Australia Consumer Data Right - Banking (CDR) covers 35.2% of ISO 27701:2019
38 of the 108 controls in ISO 27701:2019 are already satisfied by evidence you collected for Australia Consumer Data Right - Banking (CDR). 70 are genuine gaps. Every claim below was judged against both control sets and then argued against; the ones that did not survive are published further down with the reason each failed.
What this leaves you to do
ISO 27701:2019 has 108 controls. Holding Australia Consumer Data Right - Banking (CDR) already evidences 38 of them, so the work in front of you is 70 controls, not 108, which is 65% of the standard rather than all of it.
That is the whole claim. Every number in that sentence comes from the two counts above it and can be re-derived from the free tools without taking our word for any of it.
In money, using only our numbers. The full report is $299 and names 38 controls of ISO 27701:2019 you do not have to implement again, which is $7.87 per control identified. That arithmetic uses our price and our count and assumes nothing about you.
In your hours, using your assumption. We do not know what a control costs you to implement, so pick the column that looks like your organisation. These are your figures, not our claim.
| If a control takes you | 4 hours | 8 hours | 16 hours |
|---|---|---|---|
| the 38 already evidenced are | 152 hours | 304 hours | 608 hours |
| and the 70 remaining are | 280 hours | 560 hours | 1,120 hours |
Multiply by your own rate. We publish no rate because we have not measured yours, and a number built on an invented rate is the kind of claim this platform exists to argue against.
This number is directional. It says how much of ISO 27701:2019 your Australia Consumer Data Right - Banking (CDR) evidence satisfies. The reverse pair is a different number, often very different, because a security standard has enormous depth for access control and almost none for lawful basis or data subject rights.
59 candidate mappings were examined and 0 were removed. Signed off 2026-08-19, review level machine verified. 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.
Where the gaps are
Coverage is never evenly spread. A source standard usually satisfies one part of a target almost completely and barely touches another, and which part is which is the thing worth knowing before you plan the work.
Theme level, not control level, deliberately. The per-control list of what is evidenced and what is a gap is the report itself, so publishing it here would be publishing the thing being sold.
Claims that held
A sample. Each one names the control whose evidence does the work, the control it satisfies, and why.
Assesses, defines and documents the boundaries of the regulated data environment.
Requires a maintained security capability adapted to threats and reviewed at least annually.
Requires a maintained information security policy approved under a formal governance framework.
Documents practices and responsibilities including those of senior management.
Formal awareness program for all personnel interacting with the regulated data.
Requires the minimum controls to be implemented and adjusted to the assessed harm.
Monitors and evaluates control design and operating effectiveness on a defined program.
Independent skilled testers assess effectiveness and escalate deficiencies to senior management.
Claims that did not hold
Nothing proposed for this pair was rejected in review. That is unusual and worth knowing rather than hiding: it means the candidate set was small and every candidate held.
The full report
Everything above is a sample. The report is every evidenced control and every gap, with the reasoning and the source document behind each one, in a form you can hand to an assessor. $299, emailed immediately.
Buy this crosswalk