03.12.04: Withdrawn

A withdrawn requirement creates a specific kind of audit risk: not technical noncompliance, but process confusion. In practice, teams inherit control matrices from prior revisions, spreadsheets from primes, or tool templates that still list a requirement ID. If you leave 03.12.04 sitting in your control set, you invite wasted testing, bad POA&Ms, and noise that obscures real deficiencies.

For a CCO or GRC lead, the fastest path is to operationalize “withdrawn” the same way you treat any other scoping decision: formally record it, map it, and make it unambiguous for control owners and assessors. That means a clear SSP statement, an assessment procedure note aligned to NIST SP 800-171A expectations for evidence-based evaluation, and governance to keep future updates from reintroducing the withdrawn item. ¹

This page gives requirement-level implementation guidance for 03.12.04 specifically: who needs to care, what to change in your documentation stack, what evidence to retain, and the exam questions that tend to stall assessments.

What “03.12.04: Withdrawn” means (plain English)

Plain-English interpretation: NIST SP 800-171 Rev. 3 lists requirement 03.12.04 as “Withdrawn.” That indicates there is no current requirement text to implement under that identifier in Rev. 3, and it should not be assessed as a control requirement for Rev. 3 alignment. ²

What you do implement is the governance around it:

• Your compliance system must clearly show that 03.12.04 is withdrawn in Rev. 3.
• Your SSP/control catalog must not imply you have a missing control.
• Your assessment approach must exclude it from testing while preserving traceability for stakeholders who expect to see the ID.

Regulatory text

NIST SP 800-171 Rev. 3 states: “NIST SP 800-171 Rev. 3 requirement 03.12.04 (Withdrawn).” ²

Operator action: treat 03.12.04 as a non-applicable item due to withdrawal within Rev. 3, and document that decision so internal teams, customers, and assessors don’t mis-handle it during scoping and testing. ²

Who it applies to (entity and operational context)

This matters to:

• Federal contractors and subcontractors operating nonfederal information systems that process, store, or transmit CUI and align to NIST SP 800-171. ²
• GRC, compliance, and security assessment teams building an SSP, control matrix, or assessment plan based on Rev. 3. ²
• Third parties in your CUI boundary (MSPs, cloud providers, SaaS platforms) where your documentation references requirement IDs for shared responsibility, inherited controls, or customer attestations.

Operationally, it shows up in:

• SSP requirement-to-control mappings
• Control owner runbooks and checklists
• Internal audit programs
• Customer/primes security questionnaires that assume an older list
• Tooling templates that auto-import requirement IDs

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

Step 1: Identify every place 03.12.04 appears

Search across:

• SSP sections (control descriptions, implementation narratives, appendices)
• Control matrix / traceability matrix (requirement-to-policy, requirement-to-system)
• POA&M and remediation trackers
• Assessment procedures and test scripts aligned to NIST SP 800-171A
• Contractual addenda or customer response libraries

Output: a short “location list” showing document name, section/tab, and the current treatment of 03.12.04. ¹

Step 2: Update SSP mapping with an explicit withdrawal statement

In your SSP, create a requirement entry for 03.12.04 that states:

• Status: Withdrawn in NIST SP 800-171 Rev. 3
• Implementation: Not applicable—no control requirement exists in Rev. 3
• Rationale: Withdrawn requirement identifier; excluded from assessment scope
• References: cite the Rev. 3 source text

Keep the language unambiguous. Avoid vague phrasing like “handled elsewhere” unless you can point to the exact replacement requirement ID (don’t guess). ²

Step 3: Prevent false findings in your assessment approach

Align your assessment artifacts to NIST SP 800-171A-style evidence and determination structure, but for this item, the “test” is documentary:

• Assessment procedure note: “03.12.04 is withdrawn in Rev. 3; no determination required.”
• Evidence: “SSP mapping entry showing withdrawn status + change record.”

This keeps assessors from asking for logs or technical configurations that do not exist for a withdrawn requirement. ³

Step 4: Clean up POA&Ms and open items

If 03.12.04 appears as:

• an open gap,
• a planned remediation,
• or a “Partially Implemented” item,

close it administratively with:

• Closure reason: “Withdrawn in NIST SP 800-171 Rev. 3”
• Closure approver: compliance owner or authorizing official (whoever governs SSP/POA&M)
• Link to SSP entry and Rev. 3 citation

Do not mark it “Implemented.” That implies a control exists and can be tested. ²

Step 5: Manage upstream/downstream expectations (primes and third parties)

Common friction point: a prime or customer template still asks for 03.12.04 implementation details. Your response package should include:

• A standard explanation: “Withdrawn in NIST SP 800-171 Rev. 3; excluded from scope.”
• The SSP excerpt (or sanitized snippet)
• A reference to the official Rev. 3 publication/landing page for verification ⁴

If a third party is in your boundary and provides inherited controls, ensure their responsibility matrix doesn’t list 03.12.04 as a shared control.

Step 6: Put a guardrail in your control inventory so it stays clean

Add one governance control to your compliance operations:

• “Withdrawn requirement handling” procedure in your GRC runbook:
  • how you label it,
  • where you document it (SSP + assessment plan),
  • who approves changes,
  • how you respond to external questionnaires.

