03.12.04: Withdrawn

03.12.04 is a withdrawn requirement in NIST SP 800-171 Rev. 3, so you do not implement a standalone control for it. You must still operationalize it by documenting that it is withdrawn, mapping it to “no longer applicable,” and retaining evidence that your control framework and SSP reflect the current revision and don’t claim coverage for a non-existent requirement. ¹

Key takeaways:

• Treat the 03.12.04: withdrawn requirement as a governance task: confirm status, document rationale, and keep your mapping current. ¹
• Examiners often flag “phantom controls” and outdated crosswalks; your goal is clean traceability from requirement to disposition. ¹
• Preserve artifacts that prove you actively manage requirement changes: change log, control matrix, SSP updates, and assessment scoping notes. ¹

A withdrawn requirement creates a different kind of compliance risk than an unmet requirement. The risk is not that you failed to implement a security capability the standard expects. The risk is that your compliance system is out of date, your SSP/control narrative is unreliable, and your assessment scope is sloppy. That combination can turn a straightforward assessment into a credibility problem.

For a Compliance Officer, CCO, or GRC lead, “03.12.04: withdrawn requirement” should trigger a fast operational response: confirm the authoritative text, mark the requirement as withdrawn in your control library, and ensure downstream artifacts (SSP, control matrix, POA&M if you track it, internal audit plans, third-party flowdowns) do not reference 03.12.04 as an active requirement. ¹

This page gives you requirement-level implementation guidance for withdrawn controls: how to document the disposition, how to prove you keep up with revisions, what evidence auditors ask for, and how to prevent the common failure mode where teams keep testing or claiming compliance against controls that were removed. ¹

Regulatory text

Excerpt (authoritative): “NIST SP 800-171 Rev. 3 requirement 03.12.04 (Withdrawn).” ¹

Operator interpretation of the text

Because NIST SP 800-171 Rev. 3 explicitly marks 03.12.04 as withdrawn, there is no current requirement statement to implement, test, or collect technical evidence for under this identifier. Your operational obligation is governance: make sure your compliance mappings, SSP narratives, and assessment procedures reflect that the requirement is withdrawn and is therefore not applicable as an active control requirement. ¹

What an assessor will expect

Assessors generally evaluate whether your program tracks the applicable control baseline and whether your documentation is consistent with that baseline. For 03.12.04, that means:

• Your control matrix shows an explicit disposition (Withdrawn) rather than a blank or a forced mapping.
• Your SSP does not claim implementation of 03.12.04 or reference it in inherited/implemented controls.
• Your assessment plan and testing scripts do not include test steps for 03.12.04. ¹

Plain-English interpretation (what this “requirement” really requires)

Treat 03.12.04 as a bookkeeping and change-management checkpoint. You are proving two things:

1. You are working from the correct version of the standard; and
2. Your organization can explain, with evidence, why a requirement ID has no implementation or test evidence attached to it. ¹

This is not busywork. Outdated crosswalks create downstream issues: teams write procedures against removed controls, vendors are asked for irrelevant attestations, and internal audit reports cite gaps that cannot be remediated because the requirement no longer exists. ¹

Who it applies to (entity and operational context)

This guidance applies if you are:

• A federal contractor or subcontractor aligning a nonfederal system to NIST SP 800-171 Rev. 3 for Controlled Unclassified Information (CUI) handling; or
• Any nonfederal organization using NIST SP 800-171 Rev. 3 as a contractual or program baseline for safeguarding CUI. ¹

Operationally, this matters for:

• GRC/control owners maintaining the control library and mappings
• System owners maintaining the SSP and boundary
• Internal audit and assessment teams maintaining test procedures
• Supply chain/third-party risk teams that flow down requirements to third parties handling CUI on your behalf (where contract language references NIST SP 800-171) ¹

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

Use the steps below to close out 03.12.04 cleanly and prevent it from reappearing in your program.

Step 1: Confirm the authoritative status

• Record the source of truth for this disposition: “03.12.04 (Withdrawn)” in NIST SP 800-171 Rev. 3.
• Store the reference in your control library entry for 03.12.04, including the citation to the standard. ¹

Step 2: Set the control disposition in your GRC/control library

In your control catalog, set:

• Control status: Withdrawn
• Applicability: Not applicable (Withdrawn by standard)
• Implementation statement: “No implementation required; requirement withdrawn in Rev. 3.”
• Testing approach: None; verify documentation state only (control mapping hygiene). ¹

If you use Daydream or another GRC workflow tool, track this as a “requirement disposition” task with an approver, so you can prove governance and prevent accidental reactivation during audits or platform migrations.

Step 3: Clean up mappings (“phantom control” removal)

Search and remediate references to 03.12.04 across:

• Control matrix / crosswalks (e.g., NIST-to-internal controls)
• SSP control implementation summaries
• Internal audit work programs and checklists
• Policies/standards that list control IDs verbatim
• Third-party requirement exhibits in contracts or security addenda (if they enumerate 03.12.04) ¹

Deliverable: a short “mapping remediation log” that lists each place 03.12.04 appeared and what you changed.

