FedRAMP ModerateNIST SP 800-172

FedRAMP Moderate covers 60% of NIST SP 800-172

21 of the 35 controls in NIST SP 800-172 are already satisfied by evidence you collected for FedRAMP Moderate. 14 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%
of the target already covered
21
controls evidenced
14
genuine gaps
4
claims rejected in review

This number is directional. It says how much of NIST SP 800-172 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.

48 candidate mappings were examined and 4 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.

CM3 of 3 evidenced
IA3 of 3 evidenced
CA1 of 1 evidenced
RA5 of 7 evidenced, 2 to do
SI5 of 7 evidenced, 2 to do
AC2 of 3 evidenced, 1 to do
AT1 of 2 evidenced, 1 to do
PS1 of 2 evidenced, 1 to do
SC0 of 5 evidenced, 5 to do
IR0 of 2 evidenced, 2 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.

AC-203.1.2eargued against and upheld
Restrict Access to Organization-Owned, Provisioned, or Issued Information Resources

Terms and conditions for external systems restrict access to organization provisioned resources.

AC-20(1)3.1.2eargued against and upheld
Restrict Access to Organization-Owned, Provisioned, or Issued Information Resources

External systems are permitted only after verifying controls or agreeing a connection.

AC-4(21)3.1.3eargued against and upheld
Employ Secure Information Transfer Solutions

FedRAMP requires information flows separated logically or physically between domains.

AC-43.1.3eargued against and upheld
Employ Secure Information Transfer Solutions

Flow enforcement against approved policies controls transfers between connected domains.

SI-53.11.1eargued against and upheld
Threat-Aware Risk Assessment

Alerts and advisories from named external bodies are the threat intelligence intake.

RA-33.11.1eargued against and upheld
Threat-Aware Risk Assessment

FedRAMP fixes annual risk assessment, which is the assessment the threat intelligence guides.

PL-23.11.4eargued against and upheld
Security Solution Rationale Document

The FedRAMP system security plan records the controls selected and is reviewed annually.

CA-23.11.5eargued against and upheld
Assess Effectiveness of Security Solutions

FedRAMP fixes annual assessment of controls by an accredited assessor.

Claims that did not hold

4 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.

SC-73.13.1e
Create Diversity in System Components to Limit Malicious Code Propagation

judged against NIST SP 800-172 content that was corrected the same day. 3.13.2e now carries its issued requirement (introduce unpredictability into operations) not least privilege, and 3.14.3e carries scope inclusion or network segregation not supply chain provenance. Refuted 2026-08-19.

Claimed at high confidence before it was rejected.

AC-4(21)3.13.1e
Create Diversity in System Components to Limit Malicious Code Propagation

judged against NIST SP 800-172 content that was corrected the same day. 3.13.2e now carries its issued requirement (introduce unpredictability into operations) not least privilege, and 3.14.3e carries scope inclusion or network segregation not supply chain provenance. Refuted 2026-08-19.

Claimed at high confidence before it was rejected.

SA-83.13.2e
Introduce Unpredictability into System Operations

judged against NIST SP 800-172 content that was corrected the same day. 3.13.2e now carries its issued requirement (introduce unpredictability into operations) not least privilege, and 3.14.3e carries scope inclusion or network segregation not supply chain provenance. Refuted 2026-08-19.

Claimed at high confidence before it was rejected.

AC-63.13.2e
Introduce Unpredictability into System Operations

judged against NIST SP 800-172 content that was corrected the same day. 3.13.2e now carries its issued requirement (introduce unpredictability into operations) not least privilege, and 3.14.3e carries scope inclusion or network segregation not supply chain provenance. Refuted 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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