Cross-Framework Mapping

FedRAMP ModeratevsISO 27701:2019

See exactly how FedRAMP Moderate controls map to ISO 27701:2019. Pre-computed mappings, identified gaps, and coverage analysis.

131
Controls Mapped
192
Gaps Found
28%
Coverage

A reviewed coverage crosswalk for this pair is available. See which ISO 27701:2019 controls you already evidence.

According to the TheArtOfService Compliance Knowledge Graph:

FedRAMP Moderate maps to ISO 27701:2019 with 28% coverage across 92 directly mapped controls. Analysis of 323 FedRAMP Moderate controls identifies 231 compliance gaps, primarily concentrated in AC - Access Control.

Source: TheArtOfService Knowledge Graph | 323 controls analysed | 686 frameworks | 309K+ cross-framework mappings

Control Mappings

Showing 20 of 131 mapped controls across 18 domains. Sign up to explore all 309K+ mappings across 686 frameworks.

AC - Access Control(15 mappings)

AC-1Policy and Procedures2 targets
iso-27701-2019::6.1General
iso-27701-2019::6.6.1Business requirements of access control
AC-19Access Control for Mobile Devices2 targets
iso-27701-2019::6.3.2Mobile devices and teleworking
iso-27701-2019::6.6Access control
AC-19(5)Full Device or Container-Based Encryption
iso-27701-2019::6.3.2Mobile devices and teleworking
AC-2Account Management
iso-27701-2019::6.6.2User access management
AC-2(4)Automated Audit Actions
iso-27701-2019::6.6.2User access management
AC-3Access Enforcement5 targets
iso-27701-2019::6.6.1Business requirements of access control
iso-27701-2019::6.6.4System and application access control
iso-27701-2019::7.3.6Access, correction and/or erasure
iso-27701-2019::7.4.9PII transmission controls
iso-27701-2019::8.4.3PII transmission controls
AC-4Information Flow Enforcement2 targets
iso-27701-2019::6.10.1Network security management
iso-27701-2019::6.10.2Information transfer
AC-6(10)Prohibit Non-Privileged Users from Executing Privileged Functions
iso-27701-2019::6.6.4System and application access control

AT - Awareness and Training(3 mappings)

AT-2Literacy Training and Awareness2 targets
iso-27701-2019::5.5.3Awareness
iso-27701-2019::6.4.2During employment
AT-3Role-Based Training
iso-27701-2019::5.5.2Competence

AU - Audit and Accountability(2 mappings)

AU-12Audit Record Generation
iso-27701-2019::8.4.3PII transmission controls
AU-3Content of Audit Records
iso-27701-2019::6.9.4Logging and monitoring

+111 more mappings

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Coverage crosswalk

The FedRAMP Moderate to ISO 27701:2019 crosswalk

The table above lists candidate mappings. A crosswalk answers the narrower question you are probably here for: which ISO 27701:2019 controls your existing FedRAMP Moderate work already satisfies, which are real gaps, and the reasoning behind every claim so you can check it. One pair, $299, one time.

FedRAMP Moderate into ISO 27701:2019
30.6%

33 of 108 ISO 27701:2019 controls are evidenced by work you have already done for FedRAMP Moderate. 75 are genuine gaps.

86.1%PIMS-specific guidance related to ISO/IEC 27002, ISO 27701:2019
3.2%Additional ISO/IEC 27002 guidance for PII controllers, ISO 27701:2019
5.6%Additional ISO/IEC 27002 guidance for PII processors, ISO 27701:2019
0%PIMS-specific requirements related to ISO/IEC 27001, ISO 27701:2019
Machine verified. Claude Code on the Max plan, judged in context, signed off 2026-08-19. 127 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: 6.10.1 Network security management

Approved information flow control policies enforced within and between systems.

Grounded in AC-4 Information Flow Enforcement. Confidence high, survived the refutation pass.

Gap: 5.1 General

Every requirement of ISO/IEC 27001 that speaks of information security must be read as extending to the protection of privacy as it may be affected by the processing of personally identifiable information, so the management system is...

Every one of the 33 evidenced controls and 75 gaps in the report carries this much reasoning, so you can check the claim rather than take it on trust.

ISO 27701:2019 into FedRAMP Moderate
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.

FedRAMP Moderate to ISO 27701:2019
$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 28% in the header counts how many FedRAMP Moderate controls carry at least one candidate mapping in the graph, before any review. The crosswalk percentage counts something stricter: how many ISO 27701:2019 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 FedRAMP Moderate and ISO 27701:2019?

FedRAMP Moderate has 323 controls across its framework, while ISO 27701:2019 covers 108 controls. Direct mapping analysis identifies 92 overlapping controls (28% coverage). The frameworks diverge most significantly in AC - Access Control, where 35 FedRAMP Moderate controls have no direct ISO 27701:2019 equivalent.

How many controls map between FedRAMP Moderate and ISO 27701:2019?

Of 323 total FedRAMP Moderate controls, 92 map directly to ISO 27701:2019 controls, representing 28% coverage. The remaining 231 controls represent compliance gaps requiring additional documentation or compensating controls to satisfy both frameworks simultaneously.

What are the compliance gaps when mapping FedRAMP Moderate to ISO 27701:2019?

231 FedRAMP Moderate controls have no direct equivalent in ISO 27701:2019. The highest concentration of gaps is in AC - Access Control with 35 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 FedRAMP Moderate and ISO 27701:2019?

The domain with the highest gap count is AC - Access Control (35 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.