TheArtOfService
FedRAMP ModerateCloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1

FedRAMP Moderate covers 60.4% of Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1

119 of the 197 controls in Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1 are already satisfied by evidence you collected for FedRAMP Moderate. 78 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.

60.4%
of the target already covered
119
controls evidenced
78
genuine gaps
1
claims rejected in review

This number is directional. It says how much of Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1 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.

292 candidate mappings were examined and 1 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. This pair was additionally re-checked after CSA CCM v4.0.1 was rebuilt from the CAIQ v4.0.1 source on 2026-08-19: its mappings were originally judged when CCM carried no requirement text, a sample of 70 across the 21 CCM pairs found about 80 percent holding cleanly, and the two identified errors were corrected before release.

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.

IAM - Identity & Access Management14 of 16 evidenced, 2 to do
HRS - Human Resources Security11 of 13 evidenced, 2 to do
LOG - Logging & Monitoring11 of 13 evidenced, 2 to do
DCS - Datacenter Security12 of 15 evidenced, 3 to do
IVS - Infrastructure & Virtualization Security7 of 9 evidenced, 2 to do
BCR - Business Continuity Management & Operational Resilience8 of 11 evidenced, 3 to do
CCC - Change Control & Configuration Management6 of 9 evidenced, 3 to do
A&A - Audit & Assurance4 of 6 evidenced, 2 to do
GRC - Governance, Risk & Compliance5 of 8 evidenced, 3 to do
SEF - Security Incident Management, E-Discovery & Cloud Forensics5 of 8 evidenced, 3 to do
TVM - Threat & Vulnerability Management6 of 10 evidenced, 4 to do
UEM - Universal Endpoint Management8 of 14 evidenced, 6 to do
AIS - Application & Interface Security4 of 7 evidenced, 3 to do
DSP - Data Security & Privacy Lifecycle Management10 of 19 evidenced, 9 to do
STA - Supply Chain Management, Transparency & Accountability4 of 14 evidenced, 10 to do
CEK - Cryptography, Encryption & Key Management4 of 21 evidenced, 17 to do
IPY - Interoperability & Portability0 of 4 evidenced, 4 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-1CCM-A&A-01argued against and upheld
Audit and Assurance Policy and Procedures

Assessment policy and procedures are documented, approved and reviewed on a defined cycle.

CA-2(1)CCM-A&A-02argued against and upheld
Independent Assessments

Independent assessors with no conflict of interest conduct the assessment.

CA-2CCM-A&A-03argued against and upheld
Risk Based Planning Assessment

Assessments are planned and scoped against the assessed risk to the system.

CA-5CCM-A&A-06argued against and upheld
Remediation

Plans of action record assessment findings and track remediation to closure.

SA-4CCM-AIS-02argued against and upheld
Application Security Baseline Requirements

Acquisition requirements set the security baseline applications must meet.

SA-8CCM-AIS-04argued against and upheld
Secure Application Design and Development

Security and privacy engineering principles govern secure design and development.

SA-3CCM-AIS-04argued against and upheld
Secure Application Design and Development

The system development life cycle integrates security across design and build.

SA-11(1)CCM-AIS-05argued against and upheld
Automated Application Security Testing

Static code analysis is automated application security testing.

Claims that did not hold

1 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.

SR-6CCM-STA-10
Supply Chain Agreement Review

re-pointed 2026-08-19: judged when CCM carried no requirement text, so it landed on the control whose title resembled the requirement rather than the control that carries it

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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