DORANIST SP 800-161 Rev 1

DORA covers 17.3% of NIST SP 800-161 Rev 1

33 of the 191 controls in NIST SP 800-161 Rev 1 are already satisfied by evidence you collected for DORA. 158 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.

17.3%

of the target already covered

controls evidenced

158

genuine gaps

claims rejected in review

This number is directional. It says how much of NIST SP 800-161 Rev 1 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.

59 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.

C-SCRM Family: Risk Assessment4 of 7 evidenced, 3 to do

C-SCRM Family: Incident Response5 of 9 evidenced, 4 to do

C-SCRM Family: Awareness and Training2 of 4 evidenced, 2 to do

C-SCRM Family: Supply Chain Risk Management6 of 13 evidenced, 7 to do

C-SCRM Family: Contingency Planning3 of 8 evidenced, 5 to do

C-SCRM Family: Program Management9 of 30 evidenced, 21 to do

C-SCRM Family: System and Information Integrity2 of 8 evidenced, 6 to do

C-SCRM Family: Access Control1 of 14 evidenced, 13 to do

C-SCRM Family: System and Services Acquisition1 of 15 evidenced, 14 to do

C-SCRM Family: Audit and Accountability0 of 9 evidenced, 9 to do

C-SCRM Family: Assessment, Authorization, and Monitoring0 of 6 evidenced, 6 to do

C-SCRM Family: Configuration Management0 of 14 evidenced, 14 to do

C-SCRM Family: Identification and Authentication0 of 7 evidenced, 7 to do

C-SCRM Family: Maintenance0 of 8 evidenced, 8 to do

C-SCRM Family: Media Protection0 of 4 evidenced, 4 to do

C-SCRM Family: Physical and Environmental Protection0 of 9 evidenced, 9 to do

C-SCRM Family: Planning0 of 7 evidenced, 7 to do

C-SCRM Family: Personnel Security0 of 4 evidenced, 4 to do

C-SCRM Family: Personally Identifiable Information Processing and Transparency0 of 1 evidenced, 1 to do

C-SCRM Family: System and Communications Protection0 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.

DORA-Art.45AC-21argued against and upheld

Information Sharing

Sharing arrangements must protect the sensitivity of the information exchanged and respect data protection law.

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

Literacy Training and Awareness

ICT security awareness programmes must be maintained for staff.

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

Role-Based Training

Digital operational resilience training must be delivered to the roles that carry the duties.

DORA-Art.11CP-1argued against and upheld

Policy and Procedures

An ICT business continuity policy must be in place covering critical or important functions.

DORA-Art.11CP-2argued against and upheld

Contingency Plan

Response and recovery plans must sustain critical functions through disruption and restore them.

DORA-Art.11CP-4argued against and upheld

Contingency Plan Testing

Continuity and recovery plans are subject to regular testing.

DORA-Art.17IR-1argued against and upheld

Policy and Procedures

A documented incident management process with roles and communication plans must be established.

DORA-Art.25IR-3argued against and upheld

Incident Response Testing

Scenario-based and end-to-end testing of critical ICT systems is required at least yearly.

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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