ISO 22301:2019Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1

ISO 22301:2019 covers 9.6% of Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1

19 of the 197 controls in Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1 are already satisfied by evidence you collected for ISO 22301:2019. 178 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.

9.6%
of the target already covered
19
controls evidenced
178
genuine gaps
2
claims rejected in review

What this leaves you to do

Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1 has 197 controls. Holding ISO 22301:2019 already evidences 19 of them, so the work in front of you is 178 controls, not 197, which is 90% of the standard rather than all of it.

That is the whole claim. We do not know your hourly rate, how long a control takes you, or how many people you have, so there is no figure here in dollars or weeks. 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.

This number is directional. It says how much of Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1 your ISO 22301:2019 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.

43 candidate mappings were examined and 2 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. This pair was additionally re-checked after CSA CCM v4.0.1 was rebuilt from the CAIQ v4.0.1 source on 2026-08-19: its mappings were originally judged when CCM carried no requirement text, a sample of 70 across the 21 CCM pairs found about 80 percent holding cleanly, and the two identified errors were corrected before release.

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.

A&A - Audit & Assurance5 of 6 evidenced, 1 to do
BCR - Business Continuity Management & Operational Resilience9 of 11 evidenced, 2 to do
GRC - Governance, Risk & Compliance2 of 8 evidenced, 6 to do
HRS - Human Resources Security2 of 13 evidenced, 11 to do
SEF - Security Incident Management, E-Discovery & Cloud Forensics1 of 8 evidenced, 7 to do
AIS - Application & Interface Security0 of 7 evidenced, 7 to do
CCC - Change Control & Configuration Management0 of 9 evidenced, 9 to do
CEK - Cryptography, Encryption & Key Management0 of 21 evidenced, 21 to do
DCS - Datacenter Security0 of 15 evidenced, 15 to do
DSP - Data Security & Privacy Lifecycle Management0 of 19 evidenced, 19 to do
IAM - Identity & Access Management0 of 16 evidenced, 16 to do
IPY - Interoperability & Portability0 of 4 evidenced, 4 to do
IVS - Infrastructure & Virtualization Security0 of 9 evidenced, 9 to do
LOG - Logging & Monitoring0 of 13 evidenced, 13 to do
STA - Supply Chain Management, Transparency & Accountability0 of 14 evidenced, 14 to do
TVM - Threat & Vulnerability Management0 of 10 evidenced, 10 to do
UEM - Universal Endpoint Management0 of 14 evidenced, 14 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.

9.2.2CCM-A&A-01argued against and upheld
Audit and Assurance Policy and Procedures

Establishing and maintaining an audit programme is the audit policy and procedure.

9.2.2CCM-A&A-03argued against and upheld
Risk Based Planning Assessment

The audit programme must consider the importance of the processes concerned.

4.2.2CCM-A&A-04argued against and upheld
Requirements Compliance

Legal and regulatory requirements must be identified, documented and kept current.

9.2.2CCM-A&A-05argued against and upheld
Audit Management Process

Audit planning, reporting and retained results are the audit management process.

10.1CCM-A&A-06argued against and upheld
Remediation

Corrective action on nonconformities, with evidence of actions and results, is what a remediation plan requires.

5.2.2CCM-BCR-01argued against and upheld
Business Continuity Management Policy and Procedures

The policy must be communicated within the organization and to interested parties.

5.2.1CCM-BCR-01argued against and upheld
Business Continuity Management Policy and Procedures

An established, approved and maintained business continuity policy is this control.

8.2.2CCM-BCR-02argued against and upheld
Risk Assessment and Impact Analysis

Business impact analysis determines the impact of disruption over time on activities.

Claims that did not hold

2 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.

10.2CCM-A&A-06
Remediation

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

Claimed at high confidence before it was rejected.

6.1.2CCM-BCR-02
Risk Assessment and Impact Analysis

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

Claimed at medium 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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