CIS Controls v8PCI DSS 4.0

CIS Controls v8 covers 43% of PCI DSS 4.0

107 of the 249 controls in PCI DSS 4.0 are already satisfied by evidence you collected for CIS Controls v8. 142 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.

43%
of the target already covered
107
controls evidenced
142
genuine gaps
263
claims rejected in review

This number is directional. It says how much of PCI DSS 4.0 your CIS Controls v8 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.

415 candidate mappings were examined and 264 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.

Req 7: Restrict Access by Need to Know9 of 12 evidenced, 3 to do
Req 11: Test Security Regularly15 of 21 evidenced, 6 to do
Req 6: Secure Systems and Software13 of 19 evidenced, 6 to do
Req 1: Network Security Controls12 of 19 evidenced, 7 to do
Req 5: Anti-Malware8 of 13 evidenced, 5 to do
Req 2: Secure Configurations6 of 11 evidenced, 5 to do
Req 8: Identify and Authenticate Users15 of 29 evidenced, 14 to do
Req 12: Information Security Policies19 of 37 evidenced, 18 to do
Req 4: Protect Cardholder Data in Transit2 of 6 evidenced, 4 to do
Req 9: Restrict Physical Access4 of 26 evidenced, 22 to do
Req 3: Protect Stored Account Data4 of 29 evidenced, 25 to do
Req 10: Logging and Monitoring0 of 27 evidenced, 27 to do

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.

CIS-4.21.2.1argued against and upheld
NSC configuration standards defined

Secure configuration standards for network infrastructure are these NSC configuration standards.

CIS-12.41.2.3argued against and upheld
Network diagrams maintained

Maintained architecture diagrams are the network diagrams required.

CIS-3.81.2.4argued against and upheld
Data flow diagram of account data

Documented data flows are the account data flow diagram requirement.

CIS-4.81.2.5argued against and upheld
Services, protocols, ports inventoried and justified

Disabling unnecessary services requires the same enumerated, justified service list.

CIS-12.61.2.6argued against and upheld
Security features for insecure services defined

Secure network management and communication protocol requirements define features for insecure services.

CIS-12.31.2.8argued against and upheld
Configuration files secured and synchronised

Securely managing network infrastructure covers protecting device configuration files.

CIS-13.41.3.1argued against and upheld
Inbound traffic to CDE restricted

Filtering traffic between segments restricts inbound traffic to the card environment.

CIS-4.41.3.1argued against and upheld
Inbound traffic to CDE restricted

Host firewalls restrict inbound traffic reaching in scope systems.

Claims that did not hold

263 proposed mappings for this pair were rejected. They are kept in the graph rather than deleted, so what was thrown out is as inspectable as what survived. A crosswalk that never rejects anything is not being judged.

CIS-13.91.2.5
Services, protocols, ports inventoried and justified

retired metered-API path. 56 percent of its output was refuted wherever it was re-judged, so its residue is not trusted evidence. Superseded by judgement on the Claude Max plan 2026-08-19.

Claimed at medium confidence before it was rejected.

CIS-4.81.2.6
Security features for insecure services defined

retired metered-API path. 56 percent of its output was refuted wherever it was re-judged, so its residue is not trusted evidence. Superseded by judgement on the Claude Max plan 2026-08-19.

Claimed at medium confidence before it was rejected.

CIS-13.101.2.6
Security features for insecure services defined

retired metered-API path. 56 percent of its output was refuted wherever it was re-judged, so its residue is not trusted evidence. Superseded by judgement on the Claude Max plan 2026-08-19.

Claimed at medium confidence before it was rejected.

CIS-13.91.2.6
Security features for insecure services defined

retired metered-API path. 56 percent of its output was refuted wherever it was re-judged, so its residue is not trusted evidence. Superseded by judgement on the Claude Max plan 2026-08-19.

Claimed at medium confidence before it was rejected.

CIS-13.91.3.2
Outbound traffic from CDE restricted

Held back 2026-08-19. Generated by the retired metered path, refuted at 56 percent wherever re-judged. Pair pulled from sale pending a rebuild on the Max plan.

Claimed at high confidence before it was rejected.

CIS-13.41.3.3
NSCs between wireless and CDE

Held back 2026-08-19. Generated by the retired metered path, refuted at 56 percent wherever re-judged. Pair pulled from sale pending a rebuild on the Max plan.

Claimed at high confidence before it was rejected.

CIS-13.41.4.1
NSCs between trusted and untrusted networks

Held back 2026-08-19. Generated by the retired metered path, refuted at 56 percent wherever re-judged. Pair pulled from sale pending a rebuild on the Max plan.

Claimed at high confidence before it was rejected.

CIS-13.101.4.2
Inbound traffic from untrusted networks restricted

retired metered-API path. 56 percent of its output was refuted wherever it was re-judged, so its residue is not trusted evidence. Superseded by judgement on the Claude Max plan 2026-08-19.

Claimed at medium confidence before it was rejected.

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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