FedRAMP Moderate covers 71.1% of C5 (Germany)
86 of the 121 controls in C5 (Germany) are already satisfied by evidence you collected for FedRAMP Moderate. 35 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.
This number is directional. It says how much of C5 (Germany) your FedRAMP Moderate 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.
268 candidate mappings were examined and 9 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.
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.
Updating the inventory during installation, removal and update is what keeps asset records complete, accurate and current
Component inventory kept accurate and current with the attributes needed to manage the assets, which is what the criterion requires
Sanitisation or destruction of media before disposal, release or reuse is the erasure limb the criterion requires
Signed access agreements are the documented commitment to permissible use and handling before assets are issued
Termination processing retrieves organisational property, evidencing the return of assets
The contingency plan identifies essential functions, recovery objectives, restoration priorities and metrics, which is the documented impact analysis content
A single documented contingency plan with scope, roles, recovery and restoration procedures and its maintenance is the planning framework required
Coordination with business continuity, disaster recovery and continuity of operations plans matches the framework.
Claims that did not hold
6 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.
judged against C5 criterion titles before the framework carried requirement text; does not hold against the real criterion. the criterion is an approval gate before hardware enters production, with risk analysis and verification that error handling, logging, encryption, authentication and authorisation are securely configured; updating an inventory during installation records the event and gates nothing
Claimed at high confidence before it was rejected.
judged against C5 criterion titles before the framework carried requirement text; does not hold against the real criterion. the criterion is about which security obligations continue to bind a person after their employment ends or changes, and for how long; reviewing and modifying access rights on transfer is a different requirement and is already mapped to C5-IDM-04
Claimed at medium confidence before it was rejected.
judged against C5 criterion titles before the framework carried requirement text; does not hold against the real criterion. the title mentions failed logins but the basic criterion covers only dormancy: automatic locking after two months unused, approval to reinstate and revocation after six months; lockout after consecutive invalid logon attempts satisfies none of it
Claimed at high confidence before it was rejected.
judged against C5 criterion titles before the framework carried requirement text; does not hold against the real criterion. the criterion governs use of usage metadata: purpose limitation to billing, incident and security handling, anonymisation, no commercial use, retention and deletion; specifying the content fields of an audit record addresses none of that and is already mapped to C5-OPS-15
Claimed at high confidence before it was rejected.
judged against C5 criterion titles before the framework carried requirement text; does not hold against the real criterion. the title says identification of events but the criterion requires automated analysis of logging data, correlation of relationships between events and automatic reporting to the responsible departments; selecting which event types to log is the separate logging concept already mapped to C5-OPS-10
Claimed at high confidence before it was rejected.
judged against C5 criterion titles before the framework carried requirement text; does not hold against the real criterion. this criterion is structural: external doors, windows, walls and locking mechanisms that resist a burglary attempt for at least ten minutes; enforcing physical access authorisations at entry points is access control and is already mapped to C5-PS-04
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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