PCI DSS 4.0NIST SP 800-172

PCI DSS 4.0 covers 42.9% of NIST SP 800-172

15 of the 35 controls in NIST SP 800-172 are already satisfied by evidence you collected for PCI DSS 4.0. 20 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.

42.9%
of the target already covered
15
controls evidenced
20
genuine gaps
4
claims rejected in review

This number is directional. It says how much of NIST SP 800-172 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.

77 candidate mappings were examined and 4 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.

IR2 of 2 evidenced
CA1 of 1 evidenced
SI4 of 7 evidenced, 3 to do
AT1 of 2 evidenced, 1 to do
PS1 of 2 evidenced, 1 to do
RA3 of 7 evidenced, 4 to do
AC1 of 3 evidenced, 2 to do
CM1 of 3 evidenced, 2 to do
IA1 of 3 evidenced, 2 to do
SC0 of 5 evidenced, 5 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.

1.4.13.1.3eargued against and upheld
Employ Secure Information Transfer Solutions

Network security controls implemented between trusted and untrusted networks control flows between domains.

12.3.23.11.4eargued against and upheld
Security Solution Rationale Document

Documenting the customised control, its objective and the risk determination is this requirement.

12.8.43.11.6eargued against and upheld
Supply Chain Risk Assessment, Response, and Monitoring

Monitoring provider compliance status at least annually is the continuing monitoring limb.

12.8.33.11.6eargued against and upheld
Supply Chain Risk Assessment, Response, and Monitoring

An established engagement process with due diligence is the supply chain risk assessment.

12.8.33.11.7eargued against and upheld
Supply Chain Risk Management Plan

A documented process for engaging providers with due diligence is the supply chain plan.

11.4.33.12.1eargued against and upheld
Penetration Testing by Independent Agents

External penetration testing at least annually completes the coverage.

11.4.23.12.1eargued against and upheld
Penetration Testing by Independent Agents

Internal penetration testing at least annually matches the required cadence.

11.4.13.12.1eargued against and upheld
Penetration Testing by Independent Agents

A documented penetration testing methodology with tester independence is this requirement.

Claims that did not hold

4 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.

1.4.13.13.1e
Create Diversity in System Components to Limit Malicious Code Propagation

control identity corrected 2026-08-19: issued 3.13.1e is component diversity to limit malicious code propagation; these mappings are boundary protection and segmentation, judged against 3.1.3e's content which this control was wrongly carrying

Claimed at high confidence before it was rejected.

1.3.13.13.1e
Create Diversity in System Components to Limit Malicious Code Propagation

control identity corrected 2026-08-19: issued 3.13.1e is component diversity to limit malicious code propagation; these mappings are boundary protection and segmentation, judged against 3.1.3e's content which this control was wrongly carrying

Claimed at high confidence before it was rejected.

7.2.23.13.2e
Introduce Unpredictability into System Operations

control identity corrected 2026-08-19: issued 3.13.2e is introducing unpredictability into operations; these mappings are least privilege and secure engineering, a subject that appears nowhere in the issued 800-172

Claimed at high confidence before it was rejected.

7.2.13.13.2e
Introduce Unpredictability into System Operations

control identity corrected 2026-08-19: issued 3.13.2e is introducing unpredictability into operations; these mappings are least privilege and secure engineering, a subject that appears nowhere in the issued 800-172

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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