FedRAMP ModerateNIST Cybersecurity Framework 2.0

FedRAMP Moderate covers 63.2% of NIST Cybersecurity Framework 2.0

67 of the 106 controls in NIST Cybersecurity Framework 2.0 are already satisfied by evidence you collected for FedRAMP Moderate. 39 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.

63.2%
of the target already covered
67
controls evidenced
39
genuine gaps
39
claims rejected in review

What this leaves you to do

NIST Cybersecurity Framework 2.0 has 106 controls. Holding FedRAMP Moderate already evidences 67 of them, so the work in front of you is 39 controls, not 106, which is 37% of the standard rather than all of it.

That is the whole claim. Every number in that sentence comes from the two counts above it and can be re-derived from the free tools without taking our word for any of it.

In money, using only our numbers. The full report is $299 and names 67 controls of NIST Cybersecurity Framework 2.0 you do not have to implement again, which is $4.46 per control identified. That arithmetic uses our price and our count and assumes nothing about you.

In your hours, using your assumption. We do not know what a control costs you to implement, so pick the column that looks like your organisation. These are your figures, not our claim.

If a control takes you4 hours8 hours16 hours
the 67 already evidenced are268 hours536 hours1,072 hours
and the 39 remaining are156 hours312 hours624 hours

Multiply by your own rate. We publish no rate because we have not measured yours, and a number built on an invented rate is the kind of claim this platform exists to argue against.

This number is directional. It says how much of NIST Cybersecurity Framework 2.0 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.

204 candidate mappings were examined and 40 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.

PR - Protect18 of 22 evidenced, 4 to do
DE - Detect9 of 11 evidenced, 2 to do
ID - Identify16 of 21 evidenced, 5 to do
RS - Respond7 of 13 evidenced, 6 to do
RC - Recover4 of 8 evidenced, 4 to do
GV - Govern13 of 28 evidenced, 15 to do
Govern0 of 3 evidenced, 3 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.

SI-4NIST-CSF-DE.AE-02argued against and upheld
Potentially adverse events are analyzed to better understand associated activities

System monitoring analyses detected events to understand the associated activity.

AU-6NIST-CSF-DE.AE-02argued against and upheld
Potentially adverse events are analyzed to better understand associated activities

Audit review and analysis examines logged events for indications of adverse activity.

SI-4(16)NIST-CSF-DE.AE-03argued against and upheld
Information is correlated from multiple sources

Correlating monitoring information from multiple sources is the same activity.

AU-6(3)NIST-CSF-DE.AE-03argued against and upheld
Information is correlated from multiple sources

Correlating audit repositories produces organisation-wide awareness across sources.

SI-4(5)NIST-CSF-DE.AE-06argued against and upheld
Information on adverse events is provided to authorized staff and tools

System-generated alerts notify defined personnel when indicators appear.

IR-8NIST-CSF-DE.AE-08argued against and upheld
Incidents are declared when adverse events meet the defined incident criteria

The incident response plan defines the criteria for declaring an incident.

SI-4(4)NIST-CSF-DE.CM-01argued against and upheld
Networks and network services are monitored to find potentially adverse events

Monitoring inbound and outbound communications traffic covers network monitoring.

PE-6NIST-CSF-DE.CM-02argued against and upheld
The physical environment is monitored to find potentially adverse events

Monitoring physical access detects adverse events in the physical environment.

Claims that did not hold

39 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.

RA-3NIST-CSF-GV.OV-03
Organizational cybersecurity risk management performance is evaluated and reviewed for adjustments needed

retired metered-API path. 56 percent of its output was refuted wherever it was re-judged, so its residue is not trusted evidence. Superseded by judgement on the Claude Max plan 2026-08-19.

Claimed at medium confidence before it was rejected.

CA-7(4)NIST-CSF-GV.OV-03
Organizational cybersecurity risk management performance is evaluated and reviewed for adjustments needed

retired metered-API path. 56 percent of its output was refuted wherever it was re-judged, so its residue is not trusted evidence. Superseded by judgement on the Claude Max plan 2026-08-19.

Claimed at high confidence before it was rejected.

AU-6NIST-CSF-GV.OV-03
Organizational cybersecurity risk management performance is evaluated and reviewed for adjustments needed

did not survive the adversarial verification pass run by qwen3-235b-a22b-2507 via openrouter. No per-edge rationale was recorded at the time, so the process is stated rather than a reason invented.

Claimed at low confidence before it was rejected.

CA-2NIST-CSF-GV.OV-03
Organizational cybersecurity risk management performance is evaluated and reviewed for adjustments needed

retired metered-API path. 56 percent of its output was refuted wherever it was re-judged, so its residue is not trusted evidence. Superseded by judgement on the Claude Max plan 2026-08-19.

Claimed at medium confidence before it was rejected.

CA-5NIST-CSF-GV.RM-07
Strategic opportunities (i.e., positive risks) are characterized and are included in organizational cybersecurity risk discussions

NIST CSF 2.0 GV.RM-07 held a different requirement when this was judged: characterising strategic opportunities as positive risks, not identifying improvements from risk assessments. Corrected against the issued core 2026-08-21. A judgement made against different text is void whatever its outcome.

Claimed at high confidence before it was rejected.

SR-6NIST-CSF-GV.SC-03
Cybersecurity supply chain risk management is integrated into cybersecurity and enterprise risk management, risk assessment, and improvement processes

did not survive the adversarial verification pass run by qwen3-235b-a22b-2507 via openrouter. No per-edge rationale was recorded at the time, so the process is stated rather than a reason invented.

Claimed at medium confidence before it was rejected.

SA-9(1)NIST-CSF-GV.SC-03
Cybersecurity supply chain risk management is integrated into cybersecurity and enterprise risk management, risk assessment, and improvement processes

retired metered-API path. 56 percent of its output was refuted wherever it was re-judged, so its residue is not trusted evidence. Superseded by judgement on the Claude Max plan 2026-08-19.

Claimed at medium confidence before it was rejected.

RA-3(1)NIST-CSF-GV.SC-03
Cybersecurity supply chain risk management is integrated into cybersecurity and enterprise risk management, risk assessment, and improvement processes

retired metered-API path. 56 percent of its output was refuted wherever it was re-judged, so its residue is not trusted evidence. Superseded by judgement on the Claude Max plan 2026-08-19.

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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