Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1FedRAMP Moderate

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.

34.1%
of the target already covered
110
controls evidenced
213
genuine gaps
1
claims rejected in review

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.

AU - Audit and Accountability10 of 16 evidenced, 6 to do
PE - Physical and Environmental Protection11 of 19 evidenced, 8 to do
PS - Personnel Security5 of 10 evidenced, 5 to do
CM - Configuration Management12 of 27 evidenced, 15 to do
SA - System and Services Acquisition9 of 21 evidenced, 12 to do
RA - Risk Assessment4 of 11 evidenced, 7 to do
CA - Assessment, Authorization, and Monitoring5 of 14 evidenced, 9 to do
SR - Supply Chain Risk Management4 of 12 evidenced, 8 to do
AT - Awareness and Training2 of 6 evidenced, 4 to do
AC - Access Control14 of 43 evidenced, 29 to do
IR - Incident Response5 of 17 evidenced, 12 to do
MP - Media Protection2 of 7 evidenced, 5 to do
SC - System and Communications Protection8 of 29 evidenced, 21 to do
CP - Contingency Planning6 of 23 evidenced, 17 to do
SI - System and Information Integrity6 of 24 evidenced, 18 to do
IA - Identification and Authentication6 of 27 evidenced, 21 to do
PL - Planning1 of 7 evidenced, 6 to do
MA - Maintenance0 of 10 evidenced, 10 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.

CCM-IAM-01AC-1argued against and upheld
Policy and Procedures

Identity and access management policy and procedures are the same policy artefact.

CCM-UEM-06AC-11argued against and upheld
Device Lock

Automatic lock screen on managed endpoints is the same device lock.

CCM-CEK-03AC-17(2)argued against and upheld
Protection of Confidentiality and Integrity Using Encryption

Cryptographic protection of data in transit covers remote access sessions.

CCM-UEM-01AC-19argued against and upheld
Access Control for Mobile Devices

Endpoint device policy and procedures govern mobile device access.

CCM-UEM-08AC-19(5)argued against and upheld
Full Device or Container-Based Encryption

Storage encryption on managed endpoints is the same device encryption.

CCM-IAM-07AC-2argued against and upheld
Account Management

Access change and revocation is the account modification and removal requirement.

CCM-IAM-06AC-2argued against and upheld
Account Management

User access provisioning is the account creation and approval requirement.

CCM-IAM-10AC-2(7)argued against and upheld
Privileged User Accounts

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.

CCM-LOG-03SA-2
Allocation of Resources

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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