NIST SP 800-172FedRAMP Moderate

NIST SP 800-172 covers 15.8% of FedRAMP Moderate

51 of the 323 controls in FedRAMP Moderate are already satisfied by evidence you collected for NIST SP 800-172. 272 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.

15.8%
of the target already covered
51
controls evidenced
272
genuine gaps
9
claims rejected in review

This number is directional. It says how much of FedRAMP Moderate 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.

90 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.

AT - Awareness and Training4 of 6 evidenced, 2 to do
SI - System and Information Integrity9 of 24 evidenced, 15 to do
CA - Assessment, Authorization, and Monitoring5 of 14 evidenced, 9 to do
CM - Configuration Management7 of 27 evidenced, 20 to do
SR - Supply Chain Risk Management3 of 12 evidenced, 9 to do
IR - Incident Response4 of 17 evidenced, 13 to do
PS - Personnel Security2 of 10 evidenced, 8 to do
RA - Risk Assessment2 of 11 evidenced, 9 to do
AC - Access Control7 of 43 evidenced, 36 to do
IA - Identification and Authentication4 of 27 evidenced, 23 to do
PL - Planning1 of 7 evidenced, 6 to do
AU - Audit and Accountability2 of 16 evidenced, 14 to do
SA - System and Services Acquisition1 of 21 evidenced, 20 to do
CP - Contingency Planning0 of 23 evidenced, 23 to do
MA - Maintenance0 of 10 evidenced, 10 to do
MP - Media Protection0 of 7 evidenced, 7 to do
PE - Physical and Environmental Protection0 of 19 evidenced, 19 to do
SC - System and Communications Protection0 of 29 evidenced, 29 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.

3.14.2eAC-2(12)argued against and upheld
Account Monitoring for Atypical Usage

Monitoring for anomalous or suspicious behaviour detects atypical account usage.

3.9.2eAC-2(13)argued against and upheld
Disable Accounts for High-Risk Individuals

Protecting systems when adverse information develops about an individual is disabling high-risk accounts.

3.1.2eAC-20argued against and upheld
Use of External Systems

Restricting access to only organization owned, provisioned or issued resources governs external system use.

3.1.2eAC-20(1)argued against and upheld
Limits on Authorized Use

Permitting only organization provisioned resources is the strictest form of limiting authorized use.

3.1.3eAC-4argued against and upheld
Information Flow Enforcement

Secure transfer solutions controlling flows between security domains is information flow enforcement.

3.1.3eAC-4(21)argued against and upheld
Physical or Logical Separation of Information Flows

Controlling flows between separated security domains is logical separation of information flows.

3.1.1eAC-5argued against and upheld
Separation of Duties

Dual authorization for critical operations prevents one individual completing a sensitive action alone.

3.2.1eAT-2argued against and upheld
Literacy Training and Awareness

Awareness training at hire, annually and on system change covering current threats is literacy training.

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-6
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-2
Identification and Authentication (Organizational Users)

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-2(1)
MFA to Privileged Accounts

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-2(2)
MFA to Non-Privileged Accounts

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.

3.13.2eSA-8
Security and Privacy Engineering Principles

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-7
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.

3.13.1eSC-7(3)
Access Points

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.

3.13.1eSC-7(5)
Deny by Default Allow by Exception

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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