CMMC 2.0Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1

CMMC 2.0 covers 31% of Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1

61 of the 197 controls in Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1 are already satisfied by evidence you collected for CMMC 2.0. 136 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.

31%
of the target already covered
61
controls evidenced
136
genuine gaps
1
claims rejected in review

This number is directional. It says how much of Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1 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 1 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.

LOG - Logging & Monitoring9 of 13 evidenced, 4 to do
IAM - Identity & Access Management10 of 16 evidenced, 6 to do
SEF - Security Incident Management, E-Discovery & Cloud Forensics4 of 8 evidenced, 4 to do
IVS - Infrastructure & Virtualization Security4 of 9 evidenced, 5 to do
TVM - Threat & Vulnerability Management4 of 10 evidenced, 6 to do
HRS - Human Resources Security5 of 13 evidenced, 8 to do
UEM - Universal Endpoint Management5 of 14 evidenced, 9 to do
DCS - Datacenter Security5 of 15 evidenced, 10 to do
A&A - Audit & Assurance2 of 6 evidenced, 4 to do
AIS - Application & Interface Security2 of 7 evidenced, 5 to do
GRC - Governance, Risk & Compliance2 of 8 evidenced, 6 to do
CCC - Change Control & Configuration Management2 of 9 evidenced, 7 to do
DSP - Data Security & Privacy Lifecycle Management3 of 19 evidenced, 16 to do
CEK - Cryptography, Encryption & Key Management3 of 21 evidenced, 18 to do
BCR - Business Continuity Management & Operational Resilience1 of 11 evidenced, 10 to do
IPY - Interoperability & Portability0 of 4 evidenced, 4 to do
STA - Supply Chain Management, Transparency & Accountability0 of 14 evidenced, 14 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.

CA.L2-3.12.1CCM-A&A-03argued against and upheld
Risk Based Planning Assessment

Periodically assessing controls to determine effectiveness is risk based assessment.

CA.L2-3.12.2CCM-A&A-06argued against and upheld
Remediation

Plans of action correct deficiencies and eliminate vulnerabilities.

SC.L2-3.13.2CCM-AIS-04argued against and upheld
Secure Application Design and Development

Architectural designs and engineering principles that promote security govern development.

SI.L2-3.14.1CCM-AIS-07argued against and upheld
Application Vulnerability Remediation

Identifying, reporting and correcting flaws in a timely manner is the same requirement.

RA.L2-3.11.3CCM-AIS-07argued against and upheld
Application Vulnerability Remediation

Remediating vulnerabilities in accordance with risk assessments is the same requirement.

IR.L2-3.6.3CCM-BCR-10argued against and upheld
Response Plan Exercise

Testing the organisational incident response capability exercises the response plan.

CM.L2-3.4.5CCM-CCC-04argued against and upheld
Unauthorized Change Protection

Defining, documenting, approving and enforcing access restrictions on changes prevents unauthorised change.

CM.L2-3.4.3CCM-CCC-04argued against and upheld
Unauthorized Change Protection

Tracking, reviewing, approving and logging changes means only approved changes land.

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.

AC.L2-3.1.6CCM-IAM-09
Segregation of Privileged Access Roles

re-judged once CMMC 2.0 carried real requirement text rather than a pointer: using a non-privileged account for non-security work is not segregation of privileged roles

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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