NIST SP 800-172CMMC 2.0

NIST SP 800-172 covers 18.2% of CMMC 2.0

20 of the 110 controls in CMMC 2.0 are already satisfied by evidence you collected for NIST SP 800-172. 90 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.

18.2%
of the target already covered
20
controls evidenced
90
genuine gaps
9
claims rejected in review

This number is directional. It says how much of CMMC 2.0 your NIST SP 800-172 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.

57 candidate mappings were examined and 9 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.

Awareness and Training3 of 3 evidenced
Security Assessment3 of 4 evidenced, 1 to do
Personnel Security1 of 2 evidenced, 1 to do
System and Information Integrity3 of 7 evidenced, 4 to do
Configuration Management3 of 9 evidenced, 6 to do
Incident Response1 of 3 evidenced, 2 to do
Risk Assessment1 of 3 evidenced, 2 to do
Access Control3 of 22 evidenced, 19 to do
Audit and Accountability1 of 9 evidenced, 8 to do
Identification and Authentication1 of 11 evidenced, 10 to do
Maintenance0 of 6 evidenced, 6 to do
Media Protection0 of 9 evidenced, 9 to do
Physical Protection0 of 6 evidenced, 6 to do
System and Communications Protection0 of 16 evidenced, 16 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.

3.1.2eAC.L2-3.1.20argued against and upheld
External Connections

Restricting access to only organization owned, provisioned or issued resources controls external system connections.

3.1.3eAC.L2-3.1.3argued against and upheld
Control CUI Flow

Secure transfer solutions enforcing approved flows between security domains is CUI flow control.

3.1.1eAC.L2-3.1.4argued against and upheld
Separation of Duties

Dual authorization for critical operations divides security relevant duties between individuals.

3.2.1eAT.L2-3.2.1argued against and upheld
Role-Based Risk Awareness

Awareness training at hire, annually and on change makes staff aware of the risks their activities carry.

3.2.2eAT.L2-3.2.2argued against and upheld
Role-Based Training

Practical exercises for managers, executives and selected personnel reinforce role specific duties.

3.9.2eAT.L2-3.2.3argued against and upheld
Insider Threat Awareness

An insider threat program addressing adverse information about people with CUI access covers insider threat.

3.2.1eAT.L2-3.2.3argued against and upheld
Insider Threat Awareness

Awareness training covering social engineering and advanced threats teaches recognition of insider indicators.

3.11.3eAU.L2-3.3.5argued against and upheld
Audit Correlation

Advanced automation and analytics supporting analysts brings audit review and analysis together across sources.

Claims that did not hold

9 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.

3.13.2eAC.L2-3.1.5
Least Privilege

control identity corrected 2026-08-19: issued 3.13.2e is introducing unpredictability into operations; these mappings are least privilege and secure engineering, a subject that appears nowhere in the issued 800-172

Claimed at high confidence before it was rejected.

3.5.3eIA.L2-3.5.2
Authentication

corrected 2026-08-19: judged from a title claiming multifactor authentication, while the control carried 3.5.2e password-management text. Issued 800-172 3.5.3e is comply-to-connect: prohibit connection of unknown or unverified components. Authentication evidence does not satisfy it.

Claimed at high confidence before it was rejected.

3.5.3eIA.L2-3.5.3
Multifactor Authentication

corrected 2026-08-19: judged from a title claiming multifactor authentication, while the control carried 3.5.2e password-management text. Issued 800-172 3.5.3e is comply-to-connect: prohibit connection of unknown or unverified components. Authentication evidence does not satisfy it.

Claimed at high confidence before it was rejected.

3.13.1eSC.L2-3.13.1
Boundary Protection

control identity corrected 2026-08-19: issued 3.13.1e is component diversity to limit malicious code propagation; these mappings are boundary protection and segmentation, judged against 3.1.3e's content which this control was wrongly carrying

Claimed at high confidence before it was rejected.

3.13.3eSC.L2-3.13.2
Security Engineering

control identity corrected 2026-08-19: issued 3.13.3e is confusing and misleading adversaries; these mappings were judged against diversity content, which belongs to issued 3.13.1e

Claimed at high confidence before it was rejected.

3.13.2eSC.L2-3.13.2
Security Engineering

control identity corrected 2026-08-19: issued 3.13.2e is introducing unpredictability into operations; these mappings are least privilege and secure engineering, a subject that appears nowhere in the issued 800-172

Claimed at high confidence before it was rejected.

3.13.2eSC.L2-3.13.3
Role Separation

control identity corrected 2026-08-19: issued 3.13.2e is introducing unpredictability into operations; these mappings are least privilege and secure engineering, a subject that appears nowhere in the issued 800-172

Claimed at high confidence before it was rejected.

3.13.1eSC.L2-3.13.5
Public-Access System Separation

control identity corrected 2026-08-19: issued 3.13.1e is component diversity to limit malicious code propagation; these mappings are boundary protection and segmentation, judged against 3.1.3e's content which this control was wrongly carrying

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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