C5 (Germany) covers 59% of CFTC System Safeguards (17 CFR 37, 38, 39, 49)
23 of the 39 controls in CFTC System Safeguards (17 CFR 37, 38, 39, 49) are already satisfied by evidence you collected for C5 (Germany). 16 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
CFTC System Safeguards (17 CFR 37, 38, 39, 49) has 39 controls. Holding C5 (Germany) already evidences 23 of them, so the work in front of you is 16 controls, not 39, which is 41% of the standard rather than all of it.
That is the whole claim. We do not know your hourly rate, how long a control takes you, or how many people you have, so there is no figure here in dollars or weeks. 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.
This number is directional. It says how much of CFTC System Safeguards (17 CFR 37, 38, 39, 49) your C5 (Germany) 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.
67 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.
Regular security performance reporting to top management plus annual management review evidences oversight.
Annual internal audit of the management system with findings risk assessed and corrective measures tracked.
Annual risk handling with named owners reviewing treatment and residual risk evidences enterprise risk oversight.
Incident response policy sets classification, prioritisation, escalation and a standing emergency response team.
Role and rights concept mandates least privilege, segregation of duties, entitlement review and privileged MFA.
Written logging and monitoring policy fixes event criteria, activation, retention and responsibilities for audit logs.
Pre-engagement screening of everyone reaching customer data or production components covers personnel security.
Single documented continuity and contingency planning framework covering scope, owners, recovery and activation.
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.
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