TheArtOfService
NIST SP 800-161 Rev 1Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1

NIST SP 800-161 Rev 1 covers 36.5% of Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1

72 of the 197 controls in Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1 are already satisfied by evidence you collected for NIST SP 800-161 Rev 1. 125 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.

36.5%
of the target already covered
72
controls evidenced
125
genuine gaps
0
claims rejected in review

What this leaves you to do

Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1 has 197 controls. Holding NIST SP 800-161 Rev 1 already evidences 72 of them, so the work in front of you is 125 controls, not 197, which is 63% 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 NIST SP 800-161 Rev 1 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.

183 candidate mappings were examined and 0 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.

CCC - Change Control & Configuration Management7 of 9 evidenced, 2 to do
DCS - Datacenter Security10 of 15 evidenced, 5 to do
STA - Supply Chain Management, Transparency & Accountability9 of 14 evidenced, 5 to do
SEF - Security Incident Management, E-Discovery & Cloud Forensics5 of 8 evidenced, 3 to do
AIS - Application & Interface Security4 of 7 evidenced, 3 to do
GRC - Governance, Risk & Compliance4 of 8 evidenced, 4 to do
A&A - Audit & Assurance3 of 6 evidenced, 3 to do
BCR - Business Continuity Management & Operational Resilience5 of 11 evidenced, 6 to do
DSP - Data Security & Privacy Lifecycle Management8 of 19 evidenced, 11 to do
TVM - Threat & Vulnerability Management4 of 10 evidenced, 6 to do
UEM - Universal Endpoint Management5 of 14 evidenced, 9 to do
IVS - Infrastructure & Virtualization Security3 of 9 evidenced, 6 to do
HRS - Human Resources Security4 of 13 evidenced, 9 to do
IPY - Interoperability & Portability1 of 4 evidenced, 3 to do
CEK - Cryptography, Encryption & Key Management0 of 21 evidenced, 21 to do
IAM - Identity & Access Management0 of 16 evidenced, 16 to do
LOG - Logging & Monitoring0 of 13 evidenced, 13 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.

CA-2CCM-A&A-02argued against and upheld
Independent Assessments

Independent control assessment rather than acceptance of a stated claim.

RA-3CCM-A&A-03argued against and upheld
Risk Based Planning Assessment

Documented risk assessment driving assessment scope and frequency.

PM-4CCM-A&A-06argued against and upheld
Remediation

Organizational process carrying weaknesses through to closure.

CA-5CCM-A&A-06argued against and upheld
Remediation

Tracks every finding to closure with named owners and due dates.

SA-17CCM-AIS-02argued against and upheld
Application Security Baseline Requirements

Requires developer architecture and design evidence against defined requirements.

SA-15CCM-AIS-04argued against and upheld
Secure Application Design and Development

Sets the development process, standards and tools delivered security rests on.

SA-8CCM-AIS-04argued against and upheld
Secure Application Design and Development

Applies security engineering principles to built and acquired components.

SA-3CCM-AIS-04argued against and upheld
Secure Application Design and Development

Security activities run at defined points across the development life cycle.

Claims that did not hold

Nothing proposed for this pair was rejected in review. That is unusual and worth knowing rather than hiding: it means the candidate set was small and every candidate held.

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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