PCI DSS 4.0CMMC 2.0

PCI DSS 4.0 covers 61.8% of CMMC 2.0

68 of the 110 controls in CMMC 2.0 are already satisfied by evidence you collected for PCI DSS 4.0. 42 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.

61.8%
of the target already covered
68
controls evidenced
42
genuine gaps
115
claims rejected in review

This number is directional. It says how much of CMMC 2.0 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.

240 candidate mappings were examined and 115 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.

Incident Response3 of 3 evidenced
Personnel Security2 of 2 evidenced
Physical Protection5 of 6 evidenced, 1 to do
Identification and Authentication9 of 11 evidenced, 2 to do
Configuration Management7 of 9 evidenced, 2 to do
System and Information Integrity5 of 7 evidenced, 2 to do
Audit and Accountability6 of 9 evidenced, 3 to do
Awareness and Training2 of 3 evidenced, 1 to do
Risk Assessment2 of 3 evidenced, 1 to do
System and Communications Protection10 of 16 evidenced, 6 to do
Security Assessment2 of 4 evidenced, 2 to do
Access Control10 of 22 evidenced, 12 to do
Media Protection3 of 9 evidenced, 6 to do
Maintenance2 of 6 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.

8.2.1AC.L2-3.1.1argued against and upheld
Authorized Access Control

PCI assigns a unique ID to every user before any system access is allowed

7.3.1AC.L2-3.1.1argued against and upheld
Authorized Access Control

PCI access control system limits access to authorized users across all in-scope components

8.2.8AC.L2-3.1.10argued against and upheld
Session Lock

PCI requires re-authentication after fifteen minutes of session idle time

8.4.3AC.L2-3.1.12argued against and upheld
Control Remote Access

PCI requires multi-factor for all remote access originating outside the network

8.2.7AC.L2-3.1.12argued against and upheld
Control Remote Access

PCI manages and monitors third party accounts used for remote access and support

2.2.7AC.L2-3.1.13argued against and upheld
Remote Access Confidentiality

PCI encrypts all non-console administrative access using strong cryptography

11.2.2AC.L2-3.1.16argued against and upheld
Wireless Access Authorization

PCI maintains an inventory of authorized wireless access points with documented business justification

1.3.3AC.L2-3.1.16argued against and upheld
Wireless Access Authorization

PCI installs network controls between wireless networks and the environment denying unauthorized flows

Claims that did not hold

115 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.

4.2.1AC.L2-3.1.13
Remote Access Confidentiality

retired metered-API path. 56 percent of its output was refuted wherever it was re-judged, so its residue is not trusted evidence. Superseded by judgement on the Claude Max plan 2026-08-19.

Claimed at medium confidence before it was rejected.

8.6.1AC.L2-3.1.2
Transaction & Function Control

retired metered-API path. 56 percent of its output was refuted wherever it was re-judged, so its residue is not trusted evidence. Superseded by judgement on the Claude Max plan 2026-08-19.

Claimed at medium confidence before it was rejected.

7.2.6AC.L2-3.1.2
Transaction & Function Control

retired metered-API path. 56 percent of its output was refuted wherever it was re-judged, so its residue is not trusted evidence. Superseded by judgement on the Claude Max plan 2026-08-19.

Claimed at medium confidence before it was rejected.

7.2.5AC.L2-3.1.2
Transaction & Function Control

Held back 2026-08-19. Generated by the retired metered path, refuted at 56 percent wherever re-judged. Pair pulled from sale pending a rebuild on the Max plan.

Claimed at high confidence before it was rejected.

8.6.1AC.L2-3.1.4
Separation of Duties

retired metered-API path. 56 percent of its output was refuted wherever it was re-judged, so its residue is not trusted evidence. Superseded by judgement on the Claude Max plan 2026-08-19.

Claimed at medium confidence before it was rejected.

7.2.5AC.L2-3.1.4
Separation of Duties

Held back 2026-08-19. Generated by the retired metered path, refuted at 56 percent wherever re-judged. Pair pulled from sale pending a rebuild on the Max plan.

Claimed at high confidence before it was rejected.

7.2.5AC.L2-3.1.5
Least Privilege

Held back 2026-08-19. Generated by the retired metered path, refuted at 56 percent wherever re-judged. Pair pulled from sale pending a rebuild on the Max plan.

Claimed at high confidence before it was rejected.

7.2.5AC.L2-3.1.6
Non-Privileged Account Use

retired metered-API path. 56 percent of its output was refuted wherever it was re-judged, so its residue is not trusted evidence. Superseded by judgement on the Claude Max plan 2026-08-19.

Claimed at medium 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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