CMMC 2.0C5 (Germany)

CMMC 2.0 covers 26.4% of C5 (Germany)

32 of the 121 controls in C5 (Germany) are already satisfied by evidence you collected for CMMC 2.0. 89 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.

26.4%
of the target already covered
32
controls evidenced
89
genuine gaps
4
claims rejected in review

This number is directional. It says how much of C5 (Germany) your CMMC 2.0 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.

128 candidate mappings were examined and 4 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.

C5: Cryptography and Key Management2 of 4 evidenced, 2 to do
C5: Identity and Access Management4 of 9 evidenced, 5 to do
C5: Security Incident Management2 of 5 evidenced, 3 to do
C5: Communication Security3 of 8 evidenced, 5 to do
C5: Operations8 of 24 evidenced, 16 to do
C5: Asset Management2 of 6 evidenced, 4 to do
C5: Human Resources2 of 6 evidenced, 4 to do
C5: Portability and Interoperability1 of 3 evidenced, 2 to do
C5: Organisation of Information Security2 of 7 evidenced, 5 to do
C5: Product Safety and Security3 of 12 evidenced, 9 to do
C5: Procurement, Development and Modification of Information Systems2 of 10 evidenced, 8 to do
C5: Physical Security1 of 7 evidenced, 6 to do
C5: Business Continuity Management0 of 4 evidenced, 4 to do
C5: Compliance0 of 4 evidenced, 4 to do
C5: Dealing with Investigation Requests from Government Agencies0 of 4 evidenced, 4 to do
C5: Security Policies and Instructions0 of 3 evidenced, 3 to do
C5: Control and Monitoring of Service Providers and Suppliers0 of 5 evidenced, 5 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.

CM.L2-3.4.1C5-AM-01argued against and upheld
Asset Inventory

Baseline configurations and inventories of systems covering hardware, software, firmware and documentation across the lifecycle are the asset records required

MP.L2-3.8.3C5-AM-04argued against and upheld
Decommissioning of Hardware

Sanitising or destroying media before disposal or release for reuse is the erasure limb of decommissioning

SI.L2-3.14.6C5-COS-01argued against and upheld
Technical safeguards

Watching inbound and outbound traffic for attacks and for indicators that an attack is developing is the detection of irregular traffic required

SC.L2-3.13.6C5-COS-03argued against and upheld
Monitoring of connections in the Cloud Service Provider's network

Denying network traffic by default and permitting only explicitly allowed traffic is the restriction and per service justification required

SC.L2-3.13.1C5-COS-04argued against and upheld
Cross-network access

Controlling communications at the external boundary and at key internal boundaries is the gateway control required

SC.L2-3.13.8C5-CRY-02argued against and upheld
Encryption of data for transmission (transport encryption)

Cryptographic protection preventing disclosure of data during transmission is the transport encryption required

SC.L2-3.13.10C5-CRY-04argued against and upheld
Secure key management

Establishing and managing cryptographic keys across their lifecycle is required directly

CM.L2-3.4.3C5-DEV-03argued against and upheld
Policies for changes to information systems

Tracking, reviewing, approving or rejecting changes and logging the decision is the change management rules required

Claims that did not hold

4 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.

PS.L2-3.9.2C5-HR-05
Responsibilities in the event of termination or change of employment

judged against C5 criterion titles before the framework carried requirement text; does not hold against the real criterion. this criterion is about which security obligations continue to bind a person after their engagement ends and for how long; timely revocation of access on termination or transfer is access withdrawal and is already mapped to C5-IDM-04

Claimed at high confidence before it was rejected.

AC.L2-3.1.8C5-IDM-03
Locking and withdrawal of user accounts in the event of inactivity or multiple failed logins

judged against C5 criterion titles before the framework carried requirement text; does not hold against the real criterion. the title mentions failed logins but the basic criterion covers only dormancy: automatic locking after two months unused, approval to reinstate and revocation after six months; capping consecutive failed logon attempts satisfies none of it

Claimed at high confidence before it was rejected.

AU.L2-3.3.1C5-OPS-13
Logging and Monitoring - Identification of Events

judged against C5 criterion titles before the framework carried requirement text; does not hold against the real criterion. the title says identification of events but the criterion requires automated analysis of logging data, correlation between events and automatic reporting to the responsible departments; generating and retaining records is the logging concept already mapped to C5-OPS-10

Claimed at high confidence before it was rejected.

PE.L2-3.10.5C5-PS-03
Perimeter Protection

judged against C5 criterion titles before the framework carried requirement text; does not hold against the real criterion. this criterion is structural: external doors, windows, walls and locking mechanisms that resist a burglary attempt for at least ten minutes; controlling keys, locks and badge readers is access device management and belongs to C5-PS-04

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.

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