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
92
claims rejected in review

What this leaves you to do

PCI DSS 4.0 has 249 controls. Holding FedRAMP Moderate already evidences 138 of them, so the work in front of you is 111 controls, not 249, which is 45% 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 138 controls of PCI DSS 4.0 you do not have to implement again, which is $2.17 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 138 already evidenced are552 hours1,104 hours2,208 hours
and the 111 remaining are444 hours888 hours1,776 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 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.

AC-11.1.1
NSC policies and procedures documented

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 high confidence before it was rejected.

CA-11.1.1
NSC policies and procedures documented

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 high confidence before it was rejected.

AU-11.1.1
NSC policies and procedures documented

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 high confidence before it was rejected.

AT-11.1.1
NSC policies and procedures documented

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 high confidence before it was rejected.

SC-71.4.2
Inbound traffic from untrusted networks restricted

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.

SC-7(3)1.4.3
Anti-spoofing measures implemented

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.

SC-7(5)1.4.3
Anti-spoofing measures implemented

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.

AC-41.4.3
Anti-spoofing measures implemented

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.

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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