Cross-Framework Mapping

DORAvsCFTC System Safeguards (17 CFR 37, 38, 39, 49)

See exactly how DORA controls map to CFTC System Safeguards (17 CFR 37, 38, 39, 49). Pre-computed mappings, identified gaps, and coverage analysis.

46
Controls Mapped
0
Gaps Found
65%
Coverage

A reviewed coverage crosswalk for this pair is available. See which CFTC System Safeguards (17 CFR 37, 38, 39, 49) controls you already evidence.

According to the TheArtOfService Compliance Knowledge Graph:

DORA maps to CFTC System Safeguards (17 CFR 37, 38, 39, 49) with 65% coverage across 17 directly mapped controls. Analysis of 26 DORA controls identifies 9 compliance gaps, primarily concentrated in DORA Chapter II: ICT Risk Management.

Source: TheArtOfService Knowledge Graph | 26 controls analysed | 686 frameworks | 309K+ cross-framework mappings

Control Mappings

Showing 20 of 46 mapped controls across 5 domains. Sign up to explore all 309K+ mappings across 686 frameworks.

DORA Chapter II: ICT Risk Management(20 mappings)

DORA-Art.11Response and recovery5 targets
CFTC-SS-11Testing and Review of Business Continuity and Disaster Recovery Capabilities
CFTC-SS-22Business Continuity and Disaster Recovery Planning Category
CFTC-SS-27Coordination of the Recovery Plan with Members and Market Participants
CFTC-SS-8Business Continuity and Disaster Recovery Plan and Resources
CFTC-SS-9Next Business Day Recovery Time Objective
DORA-Art.12Backup policies and procedures, restoration and recovery4 targets
CFTC-SS-10Geographic Dispersal of Backup Infrastructure and Personnel
CFTC-SS-11Testing and Review of Business Continuity and Disaster Recovery Capabilities
CFTC-SS-37Protection of Swap Data Repository Data
CFTC-SS-8Business Continuity and Disaster Recovery Plan and Resources
DORA-Art.13Learning and evolving2 targets
CFTC-SS-21Remediation of Vulnerabilities and Deficiencies
CFTC-SS-3Information Security Category
DORA-Art.5Governance and organisation3 targets
CFTC-SS-2Enterprise Risk Management and Governance Category
CFTC-SS-23Resources Sufficient to Fulfil Obligations
CFTC-SS-36Internal Reporting and Review by Senior Management and the Board
DORA-Art.6ICT risk management framework5 targets
CFTC-SS-1Program of Risk Analysis and Oversight
CFTC-SS-17Enterprise Technology Risk Assessment
CFTC-SS-2Enterprise Risk Management and Governance Category
CFTC-SS-24Periodic Update of the Recovery Plan and Emergency Procedures
CFTC-SS-7Generally Accepted Standards and Best Practices
DORA-Art.7ICT systems, protocols and tools
CFTC-SS-1Program of Risk Analysis and Oversight

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Coverage crosswalk

The DORA to CFTC System Safeguards (17 CFR 37, 38, 39, 49) crosswalk

The table above lists candidate mappings. A crosswalk answers the narrower question you are probably here for: which CFTC System Safeguards (17 CFR 37, 38, 39, 49) controls your existing DORA work already satisfies, which are real gaps, and the reasoning behind every claim so you can check it. One pair, $299, one time.

DORA into CFTC System Safeguards (17 CFR 37, 38, 39, 49)
51.3%

20 of 39 CFTC System Safeguards (17 CFR 37, 38, 39, 49) controls are evidenced by work you have already done for DORA. 19 are genuine gaps.

70%CFTC System Safeguards: Risk Analysis and Oversight Program
70%CFTC System Safeguards: Cybersecurity Testing
33.3%CFTC System Safeguards: Business Continuity and Disaster Recovery
25%CFTC System Safeguards: Notification, Records and Remediation
Machine verified. Claude Code on the Max plan, judged in context, signed off 2026-08-20. 46 candidate mappings were examined and 0 were removed by a pass whose job was to argue against them.Mappings were judged by Claude Code rather than read line by line by a practitioner. Every claim shows its reasoning so you can check it. Ask and a practitioner will review this pair.

