Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1 covers 34.1% of FedRAMP Moderate
110 of the 323 controls in FedRAMP Moderate are already satisfied by evidence you collected for Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1. 213 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.
This number is directional. It says how much of FedRAMP Moderate your Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1 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.
349 candidate mappings were examined and 3 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. This pair was additionally re-checked after CSA CCM v4.0.1 was rebuilt from the CAIQ v4.0.1 source on 2026-08-19: its mappings were originally judged when CCM carried no requirement text, a sample of 70 across the 21 CCM pairs found about 80 percent holding cleanly, and the two identified errors were corrected before release.
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.
Identity and access management policy and procedures are the same policy artefact.
Automatic lock screen on managed endpoints is the same device lock.
Cryptographic protection of data in transit covers remote access sessions.
Endpoint device policy and procedures govern mobile device access.
Storage encryption on managed endpoints is the same device encryption.
Access change and revocation is the account modification and removal requirement.
User access provisioning is the account creation and approval requirement.
Management of privileged access roles is the privileged account requirement.
Claims that did not hold
1 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.
control identity corrected 2026-08-19: FedRAMP SA-2 held the title 'Common Operating Picture' and the text 'Establish a common operating picture across IT, OT and physical security functions for cyber events.', which is not a NIST SP 800-53 Rev 5 control. SA-2 is Allocation of Resources: determine the high-level security and privacy requirements in mission and business process planning, determine, document and allocate the protecting resources through capital planning and investment control, and establish a discrete line item for information security and privacy in programming and budgeting documentation. This mapping was judged against the wrong requirement, so its judgement is void. The claim on record was that CCM-LOG-03 (Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1) evidences SA-2 at medium confidence; it does not evidence resource determination, allocation or a budget line item.
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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