TheArtOfService
Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1PCI DSS 4.0

Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1 covers 41% of PCI DSS 4.0

102 of the 249 controls in PCI DSS 4.0 are already satisfied by evidence you collected for Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1. 147 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.

41%
of the target already covered
102
controls evidenced
147
genuine gaps
8
claims rejected in review

What this leaves you to do

PCI DSS 4.0 has 249 controls. Holding Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1 already evidences 102 of them, so the work in front of you is 147 controls, not 249, which is 59% 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 102 controls of PCI DSS 4.0 you do not have to implement again, which is $2.93 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 you4 hours8 hours16 hours
the 102 already evidenced are408 hours816 hours1,632 hours
and the 147 remaining are588 hours1,176 hours2,352 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 PCI DSS 4.0 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.

330 candidate mappings were examined and 10 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.

Req 6: Secure Systems and Software12 of 19 evidenced, 7 to do
Req 7: Restrict Access by Need to Know7 of 12 evidenced, 5 to do
Req 12: Information Security Policies17 of 37 evidenced, 20 to do
Req 9: Restrict Physical Access11 of 26 evidenced, 15 to do
Req 1: Network Security Controls8 of 19 evidenced, 11 to do
Req 8: Identify and Authenticate Users12 of 29 evidenced, 17 to do
Req 10: Logging and Monitoring10 of 27 evidenced, 17 to do
Req 3: Protect Stored Account Data10 of 29 evidenced, 19 to do
Req 11: Test Security Regularly7 of 21 evidenced, 14 to do
Req 4: Protect Cardholder Data in Transit2 of 6 evidenced, 4 to do
Req 5: Anti-Malware4 of 13 evidenced, 9 to do
Req 2: Secure Configurations2 of 11 evidenced, 9 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-IVS-011.1.1argued against and upheld
NSC policies and procedures documented

Infrastructure and virtualization security policy and procedures are the same artefact.

CCM-IVS-041.2.1argued against and upheld
NSC configuration standards defined

Hardening and base controls are the network device configuration standard.

CCM-CCC-011.2.2argued against and upheld
Changes to NSC reviewed and approved

Change management policy and procedures cover review and approval of changes.

CCM-IVS-081.2.3argued against and upheld
Network diagrams maintained

Network architecture documentation is the network diagram requirement.

CCM-DSP-051.2.4argued against and upheld
Data flow diagram of account data

Data flow documentation is the account data flow diagram requirement.

CCM-IVS-031.3.1argued against and upheld
Inbound traffic to CDE restricted

Restricting inbound communications to authorized connections is the same control.

CCM-IVS-031.3.2argued against and upheld
Outbound traffic from CDE restricted

Restricting outbound communications to authorized connections is the same control.

CCM-IVS-061.4.1argued against and upheld
NSCs between trusted and untrusted networks

Segmentation and segregation separate trusted from untrusted networks.

Claims that did not hold

8 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-CEK-0110.1.1
Requirement 10 policies and operational procedures documented and maintained

judged against contaminated control text, does not hold against the real PCI DSS 4.0 requirement

Claimed at high confidence before it was rejected.

CCM-CEK-1010.1.2
Requirement 10 roles and responsibilities documented and assigned

judged against contaminated control text, does not hold against the real PCI DSS 4.0 requirement

Claimed at high confidence before it was rejected.

CCM-IVS-0212.1.3
Information security roles and responsibilities defined and acknowledged

judged against contaminated control text, does not hold against the real PCI DSS 4.0 requirement

Claimed at high confidence before it was rejected.

CCM-BCR-0812.3.1
Targeted risk analysis documented for requirements that specify one

judged against contaminated control text, does not hold against the real PCI DSS 4.0 requirement

Claimed at high confidence before it was rejected.

CCM-LOG-0112.4.1
Executive management responsibility for the PCI DSS compliance program (service providers)

judged against contaminated control text, does not hold against the real PCI DSS 4.0 requirement

Claimed at high confidence before it was rejected.

CCM-TVM-0112.6.1
Formal security awareness program implemented

judged against contaminated control text, does not hold against the real PCI DSS 4.0 requirement

Claimed at high confidence before it was rejected.

CCM-IAM-109.2.3
Physical access to networking and telecommunications hardware restricted

judged against contaminated control text, does not hold against the real PCI DSS 4.0 requirement

Claimed at high confidence before it was rejected.

CCM-IAM-059.4.1
Media with cardholder data physically secured

judged against contaminated control text, does not hold against the real PCI DSS 4.0 requirement

Claimed at high 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.

Buy this crosswalk