A sample of what the report says

Evidenced: 37.1401(a)(1), 38.1051(a)(1), 49.24(b)(1) Enterprise Risk Management and Governance Category

The management body owns, approves and oversees the ICT risk framework and funds it.

Grounded in DORA-Art.5 Governance and organisation. Confidence high, survived the refutation pass.

Gap: 37.1401(a)(6), 38.1051(a)(6), 39.18(b)(2)(v), 49.24(b)(6) Systems Development and Quality Assurance Category

Address systems development and quality assurance within the program, covering requirements development, pre production and regression testing, change management procedures and approvals, outsourcing and vendor management, and training in...

Every one of the 20 evidenced controls and 19 gaps in the report carries this much reasoning, so you can check the claim rather than take it on trust.

CFTC System Safeguards (17 CFR 37, 38, 39, 49) into DORA
Not published yet

This direction has not been through crosswalk review and sign off, so no coverage figure is published for it. Reporting an unreviewed number would be worse than reporting none. It can be built to order at the same price as a pair that is already on the shelf.

If the two frameworks turn out to have too little in common for a crosswalk to help you, we say so and refund it rather than send a number worth nothing.

DORA to CFTC System Safeguards (17 CFR 37, 38, 39, 49)
$299
per framework pair, one time
  • Every evidenced control, with the reasoning behind it
  • Every gap, with what it requires
  • Its level of review stated plainly, not a bare number

Why this page shows two different percentages. The 65% in the header counts how many DORA controls carry at least one candidate mapping in the graph, before any review. The crosswalk percentage counts something stricter: how many CFTC System Safeguards (17 CFR 37, 38, 39, 49) controls are actually evidenced, after a pass that argued against each mapping and kept only what survived. They answer different questions and they are not meant to agree.

A crosswalk narrows the work. It does not replace an audit, and your assessor may take a different view on individual controls. Mappings between frameworks are judgements, not text printed in either standard, which is why every claim in the report shows its reasoning. Questions go to support@theartofservice.com.

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What are the key differences between DORA and CFTC System Safeguards (17 CFR 37, 38, 39, 49)?

DORA has 26 controls across its framework, while CFTC System Safeguards (17 CFR 37, 38, 39, 49) covers 39 controls. Direct mapping analysis identifies 17 overlapping controls (65% coverage). The frameworks diverge most significantly in DORA Chapter II: ICT Risk Management, where 3 DORA controls have no direct CFTC System Safeguards (17 CFR 37, 38, 39, 49) equivalent.

How many controls map between DORA and CFTC System Safeguards (17 CFR 37, 38, 39, 49)?

Of 26 total DORA controls, 17 map directly to CFTC System Safeguards (17 CFR 37, 38, 39, 49) controls, representing 65% coverage. The remaining 9 controls represent compliance gaps requiring additional documentation or compensating controls to satisfy both frameworks simultaneously.

What are the compliance gaps when mapping DORA to CFTC System Safeguards (17 CFR 37, 38, 39, 49)?

9 DORA controls have no direct equivalent in CFTC System Safeguards (17 CFR 37, 38, 39, 49). The highest concentration of gaps is in DORA Chapter II: ICT Risk Management with 3 unmapped controls. These gaps represent areas where additional controls, policies, or documentation must be created to achieve compliance with both frameworks.

Which control domains have the most gaps between DORA and CFTC System Safeguards (17 CFR 37, 38, 39, 49)?

The domain with the highest gap count is DORA Chapter II: ICT Risk Management (3 gaps). Export the full domain-by-domain gap breakdown via the Professional tier to generate a prioritised remediation roadmap.

This platform provides educational compliance tools, not legal, regulatory, or professional compliance advice. Cross-framework mappings are AI-assisted interpretations and do not reproduce or replace official standards. Framework names and trademarks belong to their respective owners. Consult qualified professionals for your specific compliance requirements. See our Terms of Service.