If you use Daydream to manage your requirement library and evidence workflows, configure 03.12.04 as “Withdrawn” with a required SSP note and an evidence placeholder for the withdrawal decision record, so it cannot generate remediation tasks or recurring evidence requests.

Required evidence and artifacts to retain

Keep a tight evidence set focused on traceability:

1. SSP requirement mapping entry for 03.12.04 showing “Withdrawn” and “Not applicable due to withdrawal.” ²
2. Change record (ticket, doc revision history, or memo) showing who made the update and who approved it.
3. Assessment plan/test procedure excerpt stating that 03.12.04 is withdrawn and excluded from testing. ⁵
4. POA&M closure record if it was ever tracked as a gap.
5. Customer/prime communications (if applicable) where you clarified the withdrawal status.

Common exam/audit questions and hangups

Expect these and prepare short, documentary answers:

• “Why is 03.12.04 marked N/A?”
  Because it is withdrawn in Rev. 3; provide the SSP excerpt and cite Rev. 3. ²

• “Show me the control implementation for 03.12.04.”
  You should respond that there is no implementation requirement in Rev. 3; show your assessment plan note and the withdrawal citation. ¹

• “Did you map 03.12.04 to another requirement?”
  Only do this if you have a documented, source-backed crosswalk. If you don’t, state “no direct replacement mapped” and keep focus on current Rev. 3 requirements. ²

Frequent implementation mistakes (and how to avoid them)

1. Leaving 03.12.04 in the control matrix as ‘Planned’
   Fix: relabel as “Withdrawn (Rev. 3)” and remove from remediation queues.

2. Marking it ‘Implemented’ to make dashboards green
   Fix: use “Withdrawn / not applicable” with rationale. Greenwashing creates assessment confusion.

3. Creating a “compensating control” for a withdrawn item
   Fix: don’t invent obligations. Spend time on active Rev. 3 requirements and evidence quality. ²

4. Failing to align SSP and assessment procedures
   Fix: ensure SSP, test scripts, and POA&M all tell the same story. NIST SP 800-171A-style assessments reward internal consistency and objective evidence. ⁵

Enforcement context and risk implications

No specific public enforcement cases are provided here for 03.12.04. The practical risk is indirect: a withdrawn requirement can still cause audit findings if your documentation is inconsistent, your POA&M is cluttered with non-requirements, or a customer believes you failed a requirement that does not exist in the current revision. Treat this as a documentation integrity issue tied to assessment readiness. ¹

Practical 30/60/90-day execution plan

Use phases (not calendar promises) and finish fast.

First 30 days (Immediate cleanup)

• Locate all instances of 03.12.04 across SSP, control matrix, POA&M, and test scripts.
• Update SSP entry to “Withdrawn in Rev. 3,” with explicit rationale and citation. ²
• Close any POA&M items tied to 03.12.04 with a withdrawal closure reason.

Next 60 days (Assessment readiness hardening)

• Update assessment plan/procedures to exclude 03.12.04 from testing and list required documentary evidence. ⁵
• Update customer response library and prime questionnaire templates with a standard withdrawn explanation and citation. ⁶

Next 90 days (Governance to prevent reintroduction)

• Add a “withdrawn requirement handling” step into your control lifecycle (intake, updates, annual review).
• If you use a GRC platform (including Daydream), configure the requirement record so it cannot generate tasks, only documentation evidence and an assessor note.
• Train control owners and internal auditors: “Withdrawn means document and exclude; do not build or test.”

Frequently Asked Questions

If 03.12.04 is withdrawn, do we need to do anything at all?

Yes: document that it is withdrawn, remove it from test scripts, and prevent it from appearing as an open gap. Retain SSP and assessment artifacts showing deliberate treatment. ¹

Should we mark 03.12.04 as “Not Applicable” in our SSP?

Mark it as “Withdrawn in Rev. 3” and explain that it is not applicable due to withdrawal. “N/A” alone is too vague for assessors and customers. ²

Our prime’s spreadsheet still lists 03.12.04. How do we respond?

Respond in writing that the requirement is withdrawn in NIST SP 800-171 Rev. 3 and provide a citation plus your SSP excerpt. Offer to map to the prime’s revision baseline if they confirm they are using a different revision. ⁴

Do we need objective evidence (logs, screenshots) for a withdrawn requirement?

No technical evidence is required for an obligation that does not exist. Keep documentary evidence: SSP note, assessment procedure note, and the change record showing governance. ¹

Can we map 03.12.04 to another control to be safe?

Only if you have a documented, source-backed mapping that identifies the replacement requirement. If you cannot support the mapping from authoritative text, treat it as withdrawn and focus on active requirements. ²

How should Daydream track a withdrawn requirement?

Track it as a non-assessable item with required documentation fields (withdrawn rationale, citation, approval) and block remediation workflows and evidence collection tasks that assume a technical control. This keeps dashboards accurate and reduces false findings during reviews.

Footnotes

1. NIST SP 800-171 Rev. 3; NIST SP 800-171A

2. NIST SP 800-171 Rev. 3

3. NIST SP 800-171A; NIST SP 800-171 Rev. 3

4. NIST SP 800-171 Rev. 3; NIST SP 800-171 Rev. 3 landing page

5. NIST SP 800-171A

6. NIST SP 800-171 Rev. 3 landing page