PCI DSS 4.0NIST Cybersecurity Framework 2.0

PCI DSS 4.0 covers 45.3% of NIST Cybersecurity Framework 2.0

48 of the 106 controls in NIST Cybersecurity Framework 2.0 are already satisfied by evidence you collected for PCI DSS 4.0. 58 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.

45.3%
of the target already covered
48
controls evidenced
58
genuine gaps
82
claims rejected in review

This number is directional. It says how much of NIST Cybersecurity Framework 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.

178 candidate mappings were examined and 82 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.

ID - Identify14 of 21 evidenced, 7 to do
PR - Protect14 of 22 evidenced, 8 to do
DE - Detect7 of 11 evidenced, 4 to do
GV - Govern9 of 28 evidenced, 19 to do
RS - Respond4 of 13 evidenced, 9 to do
Govern0 of 3 evidenced, 3 to do
RC - Recover0 of 8 evidenced, 8 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.

10.4.3NIST-CSF-DE.AE-02argued against and upheld
Potentially adverse events are analyzed to better understand associated activities

PCI requires exceptions and anomalies found in review be investigated and addressed

10.4.1NIST-CSF-DE.AE-02argued against and upheld
Potentially adverse events are analyzed to better understand associated activities

PCI reviews security event logs at least daily to understand what happened

10.4.1.1NIST-CSF-DE.AE-03argued against and upheld
Information is correlated from multiple sources

PCI uses automated mechanisms to review and correlate logs across components

10.3.3NIST-CSF-DE.AE-03argued against and upheld
Information is correlated from multiple sources

PCI centralizes logs from all components onto a secure internal log server

11.5.1NIST-CSF-DE.CM-01argued against and upheld
Networks and network services are monitored to find potentially adverse events

PCI monitors all traffic at the perimeter and critical points with intrusion detection

9.2.1.1NIST-CSF-DE.CM-02argued against and upheld
The physical environment is monitored to find potentially adverse events

PCI monitors entry and exit of sensitive physical areas and reviews the recorded data

10.2.1.2NIST-CSF-DE.CM-03argued against and upheld
Personnel activity and technology usage are monitored to find potentially adverse events

PCI logs all administrative actions including interactive use of system accounts

10.2.1.1NIST-CSF-DE.CM-03argued against and upheld
Personnel activity and technology usage are monitored to find potentially adverse events

PCI logs every individual user access to protected data

Claims that did not hold

82 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.

10.4.1NIST-CSF-DE.AE-06
Information on adverse events is provided to authorized staff

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.

10.7.3NIST-CSF-DE.AE-06
Information on adverse events is provided to authorized staff

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.

10.7.1NIST-CSF-DE.AE-06
Information on adverse events is provided to authorized staff

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.

12.5.2NIST-CSF-GV.OC-03
Legal, regulatory, and contractual requirements are understood

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.

12.8.2NIST-CSF-GV.OC-03
Legal, regulatory, and contractual requirements are understood

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.

12.4.2NIST-CSF-GV.OC-03
Legal, regulatory, and contractual requirements are understood

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 low confidence before it was rejected.

12.1.2NIST-CSF-GV.OV-01
Risk management strategy outcomes are reviewed

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.

12.4.2NIST-CSF-GV.OV-01
Risk management strategy outcomes are reviewed

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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