PCI DSS 4.0Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1

PCI DSS 4.0 covers 60.4% of Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1

119 of the 197 controls in Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1 are already satisfied by evidence you collected for PCI DSS 4.0. 78 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.

60.4%
of the target already covered
119
controls evidenced
78
genuine gaps
1
claims rejected in review

What this leaves you to do

Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1 has 197 controls. Holding PCI DSS 4.0 already evidences 119 of them, so the work in front of you is 78 controls, not 197, which is 40% of the standard rather than all of it.

That is the whole claim. 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.

In money, using only our numbers. The full report is $299 and names 119 controls of Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1 you do not have to implement again, which is $2.51 per control identified. That arithmetic uses our price and our count and assumes nothing about you.

In your hours, using your assumption. We do not know what a control costs you to implement, so pick the column that looks like your organisation. These are your figures, not our claim.

If a control takes you4 hours8 hours16 hours
the 119 already evidenced are476 hours952 hours1,904 hours
and the 78 remaining are312 hours624 hours1,248 hours

Multiply by your own rate. We publish no rate because we have not measured yours, and a number built on an invented rate is the kind of claim this platform exists to argue against.

This number is directional. It says how much of Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1 your PCI DSS 4.0 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.

228 candidate mappings were examined and 1 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. This pair was additionally re-checked after CSA CCM v4.0.1 was rebuilt from the CAIQ v4.0.1 source on 2026-08-19: its mappings were originally judged when CCM carried no requirement text, a sample of 70 across the 21 CCM pairs found about 80 percent holding cleanly, and the two identified errors were corrected before release.

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.

IAM - Identity & Access Management14 of 16 evidenced, 2 to do
AIS - Application & Interface Security6 of 7 evidenced, 1 to do
LOG - Logging & Monitoring11 of 13 evidenced, 2 to do
A&A - Audit & Assurance5 of 6 evidenced, 1 to do
TVM - Threat & Vulnerability Management8 of 10 evidenced, 2 to do
IVS - Infrastructure & Virtualization Security7 of 9 evidenced, 2 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
DCS - Datacenter Security9 of 15 evidenced, 6 to do
UEM - Universal Endpoint Management8 of 14 evidenced, 6 to do
CCC - Change Control & Configuration Management5 of 9 evidenced, 4 to do
HRS - Human Resources Security7 of 13 evidenced, 6 to do
DSP - Data Security & Privacy Lifecycle Management10 of 19 evidenced, 9 to do
GRC - Governance, Risk & Compliance4 of 8 evidenced, 4 to do
CEK - Cryptography, Encryption & Key Management10 of 21 evidenced, 11 to do
BCR - Business Continuity Management & Operational Resilience1 of 11 evidenced, 10 to do
IPY - Interoperability & Portability0 of 4 evidenced, 4 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.

12.4.2CCM-A&A-01argued against and upheld
Audit and Assurance Policy and Procedures

Requires periodic reviews confirming personnel follow security policies and procedures.

11.4.3CCM-A&A-02argued against and upheld
Independent Assessments

External penetration testing must be performed by a qualified independent party.

11.3.2CCM-A&A-02argued against and upheld
Independent Assessments

External scanning must be performed by an approved vendor independent of the entity.

12.4.2CCM-A&A-04argued against and upheld
Requirements Compliance

Reviews must confirm ongoing compliance with the applicable requirements.

6.5.2CCM-A&A-04argued against and upheld
Requirements Compliance

Applicable requirements must be confirmed in place after each significant change.

12.4.2.1CCM-A&A-05argued against and upheld
Audit Management Process

Reviews must be documented with results, remediation and sign off.

11.4.4CCM-A&A-06argued against and upheld
Remediation

Findings must be corrected and testing repeated to verify the correction.

6.1.1CCM-AIS-01argued against and upheld
Application and Interface Security Policy and Procedures

Requires documented, current and communicated policies for secure software.

Claims that did not hold

1 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.

12.8.4CCM-STA-10
Supply Chain Agreement Review

re-pointed 2026-08-19: judged when CCM carried no requirement text, so it landed on the control whose title resembled the requirement rather than the control that carries it

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.

Buy this crosswalk