FedRAMP ModeratePCI DSS 4.0

FedRAMP Moderate covers 55.4% of PCI DSS 4.0

138 of the 249 controls in PCI DSS 4.0 are already satisfied by evidence you collected for FedRAMP Moderate. 111 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.

55.4%

of the target already covered

138

controls evidenced

111

genuine gaps

claims rejected in review

This number is directional. It says how much of PCI DSS 4.0 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.

454 candidate mappings were examined and 98 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.

Req 2: Secure Configurations8 of 11 evidenced, 3 to do

Req 8: Identify and Authenticate Users20 of 29 evidenced, 9 to do

Req 4: Protect Cardholder Data in Transit4 of 6 evidenced, 2 to do

Req 1: Network Security Controls12 of 19 evidenced, 7 to do

Req 11: Test Security Regularly13 of 21 evidenced, 8 to do

Req 12: Information Security Policies22 of 37 evidenced, 15 to do

Req 7: Restrict Access by Need to Know7 of 12 evidenced, 5 to do

Req 6: Secure Systems and Software11 of 19 evidenced, 8 to do

Req 10: Logging and Monitoring15 of 27 evidenced, 12 to do

Req 9: Restrict Physical Access13 of 26 evidenced, 13 to do

Req 5: Anti-Malware5 of 13 evidenced, 8 to do

Req 3: Protect Stored Account Data8 of 29 evidenced, 21 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.

SC-11.1.1argued against and upheld

NSC policies and procedures documented

Communications protection policy and procedures are documented, approved and reviewed on a cycle.

CM-61.2.1argued against and upheld

NSC configuration standards defined

Configuration settings establish and enforce the standard network devices must meet.

CM-31.2.2argued against and upheld

Changes to NSC reviewed and approved

Configuration change control reviews, approves and logs changes to network devices.

PL-81.2.3argued against and upheld

Network diagrams maintained

The security architecture documents the network design and its components.

AC-41.2.4argued against and upheld

Data flow diagram of account data

Information flow enforcement rests on documented flows of the protected data.

CM-7(1)1.2.5argued against and upheld

Services, protocols, ports inventoried and justified

Periodic review identifies the services and ports actually in use.

CM-71.2.5argued against and upheld

Services, protocols, ports inventoried and justified

Least functionality requires ports, protocols and services to be justified.

CM-7(1)1.2.7argued against and upheld

NSC rule sets reviewed every six months

Periodic review of functions, ports and services is the rule set review.

Claims that did not hold

92 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-71.4.2

Inbound traffic from untrusted networks restricted