TheArtOfService
NIST SP 800-161 Rev 1PCI DSS 4.0

NIST SP 800-161 Rev 1 covers 15.7% of PCI DSS 4.0

39 of the 249 controls in PCI DSS 4.0 are already satisfied by evidence you collected for NIST SP 800-161 Rev 1. 210 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.

15.7%
of the target already covered
39
controls evidenced
210
genuine gaps
0
claims rejected in review

This number is directional. It says how much of PCI DSS 4.0 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.

112 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.

Req 6: Secure Systems and Software9 of 19 evidenced, 10 to do
Req 9: Restrict Physical Access12 of 26 evidenced, 14 to do
Req 2: Secure Configurations3 of 11 evidenced, 8 to do
Req 12: Information Security Policies10 of 37 evidenced, 27 to do
Req 5: Anti-Malware3 of 13 evidenced, 10 to do
Req 11: Test Security Regularly1 of 21 evidenced, 20 to do
Req 8: Identify and Authenticate Users1 of 29 evidenced, 28 to do
Req 1: Network Security Controls0 of 19 evidenced, 19 to do
Req 10: Logging and Monitoring0 of 27 evidenced, 27 to do
Req 3: Protect Stored Account Data0 of 29 evidenced, 29 to do
Req 4: Protect Cardholder Data in Transit0 of 6 evidenced, 6 to do
Req 7: Restrict Access by Need to Know0 of 12 evidenced, 12 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-711.5.2argued against and upheld
Change detection mechanism (FIM)

Software, firmware and information integrity verification is the change detection mechanism.

IR-812.10.1argued against and upheld
Incident response plan

Incident response plan covering roles, scenarios and notification paths.

IR-112.10.1argued against and upheld
Incident response plan

Incident response policy and procedures established in advance.

IR-212.10.4argued against and upheld
Incident responder training

Incident response training for the personnel who would have to act.

SA-2212.3.4argued against and upheld
Hardware and software technologies reviewed annually

Manages components the supplier no longer supports, which is the end of life check.

CM-812.3.4argued against and upheld
Hardware and software technologies reviewed annually

Component inventory carrying supplier and support status for the review.

PM-512.5.1argued against and upheld
Inventory of system components in scope

System inventory maintained in a form that supports scope and dependency questions.

PS-312.7.1argued against and upheld
Personnel screening

Personnel screening commensurate with the access the person will hold.

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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