NIST SP 800-161 Rev 1NIST Cybersecurity Framework 2.0

NIST SP 800-161 Rev 1 covers 35.8% of NIST Cybersecurity Framework 2.0

38 of the 106 controls in NIST Cybersecurity Framework 2.0 are already satisfied by evidence you collected for NIST SP 800-161 Rev 1. 68 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.

35.8%
of the target already covered
38
controls evidenced
68
genuine gaps
7
claims rejected in review

What this leaves you to do

NIST Cybersecurity Framework 2.0 has 106 controls. Holding NIST SP 800-161 Rev 1 already evidences 38 of them, so the work in front of you is 68 controls, not 106, which is 64% 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 NIST Cybersecurity Framework 2.0 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.

165 candidate mappings were examined and 7 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.

ID - Identify13 of 21 evidenced, 8 to do
GV - Govern10 of 28 evidenced, 18 to do
PR - Protect7 of 22 evidenced, 15 to do
RS - Respond4 of 13 evidenced, 9 to do
DE - Detect3 of 11 evidenced, 8 to do
RC - Recover1 of 8 evidenced, 7 to do
Govern0 of 3 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.

SI-5NIST-CSF-DE.AE-07argued against and upheld
Cyber threat intelligence and other contextual information are integrated into the analysis

Advisories about acquired components provide the contextual information.

RA-10NIST-CSF-DE.AE-07argued against and upheld
Cyber threat intelligence and other contextual information are integrated into the analysis

Threat hunting integrates intelligence into active analysis rather than waiting.

PM-16NIST-CSF-DE.AE-07argued against and upheld
Cyber threat intelligence and other contextual information are integrated into the analysis

Threat awareness of actors targeting the supply chain feeds analysis.

SI-4NIST-CSF-DE.CM-06argued against and upheld
External service provider activities and services are monitored to find potentially adverse events

Monitors for behaviour indicating compromise arriving through delivered components.

CA-7NIST-CSF-DE.CM-06argued against and upheld
External service provider activities and services are monitored to find potentially adverse events

Continuously monitors supplier and provider risk rather than at fixed points.

AU-16NIST-CSF-DE.CM-06argued against and upheld
External service provider activities and services are monitored to find potentially adverse events

Cross organizational audit logging so activity spanning the boundary can be reconstructed.

AU-6NIST-CSF-DE.CM-06argued against and upheld
External service provider activities and services are monitored to find potentially adverse events

Reviews supply chain activity in logs for misuse of supplier access.

SI-7NIST-CSF-DE.CM-09argued against and upheld
Computing hardware and software, runtime environments, and their data are monitored to find potentially adverse events

Verifies software and firmware integrity before and after installation.

Claims that did not hold

7 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.

SR-6NIST-CSF-GV.SC-07
The risks posed by a supplier, their products and services, and other third parties are understood, recorded, prioritized, assessed, responded to, and monitored over the course of the relationship

NIST CSF 2.0 GV.SC-07 held a different requirement when this was judged: understanding, recording, prioritising and monitoring supplier risk, not verifying supply chain risk management. Corrected against the issued core 2026-08-21. A judgement made against different text is void whatever its outcome.

Claimed at high confidence before it was rejected.

PM-31NIST-CSF-GV.SC-07
The risks posed by a supplier, their products and services, and other third parties are understood, recorded, prioritized, assessed, responded to, and monitored over the course of the relationship

NIST CSF 2.0 GV.SC-07 held a different requirement when this was judged: understanding, recording, prioritising and monitoring supplier risk, not verifying supply chain risk management. Corrected against the issued core 2026-08-21. A judgement made against different text is void whatever its outcome.

Claimed at high confidence before it was rejected.

CA-7NIST-CSF-GV.SC-07
The risks posed by a supplier, their products and services, and other third parties are understood, recorded, prioritized, assessed, responded to, and monitored over the course of the relationship

NIST CSF 2.0 GV.SC-07 held a different requirement when this was judged: understanding, recording, prioritising and monitoring supplier risk, not verifying supply chain risk management. Corrected against the issued core 2026-08-21. A judgement made against different text is void whatever its outcome.

Claimed at high confidence before it was rejected.

CA-2NIST-CSF-GV.SC-07
The risks posed by a supplier, their products and services, and other third parties are understood, recorded, prioritized, assessed, responded to, and monitored over the course of the relationship

NIST CSF 2.0 GV.SC-07 held a different requirement when this was judged: understanding, recording, prioritising and monitoring supplier risk, not verifying supply chain risk management. Corrected against the issued core 2026-08-21. A judgement made against different text is void whatever its outcome.

Claimed at high confidence before it was rejected.

PM-6NIST-CSF-ID.RA-08
Processes for receiving, analyzing, and responding to vulnerability disclosures are established

NIST CSF 2.0 ID.RA-08 held a different requirement when this was judged: vulnerability disclosure processes, not effectiveness of risk responses. Corrected against the issued core 2026-08-21. A judgement made against different text is void whatever its outcome.

Claimed at medium confidence before it was rejected.

MA-6NIST-CSF-RC.RP-04
Critical mission functions and cybersecurity risk management are considered to establish post-incident operational norms

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. A judgement made against different text is void whatever its outcome.

Claimed at high confidence before it was rejected.

CP-2NIST-CSF-RC.RP-04
Critical mission functions and cybersecurity risk management are considered to establish post-incident operational norms

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. A judgement made against different text is void whatever its outcome.

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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