PCI DSS 4.0FedRAMP Moderate

PCI DSS 4.0 covers 51.1% of FedRAMP Moderate

165 of the 323 controls in FedRAMP Moderate are already satisfied by evidence you collected for PCI DSS 4.0. 158 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.

51.1%

of the target already covered

165

controls evidenced

158

genuine gaps

346

claims rejected in review

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

628 candidate mappings were examined and 349 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.

SI - System and Information Integrity16 of 24 evidenced, 8 to do

AT - Awareness and Training4 of 6 evidenced, 2 to do

CA - Assessment, Authorization, and Monitoring9 of 14 evidenced, 5 to do

AU - Audit and Accountability10 of 16 evidenced, 6 to do

SC - System and Communications Protection18 of 29 evidenced, 11 to do

SA - System and Services Acquisition13 of 21 evidenced, 8 to do

CM - Configuration Management16 of 27 evidenced, 11 to do

SR - Supply Chain Risk Management7 of 12 evidenced, 5 to do

AC - Access Control24 of 43 evidenced, 19 to do

RA - Risk Assessment6 of 11 evidenced, 5 to do

PS - Personnel Security5 of 10 evidenced, 5 to do

MP - Media Protection3 of 7 evidenced, 4 to do

PL - Planning3 of 7 evidenced, 4 to do

IR - Incident Response7 of 17 evidenced, 10 to do

IA - Identification and Authentication11 of 27 evidenced, 16 to do

PE - Physical and Environmental Protection7 of 19 evidenced, 12 to do

CP - Contingency Planning5 of 23 evidenced, 18 to do

MA - Maintenance1 of 10 evidenced, 9 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.

8.1.1AC-1argued against and upheld

Policy and Procedures

Requires documented, current and communicated identification and authentication policies.

7.1.1AC-1argued against and upheld

Policy and Procedures

Requires documented, current and communicated access control policies and procedures.

8.2.8AC-11argued against and upheld

Device Lock

Idle sessions must require the user to re authenticate to reactivate.

8.4.3AC-17argued against and upheld

Remote Access

Remote access from outside the network must use multifactor authentication.

8.2.7AC-17argued against and upheld

Remote Access

Remote access accounts used by third parties must be managed and monitored.

2.2.7AC-17(2)argued against and upheld

Protection of Confidentiality and Integrity Using Encryption

Non console administrative access must be encrypted with strong cryptography.

11.2.1AC-18argued against and upheld

Wireless Access

Authorized and unauthorized wireless access points must be managed and tested for.

1.3.3AC-18argued against and upheld

Wireless Access

Network security controls must be installed between wireless networks and the environment.

Claims that did not hold

346 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.

12.1.1AC-1

Policy and Procedures