Step 4: Validate versioning across your compliance set

Withdrawn requirements often signal a version mismatch. Do a version alignment check:

• Confirm your SSP header/version statement references NIST SP 800-171 Rev. 3 as your baseline.
• Confirm your control matrix baseline matches the same revision.
• Confirm your assessment methodology references the same revision. ¹

Step 5: Update assessment scoping and examiner-ready narrative

Create a one-paragraph narrative you can reuse in assessments:

• “Control 03.12.04 is withdrawn in NIST SP 800-171 Rev. 3; therefore, no control implementation or test evidence exists. Our control matrix records this disposition, and our assessment procedures exclude it.” ¹

Step 6: Put a recurrence guardrail in place

Withdrawn today can become renumbered, replaced, or reintroduced later. Add a lightweight control to your governance calendar:

• Monitor NIST SP 800-171 Rev. 3 source updates and maintain a change log of requirement dispositions and mapping changes. ¹

Required evidence and artifacts to retain

Keep evidence that proves active governance and clean traceability. Minimum artifacts:

1. Control library entry for 03.12.04 marked “Withdrawn,” with citation. ¹
2. Control matrix / crosswalk export showing disposition and no forced mapping to internal controls.
3. SSP excerpt or change record showing 03.12.04 removed or marked withdrawn, plus revision baseline alignment. ¹
4. Mapping remediation log (tickets, PRs, or change requests) showing where references were removed.
5. Assessment procedure index (or audit program) demonstrating 03.12.04 is out of scope due to withdrawal. ¹
6. Governance change log documenting standard revision monitoring and decisions.

Common exam/audit questions and hangups

Expect these questions, and have the artifact ready:

Auditor question	What they are probing	Best artifact
“Why is 03.12.04 not implemented?”	Version awareness and completeness	Control entry + citation showing Withdrawn 1
“Show me where you addressed 03.12.04 in the SSP.”	SSP consistency	SSP excerpt/change record showing Withdrawn 1
“Your control matrix has a gap here. Is it a finding?”	Mapping hygiene	Crosswalk export with disposition note
“Do your test scripts cover all requirements?”	Assessment integrity	Audit program index excluding withdrawn IDs with rationale 1
“Which revision are you using?”	Baseline alignment	SSP title page/version statement + control baseline reference 1

Frequent implementation mistakes (and how to avoid them)

1. Forcing a mapping anyway. Teams sometimes map withdrawn requirements to a “close enough” internal control to avoid blanks. Avoid this. Mark it withdrawn and document why. ¹
2. Leaving the requirement as “Not Implemented.” That reads like a gap with remediation expected. Use “Withdrawn” as the status, not “Not Implemented.” ¹
3. SSP drift. The SSP gets copied forward and still mentions 03.12.04 in narrative sections. Run a text search across SSP and appendices.
4. Testing the wrong baseline. Audit teams may use an old checklist that still includes 03.12.04. Version-control your audit program and tie it to Rev. 3. ¹
5. Third-party flowdown confusion. If a subcontractor is asked to “comply with 03.12.04,” you create contractual ambiguity. Update templates that enumerate control IDs. ¹

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement. The practical risk is assessment failure modes: inconsistent documentation, unclear scope, and loss of confidence in your compliance assertions for CUI safeguarding requirements aligned to NIST SP 800-171 Rev. 3. ¹

Practical 30/60/90-day execution plan

Use phases rather than fixed timelines if your assessment date is uncertain; tie tasks to your next audit or customer assessment.

First 30 days (stabilize and document)

• Confirm 03.12.04 is withdrawn in your authoritative baseline and record the citation. ¹
• Update the control library entry: status = Withdrawn, applicability note, testing note.
• Run a repository-wide search (SSP, policies, audit scripts, contract templates) and open remediation tickets for every occurrence.

Days 31–60 (clean downstream artifacts)

• Publish an updated control matrix/crosswalk that includes explicit disposition for 03.12.04.
• Update SSP language and appendices; preserve change history.
• Update internal audit/assessment checklists; remove test steps tied to 03.12.04 and add a “withdrawn control verification” step (documentation-only).

Days 61–90 (institutionalize)

• Add a standards-change review to your governance calendar (ownership, cadence, evidence expectations). ¹
• Train control owners and audit staff on how withdrawn requirements are represented (Withdrawn vs Not Implemented).
• In Daydream, convert the remediation log and disposition decision into a reusable evidence package for future assessments, so the question is answered once and consistently.

Frequently Asked Questions

If 03.12.04 is withdrawn, do I need a compensating control?

No compensating control is required for a withdrawn requirement because there is no active requirement statement to satisfy. Your job is to document the withdrawn status and ensure your SSP/control matrix and test plans reflect that disposition. ¹

Should I keep 03.12.04 in my control matrix at all?

Yes, most teams keep withdrawn IDs as rows with an explicit “Withdrawn” status to preserve traceability and avoid audit confusion. The row should clearly state “Withdrawn in Rev. 3” and have no mapped control/test evidence. ¹

Auditors marked 03.12.04 as a gap because there’s no evidence. How do I respond?

Provide the authoritative excerpt showing it is withdrawn and show your control disposition entry plus the SSP/control matrix references. Ask the auditor to record it as “Not applicable (Withdrawn)” rather than a deficiency. ¹

What if a customer contract still references 03.12.04 explicitly?

Treat it as a contract clarification issue. Document that the requirement is withdrawn in the current revision, propose revised language that references the correct revision, and preserve the customer communication and contract redline as evidence. ¹

How do I prevent withdrawn requirements from reappearing in future audits?

Version-control your control matrix and audit program, and maintain a simple change log for requirement dispositions. Tools like Daydream help by making “withdrawn” a first-class status with approvals and recurring evidence packaging.

Does “withdrawn” mean the underlying security practice is unnecessary?

Withdrawn only means the requirement ID is removed from the Rev. 3 baseline; it does not, by itself, declare a practice good or bad. If you already have a related internal control, keep it based on your risk and other applicable requirements, but do not claim it as satisfying 03.12.04. ¹

Footnotes

1. NIST SP 800-171 Rev. 3