PCI DSS 4.0 covers 29.6% of ISO 27701:2019
32 of the 108 controls in ISO 27701:2019 are already satisfied by evidence you collected for PCI DSS 4.0. 76 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.
This number is directional. It says how much of ISO 27701:2019 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.
257 candidate mappings were examined and 125 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.
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.
Network security controls between trusted and untrusted networks is the network control limb.
Controls implemented between trusted and untrusted networks is segregation in networks.
Defined and maintained configuration standards for network security controls is network security management.
Securing data whenever sent via end user messaging technologies covers the other transfer channel.
Strong cryptography safeguarding data during transmission over open public networks is information transfer.
Developing bespoke and custom software securely to industry standards is this clause.
Defined engineering techniques preventing common attacks is security built into development.
Secure development based on industry standards is the security requirements specification.
Claims that did not hold
125 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.
Generated by the retired metered path, which was refuted at 56 percent wherever it was re-judged. Held back so an unreleased pair cannot be signed off on unreviewed mappings. Re-judge on the Max plan to revive.
Claimed at high confidence before it was rejected.
Generated by the retired metered path, which was refuted at 56 percent wherever it was re-judged. Held back so an unreleased pair cannot be signed off on unreviewed mappings. Re-judge on the Max plan to revive.
Claimed at high confidence before it was rejected.
Generated by the retired metered path, which was refuted at 56 percent wherever it was re-judged. Held back so an unreleased pair cannot be signed off on unreviewed mappings. Re-judge on the Max plan to revive.
Claimed at high confidence before it was rejected.
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.
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.
Generated by the retired metered path, which was refuted at 56 percent wherever it was re-judged. Held back so an unreleased pair cannot be signed off on unreviewed mappings. Re-judge on the Max plan to revive.
Claimed at high confidence before it was rejected.
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.
Generated by the retired metered path, which was refuted at 56 percent wherever it was re-judged. Held back so an unreleased pair cannot be signed off on unreviewed mappings. Re-judge on the Max plan to revive.
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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