Cross-Framework Mapping

ISO 27701:2019vsPCI DSS 4.0

See exactly how ISO 27701:2019 controls map to PCI DSS 4.0. Pre-computed mappings, identified gaps, and coverage analysis.

475
Controls Mapped
0
Gaps Found
54%
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:

ISO 27701:2019 maps to PCI DSS 4.0 with 54% coverage across 0 directly mapped controls. Analysis of 145 ISO 27701:2019 controls identifies 145 compliance gaps, primarily concentrated in PIMS-specific guidance related to ISO/IEC 27002 – ISO 27701:2019.

Source: TheArtOfService Knowledge Graph | 145 controls analysed | 686 frameworks | 309K+ cross-framework mappings

Control Mappings

Showing 20 of 475 mapped controls across 4 domains. Sign up to explore all 309K+ mappings across 686 frameworks.

PIMS-specific requirements related to ISO/IEC 27001, ISO 27701:2019(20 mappings)

iso-27701-2019::5.1General4 targets
12.1.1An overall information security policy is: • Established. • Published. • Maintained. • Disseminated to all relevant personnel, as well as to relevant vendors and business partners
12.1.2The information security policy is: • Reviewed at least once every 12 months. • Updated as needed to reflect changes to business objectives or risks to the environment
2.1.1All security policies and operational procedures that are identified in Requirement 2 are: • Documented. • Kept up to date. • In use. • Known to all affected parties
5.1.1All security policies and operational procedures that are identified in Requirement 5 are: • Documented. • Kept up to date. • In use. • Known to all affected parties
iso-27701-2019::5.2Context of the organization4 targets
12.1.1An overall information security policy is: • Established. • Published. • Maintained. • Disseminated to all relevant personnel, as well as to relevant vendors and business partners
12.1.2The information security policy is: • Reviewed at least once every 12 months. • Updated as needed to reflect changes to business objectives or risks to the environment
12.5.2PCI DSS scope documented and confirmed annually
12.8.2Written agreements with TPSPs
iso-27701-2019::5.2.3Determining the scope of the information security management system3 targets
12.5.2PCI DSS scope documented and confirmed annually
12.5.2.1Service provider scope confirmed every 6 months
12.5.3Impact analysis on org structure changes (SP)
iso-27701-2019::5.2.4Information security management system4 targets
12.1.1An overall information security policy is: • Established. • Published. • Maintained. • Disseminated to all relevant personnel, as well as to relevant vendors and business partners
12.1.2The information security policy is: • Reviewed at least once every 12 months. • Updated as needed to reflect changes to business objectives or risks to the environment
12.1.4CISO or equivalent responsibility
2.1.1All security policies and operational procedures that are identified in Requirement 2 are: • Documented. • Kept up to date. • In use. • Known to all affected parties
iso-27701-2019::5.3Leadership3 targets
12.1.1An overall information security policy is: • Established. • Published. • Maintained. • Disseminated to all relevant personnel, as well as to relevant vendors and business partners
12.1.2The information security policy is: • Reviewed at least once every 12 months. • Updated as needed to reflect changes to business objectives or risks to the environment
2.1.1All security policies and operational procedures that are identified in Requirement 2 are: • Documented. • Kept up to date. • In use. • Known to all affected parties
iso-27701-2019::5.3.1Leadership and commitment2 targets
12.1.1An overall information security policy is: • Established. • Published. • Maintained. • Disseminated to all relevant personnel, as well as to relevant vendors and business partners
12.1.2The information security policy is: • Reviewed at least once every 12 months. • Updated as needed to reflect changes to business objectives or risks to the environment

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Coverage crosswalk

The ISO 27701:2019 to PCI DSS 4.0 crosswalk

The table above lists candidate mappings. A crosswalk answers the narrower question you are probably here for: which PCI DSS 4.0 controls your existing ISO 27701:2019 work already satisfies, which are real gaps, and the reasoning behind every claim so you can check it. One pair, $299, one time.

ISO 27701:2019 into PCI DSS 4.0
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.

PCI DSS 4.0 into ISO 27701:2019
29.6%

32 of 108 ISO 27701:2019 controls are evidenced by work you have already done for PCI DSS 4.0. 76 are genuine gaps.

75%PIMS-specific guidance related to ISO/IEC 27002, ISO 27701:2019
12.9%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. 257 candidate mappings were examined and 125 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

Controls implemented between trusted and untrusted networks is segregation in networks.

Grounded in 1.4.1 NSCs between trusted and untrusted networks. 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 32 evidenced controls and 76 gaps in the report carries this much reasoning, so you can check the claim rather than take it on trust.

PCI DSS 4.0 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 54% in the header counts how many ISO 27701:2019 controls carry at least one candidate mapping in the graph, before any review. The crosswalk percentage counts something stricter: how many PCI DSS 4.0 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 ISO 27701:2019 and PCI DSS 4.0?

ISO 27701:2019 has 145 controls across its framework, while PCI DSS 4.0 covers 249 controls. Direct mapping analysis identifies 0 overlapping controls (54% coverage). The frameworks diverge most significantly in PIMS-specific guidance related to ISO/IEC 27002 – ISO 27701:2019, where 50 ISO 27701:2019 controls have no direct PCI DSS 4.0 equivalent.

How many controls map between ISO 27701:2019 and PCI DSS 4.0?

Of 145 total ISO 27701:2019 controls, 0 map directly to PCI DSS 4.0 controls, representing 54% coverage. The remaining 145 controls represent compliance gaps requiring additional documentation or compensating controls to satisfy both frameworks simultaneously.

What are the compliance gaps when mapping ISO 27701:2019 to PCI DSS 4.0?

145 ISO 27701:2019 controls have no direct equivalent in PCI DSS 4.0. The highest concentration of gaps is in PIMS-specific guidance related to ISO/IEC 27002 – ISO 27701:2019 with 50 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 ISO 27701:2019 and PCI DSS 4.0?

The domain with the highest gap count is PIMS-specific guidance related to ISO/IEC 27002 – ISO 27701:2019 (50 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.