CMMC 2.0PCI DSS 4.0

CMMC 2.0 covers 37.3% of PCI DSS 4.0

93 of the 249 controls in PCI DSS 4.0 are already satisfied by evidence you collected for CMMC 2.0. 156 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.

37.3%
of the target already covered
93
controls evidenced
156
genuine gaps
152
claims rejected in review

This number is directional. It says how much of PCI DSS 4.0 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.

314 candidate mappings were examined and 153 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.

Req 7: Restrict Access by Need to Know7 of 12 evidenced, 5 to do
Req 10: Logging and Monitoring15 of 27 evidenced, 12 to do
Req 2: Secure Configurations6 of 11 evidenced, 5 to do
Req 1: Network Security Controls10 of 19 evidenced, 9 to do
Req 8: Identify and Authenticate Users15 of 29 evidenced, 14 to do
Req 9: Restrict Physical Access12 of 26 evidenced, 14 to do
Req 6: Secure Systems and Software8 of 19 evidenced, 11 to do
Req 5: Anti-Malware5 of 13 evidenced, 8 to do
Req 4: Protect Cardholder Data in Transit2 of 6 evidenced, 4 to do
Req 11: Test Security Regularly5 of 21 evidenced, 16 to do
Req 3: Protect Stored Account Data4 of 29 evidenced, 25 to do
Req 12: Information Security Policies4 of 37 evidenced, 33 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.L2-3.4.21.2.1argued against and upheld
NSC configuration standards defined

Establishing and enforcing security configuration settings is the configuration standard for network controls.

CM.L2-3.4.31.2.2argued against and upheld
Changes to NSC reviewed and approved

Tracking, reviewing, approving and logging system changes covers network control changes.

CM.L2-3.4.71.2.5argued against and upheld
Services, protocols, ports inventoried and justified

Restricting and disabling nonessential ports, protocols and services requires them to be identified and justified.

CM.L2-3.4.61.2.5argued against and upheld
Services, protocols, ports inventoried and justified

Least functionality requires only essential capabilities, ports and services to remain enabled.

SC.L2-3.13.61.3.1argued against and upheld
Inbound traffic to CDE restricted

Denying network traffic by default and permitting by exception restricts inbound traffic.

SC.L2-3.13.11.3.1argued against and upheld
Inbound traffic to CDE restricted

Monitoring and controlling communications at the boundary restricts inbound traffic to the environment.

SC.L2-3.13.61.3.2argued against and upheld
Outbound traffic from CDE restricted

Default deny policy applies to outbound traffic as well as inbound.

SC.L2-3.13.11.3.2argued against and upheld
Outbound traffic from CDE restricted

Boundary protection controls communications leaving the protected environment.

Claims that did not hold

152 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.

CA.L2-3.12.41.1.1
NSC policies and procedures documented

Held back 2026-08-19. Generated by the retired metered path, refuted at 56 percent wherever re-judged. Pair pulled from sale pending a rebuild on the Max plan.

Claimed at high confidence before it was rejected.

SC.L2-3.13.61.2.5
Services, protocols, ports inventoried and justified

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.

SC.L2-3.13.11.4.2
Inbound traffic from untrusted networks restricted

Held back 2026-08-19. Generated by the retired metered path, refuted at 56 percent wherever re-judged. Pair pulled from sale pending a rebuild on the Max plan.

Claimed at high confidence before it was rejected.

AU.L2-3.3.110.2.1.2
Log all admin actions

Held back 2026-08-19. Generated by the retired metered path, refuted at 56 percent wherever re-judged. Pair pulled from sale pending a rebuild on the Max plan.

Claimed at high confidence before it was rejected.

AU.L2-3.3.810.2.1.3
Log access to audit logs

Held back 2026-08-19. Generated by the retired metered path, refuted at 56 percent wherever re-judged. Pair pulled from sale pending a rebuild on the Max plan.

Claimed at high confidence before it was rejected.

AU.L2-3.3.210.2.1.5
Log changes to identification and authentication

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.

AU.L2-3.3.110.2.1.5
Log changes to identification and authentication

Held back 2026-08-19. Generated by the retired metered path, refuted at 56 percent wherever re-judged. Pair pulled from sale pending a rebuild on the Max plan.

Claimed at high confidence before it was rejected.

AU.L2-3.3.110.2.1.7
Log creation and deletion of system level objects

Held back 2026-08-19. Generated by the retired metered path, refuted at 56 percent wherever re-judged. Pair pulled from sale pending a rebuild on the Max plan.

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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