CMMC 2.0ISO 27701:2019

CMMC 2.0 covers 31.5% of ISO 27701:2019

34 of the 108 controls in ISO 27701:2019 are already satisfied by evidence you collected for CMMC 2.0. 74 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.

31.5%
of the target already covered
34
controls evidenced
74
genuine gaps
15
claims rejected in review

This number is directional. It says how much of ISO 27701:2019 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.

95 candidate mappings were examined and 15 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.

PIMS-specific guidance related to ISO/IEC 27002, ISO 27701:201922 of 36 evidenced, 14 to do
PIMS-specific requirements related to ISO/IEC 27001, ISO 27701:20198 of 23 evidenced, 15 to do
Additional ISO/IEC 27002 guidance for PII processors, ISO 27701:20192 of 18 evidenced, 16 to do
Additional ISO/IEC 27002 guidance for PII controllers, ISO 27701:20192 of 31 evidenced, 29 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.L2-3.12.45.2.3argued against and upheld
Determining the scope of the information security management system

Both require the system boundary and operating environment to be determined and documented.

RA.L2-3.11.15.4.1argued against and upheld
Actions to address risks and opportunities

Both require risks assessed so that actions to address them can be chosen.

AT.L2-3.2.25.5.2argued against and upheld
Competence

Both require personnel competent for the security duties assigned to them.

AT.L2-3.2.15.5.3argued against and upheld
Awareness

Both require personnel made aware of security risks and the policies governing them.

RA.L2-3.11.15.6.2argued against and upheld
Information security risk assessment

Both require periodic assessment of risk to systems and the information they hold.

RA.L2-3.11.35.6.3argued against and upheld
Information security risk treatment

Both require identified risks treated in the priority order the assessment sets.

CA.L2-3.12.35.7.1argued against and upheld
Monitoring, measurement, analysis and evaluation

Both require control effectiveness monitored on an ongoing basis.

CA.L2-3.12.25.8.1argued against and upheld
Nonconformity and corrective action

Both require corrective action plans against identified deficiencies.

Claims that did not hold

15 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.

AT.L2-3.2.25.5.3
Awareness

Generated by the retired metered path, which was refuted at 56 percent wherever it was re-judged. Held back so an unreleased pair cannot be signed off on unreviewed mappings. Re-judge on the Max plan to revive.

Claimed at high confidence before it was rejected.

IA.L2-3.5.26.6.1
Business requirements of access control

retired metered-API path. 56 percent of its output was refuted wherever it was re-judged, so its residue is not trusted evidence. Superseded by judgement on the Claude Max plan 2026-08-19.

Claimed at medium confidence before it was rejected.

AC.L2-3.1.46.6.1
Business requirements of access control

retired metered-API path. 56 percent of its output was refuted wherever it was re-judged, so its residue is not trusted evidence. Superseded by judgement on the Claude Max plan 2026-08-19.

Claimed at medium confidence before it was rejected.

AC.L2-3.1.56.6.1
Business requirements of access control

Generated by the retired metered path, which was refuted at 56 percent wherever it was re-judged. Held back so an unreleased pair cannot be signed off on unreviewed mappings. Re-judge on the Max plan to revive.

Claimed at high confidence before it was rejected.

PE.L2-3.10.26.8
Physical and environmental security

Generated by the retired metered path, which was refuted at 56 percent wherever it was re-judged. Held back so an unreleased pair cannot be signed off on unreviewed mappings. Re-judge on the Max plan to revive.

Claimed at high confidence before it was rejected.

PE.L2-3.10.36.8
Physical and environmental security

retired metered-API path. 56 percent of its output was refuted wherever it was re-judged, so its residue is not trusted evidence. Superseded by judgement on the Claude Max plan 2026-08-19.

Claimed at medium confidence before it was rejected.

PE.L2-3.10.16.8
Physical and environmental security

Generated by the retired metered path, which was refuted at 56 percent wherever it was re-judged. Held back so an unreleased pair cannot be signed off on unreviewed mappings. Re-judge on the Max plan to revive.

Claimed at high confidence before it was rejected.

PE.L2-3.10.56.8
Physical and environmental security

retired metered-API path. 56 percent of its output was refuted wherever it was re-judged, so its residue is not trusted evidence. Superseded by judgement on the Claude Max plan 2026-08-19.

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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