SP 800-171 Rev. 3 explicitly labels 03.11.03 as “Withdrawn,” which is the operative fact you need to act on. ¹ That means your operational goal is assessor clarity: you can show you recognized the withdrawal, updated your internal control catalog, and maintained a defensible mapping between requirements, system components, and evidence for your CUI environment.

This page gives you requirement-level implementation guidance to operationalize the 03.11.03: withdrawn requirement status quickly and cleanly.

Regulatory text

Requirement text (excerpt): “NIST SP 800-171 Rev. 3 requirement 03.11.03 (Withdrawn).”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

Operator interpretation (what you must do)

Because 03.11.03 is withdrawn, you are not expected to implement a distinct safeguard labeled 03.11.03. Your obligation is to manage the withdrawal correctly inside your compliance system:

• Document that 03.11.03 is withdrawn in your System Security Plan (SSP) and control library. ¹
• Maintain traceability so an assessor can see which current controls/requirements cover any legacy security intent that your program previously associated with 03.11.03.
• Keep POA&M hygiene: if retiring a legacy control creates an actual security or compliance gap, track it with dates, owners, and closure validation artifacts.

This is an operational governance requirement even though it is not a technical requirement.

Plain-English interpretation

“03.11.03: withdrawn requirement” means: NIST removed this requirement from Rev. 3, so you should not claim it as an implemented requirement. Instead, prove you’re working from the current baseline and that your documentation, mappings, and evidence still support your CUI protection posture. ¹

In practice, assessors look for two things:

1. Version control discipline: you know which revision you follow and your SSP matches it.
2. No hidden gaps: removing a withdrawn item did not weaken your actual safeguards for CUI.

Who it applies to

Applies to:

• Federal contractors and subcontractors operating nonfederal systems that handle Controlled Unclassified Information (CUI) and align their environment to NIST SP 800-171 Rev. 3. ¹

Operational contexts where this shows up:

• You are updating your SSP and control mappings for Rev. 3 adoption.
• You are preparing for an assessment and a control list includes 03.11.03 from an older spreadsheet, tool, or template.
• You inherited a third-party governance package (from an MSP, prime contractor, or consultant) that references 03.11.03 without noting it is withdrawn.

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

Step 1: Freeze the current “source of truth”

• Confirm your program baseline is NIST SP 800-171 Rev. 3 and make that explicit in the SSP header, control catalog metadata, and assessment plan. ¹
• Identify all places 03.11.03 appears: SSP sections, control matrices, ticketing tags, GRC tool control objects, and policies/standards.

Deliverable: “Control inventory extract” showing every reference to 03.11.03 and where it lives.

Step 2: Decide the disposition for legacy 03.11.03 content

For each legacy statement tied to 03.11.03, choose one:

• Re-map: The legacy intent is still required, just addressed under a different current requirement/control statement.
• Retire: The legacy intent is no longer required and does not represent a needed safeguard for your environment.
• Keep as internal standard: Even if not required by NIST, you keep it as an internal control because it reduces risk, supports customer commitments, or aligns to other frameworks.

Decision artifact: a short “withdrawal disposition memo” per item (one page is enough) that states re-map/retire/keep plus rationale.

Step 3: Update the SSP and control narrative

In the SSP requirement traceability section (or control implementation statements):

• Mark 03.11.03 = Withdrawn exactly and do not claim “Implemented.” ¹
• Add a cross-reference note: “Legacy control content mapped to: [current requirement IDs/control statements]” or “Retired; no replacement required.”

Keep it simple. Your goal is to prevent assessor confusion and reduce follow-up questions.

Step 4: Validate technical and procedural coverage did not regress

Even though withdrawn, you still need to ensure you did not remove a safeguard that matters to CUI protection.

• If you re-mapped, test the mapped control’s operation (configuration, logs, review cadence, approvals).
• If you retired, confirm compensating coverage exists or document why the control is unnecessary in your environment.

Practical test examples (choose what fits your environment):

• Pull representative logs/reports that demonstrate the mapped control operates.
• Confirm responsible control owners can explain operation and exceptions.
• Verify scope: only the CUI enclave/in-scope systems are claimed in evidence.

Step 5: Align POA&M to the new mapping

If you find a gap during validation:

• Create or update POA&M items with: description, owner, risk rating method, target completion date, and closure criteria.
• Do not close a POA&M item until you have closure validation evidence (test output, screenshots, approval record, or change ticket).

This aligns to common assessment expectations around documentation currency and provable remediation tied to CUI controls. ¹

Step 6: Build an assessor-ready evidence packet

For 03.11.03 specifically, your evidence is governance evidence:

• SSP excerpt showing “Withdrawn”
• Crosswalk table entries
• Change control records for the SSP update
• Validation notes showing no coverage regression
• POA&M entries where applicable

If you use Daydream, treat this as a clean control lifecycle workflow: mark withdrawn, link legacy artifacts, map to current requirements, assign owners, and generate an exportable audit packet without manually reconciling spreadsheets.

Required evidence and artifacts to retain

Minimum artifacts (keep them together in your audit repository):

1. SSP excerpt indicating 03.11.03 is withdrawn. ¹
2. Control crosswalk/mapping table showing where legacy 03.11.03 content landed (re-mapped) or why it was retired.
3. Change record (ticket, approval, version history) for the SSP/control catalog update.
4. Operational validation evidence for the mapped requirement(s): logs, review output, screenshots, test results, or meeting minutes.
5. POA&M records for any resulting gaps, with closure validation.

