Cross-Framework Mapping

PCI DSS 4.0vsISO 27701:2019

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

475
Controls Mapped
0
Gaps Found
83%
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:

PCI DSS 4.0 maps to ISO 27701:2019 with 83% coverage across 207 directly mapped controls. Analysis of 249 PCI DSS 4.0 controls identifies 42 compliance gaps, primarily concentrated in Req 11: Test Security Regularly.

Source: TheArtOfService Knowledge Graph | 249 controls analysed | 686 frameworks | 309K+ cross-framework mappings

Control Mappings

Showing 20 of 475 mapped controls across 12 domains. Sign up to explore all 309K+ mappings across 686 frameworks.

Req 1: Network Security Controls(20 mappings)

1.1.1NSC policies and procedures documented3 targets
iso-27701-2019::5.5.5Documented information
iso-27701-2019::6.10.1Network security management
iso-27701-2019::6.2.1Management direction for information security
1.1.2Roles and responsibilities for Requirement 12 targets
iso-27701-2019::5.3.3Organizational roles, responsibilities and authorities
iso-27701-2019::6.5.1Responsibility for assets
1.2.1NSC configuration standards defined2 targets
iso-27701-2019::5.6.1Operational planning and control
iso-27701-2019::6.10.1Network security management
1.2.2Changes to NSC reviewed and approved
iso-27701-2019::6.9.1Operational procedures and responsibilities
1.2.3Network diagrams maintained3 targets
iso-27701-2019::6.10.1Network security management
iso-27701-2019::6.5.1Responsibility for assets
iso-27701-2019::6.9.1Operational procedures and responsibilities
1.2.5Services, protocols, ports inventoried and justified2 targets
iso-27701-2019::6.10.1Network security management
iso-27701-2019::6.9.1Operational procedures and responsibilities
1.2.6Security features for insecure services defined
iso-27701-2019::6.9.6Technical vulnerability management
1.2.7NSC rule sets reviewed every six months2 targets
iso-27701-2019::6.10.1Network security management
iso-27701-2019::6.15.2Information security reviews
1.3.1Inbound traffic to CDE restricted3 targets
iso-27701-2019::6.10Communications security
iso-27701-2019::6.10.1Network security management
iso-27701-2019::6.6.1Business requirements of access control
1.3.2Outbound traffic from CDE restricted
iso-27701-2019::6.10Communications security

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Coverage crosswalk

The PCI DSS 4.0 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 PCI DSS 4.0 work already satisfies, which are real gaps, and the reasoning behind every claim so you can check it. One pair, $299, one time.

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.

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 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 83% in the header counts how many PCI DSS 4.0 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 PCI DSS 4.0 and ISO 27701:2019?

PCI DSS 4.0 has 249 controls across its framework, while ISO 27701:2019 covers 145 controls. Direct mapping analysis identifies 207 overlapping controls (83% coverage). The frameworks diverge most significantly in Req 11: Test Security Regularly, where 9 PCI DSS 4.0 controls have no direct ISO 27701:2019 equivalent.

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

Of 249 total PCI DSS 4.0 controls, 207 map directly to ISO 27701:2019 controls, representing 83% coverage. The remaining 42 controls represent compliance gaps requiring additional documentation or compensating controls to satisfy both frameworks simultaneously.

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

42 PCI DSS 4.0 controls have no direct equivalent in ISO 27701:2019. The highest concentration of gaps is in Req 11: Test Security Regularly with 9 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 PCI DSS 4.0 and ISO 27701:2019?

The domain with the highest gap count is Req 11: Test Security Regularly (9 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.