FedRAMP ModerateISO 22301:2019

FedRAMP Moderate covers 28.1% of ISO 22301:2019

16 of the 57 controls in ISO 22301:2019 are already satisfied by evidence you collected for FedRAMP Moderate. 41 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.

28.1%
of the target already covered
16
controls evidenced
41
genuine gaps
9
claims rejected in review

This number is directional. It says how much of ISO 22301:2019 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.

68 candidate mappings were examined and 10 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.

Improvement, ISO 22301:20191 of 2 evidenced, 1 to do
Operation, ISO 22301:20199 of 19 evidenced, 10 to do
Performance evaluation, ISO 22301:20193 of 8 evidenced, 5 to do
Support, ISO 22301:20192 of 8 evidenced, 6 to do
Leadership, ISO 22301:20191 of 5 evidenced, 4 to do
Context of the organization, ISO 22301:20190 of 8 evidenced, 8 to do
Planning, ISO 22301:20190 of 7 evidenced, 7 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-510.1argued against and upheld
Nonconformity and corrective action

A plan of action and milestones tracking remediation of assessment findings is corrective action under 10.1.

CP-15.2argued against and upheld
Policy

Contingency planning policy is issued, approved at senior level and reviewed on a defined cycle.

CP-37.2argued against and upheld
Competence

Contingency training trains personnel in their assigned continuity roles and responsibilities.

CP-37.3argued against and upheld
Awareness

Contingency training makes personnel aware of the plan and their part in it.

RA-98.2.2argued against and upheld
Business impact analysis

Criticality analysis identifies critical components and functions, the core of impact analysis.

CP-28.2.2argued against and upheld
Business impact analysis

Identifying essential missions, functions and recovery priorities is a business impact analysis.

RA-38.2.3argued against and upheld
Risk assessment

Risk assessment of likelihood and impact to operations and assets is the same activity.

CP-78.3.4argued against and upheld
Resource requirements

An alternate processing site with the equipment and supplies needed to resume operations is a determined resource requirement.

Claims that did not hold

9 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-510.2
Continual improvement

target corrected: ISO 22301 clauses 10.1 and 10.2 were swapped in the graph

Claimed at high confidence before it was rejected.

CP-15.2.1
Establishing the business continuity policy

parent and subclause double counted, resolved to the most specific clause

Claimed at high confidence before it was rejected.

CP-15.2.2
Communicating the business continuity policy

parent and subclause double counted, resolved to the most specific clause

Claimed at high confidence before it was rejected.

RA-36.1.2
Addressing risks and opportunities

attached to a mis-titled clause, real 6.1.2 is Addressing risks and opportunities

Claimed at high confidence before it was rejected.

CP-26.2.1
Establishing business continuity objectives

a contingency plan is not objective setting, and CP-2 maps correctly to 8.4.4 Business continuity plans

Claimed at high confidence before it was rejected.

CP-88.3.2
Identification of strategies and solutions

8.3.5 is implementing the selected solutions; this control provides resources, so it belongs on 8.3.4

Claimed at medium confidence before it was rejected.

CP-78.3.2
Identification of strategies and solutions

8.3.5 is implementing the selected solutions; this control provides resources, so it belongs on 8.3.4

Claimed at high confidence before it was rejected.

CP-28.4.1
General

parent and subclause double counted, resolved to the most specific clause

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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