NIST Cybersecurity Framework 2.0ISO 27701:2019

NIST Cybersecurity Framework 2.0 covers 47.2% of ISO 27701:2019

51 of the 108 controls in ISO 27701:2019 are already satisfied by evidence you collected for NIST Cybersecurity Framework 2.0. 57 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.

47.2%
of the target already covered
51
controls evidenced
57
genuine gaps
175
claims rejected in review

What this leaves you to do

ISO 27701:2019 has 108 controls. Holding NIST Cybersecurity Framework 2.0 already evidences 51 of them, so the work in front of you is 57 controls, not 108, which is 53% 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 51 controls of ISO 27701:2019 you do not have to implement again, which is $5.86 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 51 already evidenced are204 hours408 hours816 hours
and the 57 remaining are228 hours456 hours912 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 ISO 27701:2019 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.

253 candidate mappings were examined and 175 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.

PIMS-specific requirements related to ISO/IEC 27001, ISO 27701:201919 of 23 evidenced, 4 to do
PIMS-specific guidance related to ISO/IEC 27002, ISO 27701:201929 of 36 evidenced, 7 to do
Additional ISO/IEC 27002 guidance for PII controllers, ISO 27701:20192 of 31 evidenced, 29 to do
Additional ISO/IEC 27002 guidance for PII processors, ISO 27701:20191 of 18 evidenced, 17 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-GV.OC-015.2.1argued against and upheld
Understanding the organization and its context

Both require the organization to determine its role and operating context.

NIST-CSF-GV.OC-025.2.2argued against and upheld
Understanding the needs and expectations of interested parties

Both require internal and external interested parties to be identified and understood.

NIST-CSF-GV.RM-015.2.4argued against and upheld
Information security management system

Both require an established and continually maintained risk management system.

NIST-CSF-GV.RR-015.3.1argued against and upheld
Leadership and commitment

Both require leadership commitment demonstrated over the security system.

NIST-CSF-GV.PO-015.3.2argued against and upheld
Policy

Both require a policy established from organizational context and strategy.

NIST-CSF-GV.RR-025.3.3argued against and upheld
Organizational roles, responsibilities and authorities

Both require roles, responsibilities and authorities assigned and communicated.

NIST-CSF-ID.RA-065.4.1argued against and upheld
Actions to address risks and opportunities

Both require risk responses chosen, planned, tracked and communicated.

NIST-CSF-GV.RM-015.4.2argued against and upheld
Information security objectives and planning to achieve them

Both require risk management objectives established and agreed with plans to meet them.

Claims that did not hold

175 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-GV.OC-025.2
Context of the organization

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.

NIST-CSF-GV.OC-015.2
Context of the organization

Generated by the retired metered path, which was refuted at 56 percent wherever it was re-judged. Held back so an unreleased pair cannot be signed off on unreviewed mappings. Re-judge on the Max plan to revive.

Claimed at high confidence before it was rejected.

NIST-CSF-GV.OC-045.2
Context of the organization

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.

NIST-CSF-GV.OC-035.2
Context of the organization

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.

NIST-CSF-ID.AM-035.2.3
Determining the scope of the information security management system

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.

NIST-CSF-GV.OC-025.2.3
Determining the scope of the information security management system

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.

NIST-CSF-GV.OC-035.2.3
Determining the scope of the information security management system

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.

NIST-CSF-GV.OC-015.2.3
Determining the scope of the information security management system

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.

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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