NIST Cybersecurity Framework 2.0DORA

NIST Cybersecurity Framework 2.0 covers 50% of DORA

13 of the 26 controls in DORA are already satisfied by evidence you collected for NIST Cybersecurity Framework 2.0. 13 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.

50%
of the target already covered
13
controls evidenced
13
genuine gaps
2
claims rejected in review

What this leaves you to do

DORA has 26 controls. Holding NIST Cybersecurity Framework 2.0 already evidences 13 of them, so the work in front of you is 13 controls, not 26, which is 50% 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 13 controls of DORA you do not have to implement again, which is $23.00 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 13 already evidenced are52 hours104 hours208 hours
and the 13 remaining are52 hours104 hours208 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 DORA your NIST Cybersecurity Framework 2.0 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.

76 candidate mappings were examined and 2 were removed. Signed off 2026-08-20, 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.

DORA Chapter II: ICT Risk Management9 of 11 evidenced, 2 to do
DORA Chapters VI-VII: Information Sharing, Penalties and Data Protection1 of 3 evidenced, 2 to do
DORA Chapter III: ICT-Related Incident Management1 of 4 evidenced, 3 to do
DORA Chapter IV: Digital Operational Resilience Testing1 of 4 evidenced, 3 to do
DORA Chapter V: ICT Third-Party Risk Management1 of 4 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.

NIST-CSF-DE.AE-02DORA-Art.10argued against and upheld
Detection

Analysing potentially adverse events to understand associated activity is the detection process.

NIST-CSF-DE.CM-09DORA-Art.10argued against and upheld
Detection

Computing hardware and software monitored for adverse events adds a further detection layer.

NIST-CSF-DE.AE-08DORA-Art.10argued against and upheld
Detection

Declaring incidents when adverse events meet defined criteria is the alert threshold duty.

NIST-CSF-DE.CM-01DORA-Art.10argued against and upheld
Detection

Networks and network services monitored to find adverse events covers network performance detection.

NIST-CSF-ID.IM-04DORA-Art.11argued against and upheld
Response and recovery

Incident response and other plans established and maintained is the documented plan duty.

NIST-CSF-RS.MI-01DORA-Art.11argued against and upheld
Response and recovery

Containing incidents is the quickly contain damage duty.

NIST-CSF-RC.RP-01DORA-Art.11argued against and upheld
Response and recovery

Executing the recovery portion of the incident response plan is the recovery plan duty.

NIST-CSF-RC.RP-03DORA-Art.12argued against and upheld
Backup policies and procedures, restoration and recovery

Verifying backup integrity before restoration evidences backups restore with minimal disruption.

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.

NIST-CSF-RC.RP-04DORA-Art.11
Response and recovery

NIST CSF 2.0 RC.RP-04 held a different requirement when this was judged: establishing post-incident operational norms, not restoring critical functions to operational capability. Corrected against the issued core 2026-08-21.

Claimed at high confidence before it was rejected.

NIST-CSF-RS.AN-08DORA-Art.13
Learning and evolving

NIST CSF 2.0 RS.AN-08 held a different requirement when this was judged: estimating and validating an incident's magnitude, not root cause analysis. Corrected against the issued core 2026-08-21.

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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