Common exam/audit questions and hangups

Expect these questions and prepare crisp answers:

• “Why is 03.11.03 listed in your control matrix?”
  Answer: “It is withdrawn in Rev. 3; we keep it as a reference only and mapped its legacy intent to current requirements.” ¹
• “Show me where the old control’s security objective is met now.”
  Provide the crosswalk plus operating evidence for the mapped control.
• “Who approved retiring the legacy safeguard?”
  Show the change ticket and approval plus risk acceptance, if applicable.
• “How do you ensure your SSP stays aligned to Rev. 3 over time?”
  Show your document review process and version control practice.

Frequent implementation mistakes and how to avoid them

Mistake 1: Marking a withdrawn requirement as “Implemented”

Why it fails: It signals you are not tracking the current baseline and can trigger broader sampling by an assessor.
Avoid it: Use a distinct status like “Withdrawn (Rev. 3)” in SSP/control matrices. ¹

Mistake 2: Deleting all references without impact analysis

Why it fails: You can create a real security gap while believing you are “cleaning up.”
Avoid it: Run the disposition process (re-map/retire/keep) and validate control operation.

Mistake 3: Re-mapping without updating evidence collection

Why it fails: You point 03.11.03 to a new requirement but still collect the old evidence set, which does not prove operation.
Avoid it: For each mapped requirement, define measurable implementation criteria and recurring evidence (logs, reviews, approvals, test outputs).

Mistake 4: POA&M “paper closure”

Why it fails: Closing gaps without validation invites findings.
Avoid it: Require closure evidence and a reviewer sign-off before marking complete.

Enforcement context and risk implications

No public enforcement cases were provided for this requirement in the source catalog, and NIST SP 800-171 itself is a framework standard rather than an enforcement action record. The practical risk is indirect:

• Assessment risk: confusion, inconsistent SSP narratives, and missing traceability can drive negative assessment outcomes or delayed awards if your customer requires demonstrable alignment to NIST SP 800-171 Rev. 3. ¹
• Contractual risk: many federal contracts incorporate NIST SP 800-171 expectations; misstating your baseline or control implementation can create dispute risk.

Treat withdrawn items as a maturity test: clean mappings, clean evidence, clean governance.

Practical 30/60/90-day execution plan

First 30 days (stabilize and document)

• Identify every 03.11.03 reference across SSP, policies, control matrices, and tooling.
• Update SSP/control catalog to mark 03.11.03 as withdrawn with a short note. ¹
• Create your initial crosswalk entry and assign an owner for the mapping decision.

Days 31–60 (validate and remediate)

• Complete disposition decisions for all legacy 03.11.03 content (re-map/retire/keep).
• For re-mapped items, confirm implementation and start collecting the right operational evidence.
• Open POA&M items for any gaps uncovered; define closure criteria and required validation artifacts.

Days 61–90 (harden for assessment)

• Run an internal “assessor walkthrough” for the withdrawal package: SSP excerpt, crosswalk, evidence samples, and POA&M status.
• Confirm control owners can explain the mapping and produce evidence on request.
• Lock a lightweight recurring review: SSP version control checks and evidence collection quality checks tied to your assessment calendar.

Control design pattern (recommended)

If you need a repeatable approach for withdrawn requirements, use this pattern:

• Mapping discipline: map the requirement to SSP control statements, responsible system components, and accountable control owners.
• Measurable evidence: define measurable implementation criteria and collect recurring operational evidence (logs, reviews, approvals, test outputs).
• Remediation governance: track gaps in a POA&M with target dates, risk ratings, and closure validation before marking complete.

This is the fastest way to make “withdrawn” operational instead of ambiguous.

Frequently Asked Questions

What does “03.11.03: withdrawn requirement” mean for my assessment scope?

It means you should not be assessed on a standalone 03.11.03 control in Rev. 3. You may still need to show where any legacy intent is covered elsewhere and that your SSP reflects the Rev. 3 baseline. ¹

Should I delete 03.11.03 from my SSP and control matrix?

Don’t delete it blindly. Mark it as withdrawn and add a mapping/retirement note so an assessor can trace how you handled the transition. ¹

What evidence is “enough” for a withdrawn requirement?

Evidence should prove governance: SSP excerpt showing “Withdrawn,” a crosswalk/mapping decision record, and change control history. If you re-mapped to other requirements, keep operating evidence for those controls.

If a prime contractor’s template still lists 03.11.03, what should I do?

Keep their template as an input, but correct your internal source of truth to Rev. 3 and document the withdrawal explicitly. Provide the prime a crosswalk note so your submissions stay consistent with NIST SP 800-171 Rev. 3. ¹

Can I keep the old 03.11.03 safeguard as an internal control anyway?

Yes. Treat it as an internal standard (not a NIST requirement), assign an owner, and collect evidence if you plan to claim it in security assertions to customers or auditors.

How do I prevent this problem from recurring across other withdrawn or changed requirements?

Maintain a formal control lifecycle workflow: version pinning (Rev. 3), a change log for control catalog edits, and a crosswalk requirement for any control added/changed/retired. A GRC workflow tool like Daydream helps by keeping mappings, ownership, evidence, and POA&M status in one place.

Footnotes

1. NIST SP 800-171 Rev. 3