DORAFedRAMP Moderate

DORA covers 11.5% of FedRAMP Moderate

37 of the 323 controls in FedRAMP Moderate are already satisfied by evidence you collected for DORA. 286 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.

11.5%

of the target already covered

controls evidenced

286

genuine gaps

claims rejected in review

This number is directional. It says how much of FedRAMP Moderate your DORA 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.

60 candidate mappings were examined and 0 were removed. Signed off 2026-08-20, 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.

SR - Supply Chain Risk Management6 of 12 evidenced, 6 to do

AT - Awareness and Training3 of 6 evidenced, 3 to do

RA - Risk Assessment4 of 11 evidenced, 7 to do

CA - Assessment, Authorization, and Monitoring5 of 14 evidenced, 9 to do

CP - Contingency Planning7 of 23 evidenced, 16 to do

IR - Incident Response5 of 17 evidenced, 12 to do

SI - System and Information Integrity2 of 24 evidenced, 22 to do

SC - System and Communications Protection2 of 29 evidenced, 27 to do

SA - System and Services Acquisition1 of 21 evidenced, 20 to do

CM - Configuration Management1 of 27 evidenced, 26 to do

AC - Access Control1 of 43 evidenced, 42 to do

AU - Audit and Accountability0 of 16 evidenced, 16 to do

IA - Identification and Authentication0 of 27 evidenced, 27 to do

MA - Maintenance0 of 10 evidenced, 10 to do

MP - Media Protection0 of 7 evidenced, 7 to do

PE - Physical and Environmental Protection0 of 19 evidenced, 19 to do

PL - Planning0 of 7 evidenced, 7 to do

PS - Personnel Security0 of 10 evidenced, 10 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.

DORA-Art.9AC-2argued against and upheld

Account Management

Access management is a named protection the entity must implement and maintain.

DORA-Art.13AT-1argued against and upheld

Policy and Procedures

ICT security awareness programmes and resilience training must be established and maintained.

DORA-Art.13AT-2argued against and upheld

Literacy Training and Awareness

Security awareness programmes must run for staff on a continuing basis.

DORA-Art.13AT-3argued against and upheld

Role-Based Training

Digital operational resilience training must reach the roles carrying ICT responsibilities.

DORA-Art.24CA-1argued against and upheld

Policy and Procedures

A resilience testing programme must be established, maintained and reviewed within the framework.

DORA-Art.24CA-7argued against and upheld

Continuous Monitoring

A risk-based programme sets what is assessed, how often, and is reviewed for suitability.

DORA-Art.25CA-8argued against and upheld

Penetration Testing

Penetration testing is a required test type with critical systems tested at least yearly.

DORA-Art.26CA-8(1)argued against and upheld

Penetration Testing | Independent Penetration Testing Agent or Team. Employ an independent penetration testing agent or team to perform penetration testing on the system or system components

Threat-led penetration testing must be performed by qualified internal or external testers.

Claims that did not hold

Nothing proposed for this pair was rejected in review. That is unusual and worth knowing rather than hiding: it means the candidate set was small and every candidate held.

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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