PCI DSS 4.0NIST SP 800-53 Rev 5

PCI DSS 4.0 covers 30% of NIST SP 800-53 Rev 5

90 of the 300 controls in NIST SP 800-53 Rev 5 are already satisfied by evidence you collected for PCI DSS 4.0. 210 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.

30%
of the target already covered
90
controls evidenced
210
genuine gaps
281
claims rejected in review

What this leaves you to do

NIST SP 800-53 Rev 5 has 300 controls. Holding PCI DSS 4.0 already evidences 90 of them, so the work in front of you is 210 controls, not 300, which is 70% of the standard rather than all of it.

That is the whole claim. We do not know your hourly rate, how long a control takes you, or how many people you have, so there is no figure here in dollars or weeks. Every number in that sentence comes from the two counts above it and can be re-derived from the free tools without taking our word for any of it.

This number is directional. It says how much of NIST SP 800-53 Rev 5 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.

474 candidate mappings were examined and 281 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.

IR - Incident Response7 of 9 evidenced, 2 to do
CM - Configuration Management9 of 14 evidenced, 5 to do
AT - Awareness and Training3 of 5 evidenced, 2 to do
AU - Audit and Accountability8 of 15 evidenced, 7 to do
MP - Media Protection4 of 8 evidenced, 4 to do
SA - System and Services Acquisition7 of 17 evidenced, 10 to do
AC - Access Control9 of 23 evidenced, 14 to do
IA - Identification and Authentication5 of 13 evidenced, 8 to do
SI - System and Information Integrity8 of 22 evidenced, 14 to do
PS - Personnel Security3 of 9 evidenced, 6 to do
SR - Supply Chain Risk Management3 of 12 evidenced, 9 to do
CA - Assessment, Authorization, and Monitoring2 of 8 evidenced, 6 to do
PL - Planning2 of 8 evidenced, 6 to do
PE - Physical and Environmental Protection5 of 22 evidenced, 17 to do
RA - Risk Assessment2 of 9 evidenced, 7 to do
SC - System and Communications Protection9 of 47 evidenced, 38 to do
MA - Maintenance1 of 7 evidenced, 6 to do
PM - Program Management3 of 32 evidenced, 29 to do
CP - Contingency Planning0 of 12 evidenced, 12 to do
PT - PII Processing and Transparency0 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.

12.1.1NIST800-AC-1argued against and upheld
Access control policy and procedures

PCI overall security policy is established, published, maintained and disseminated

7.1.1NIST800-AC-1argued against and upheld
Access control policy and procedures

PCI requires access control policies and operational procedures be documented, current and known

8.2.8NIST800-AC-11argued against and upheld
Device lock

PCI requires re-authentication after fifteen minutes of session inactivity

8.4.3NIST800-AC-17argued against and upheld
Remote access

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

8.2.7NIST800-AC-17argued against and upheld
Remote access

PCI manages and monitors third party remote access to system components

2.2.7NIST800-AC-17argued against and upheld
Remote access

PCI encrypts all non-console administrative access with strong cryptography

11.2.1NIST800-AC-18argued against and upheld
Wireless access

PCI tests quarterly for unauthorized wireless access points

4.2.1.2NIST800-AC-18argued against and upheld
Wireless access

PCI requires strong cryptography for wireless authentication and transmission

Claims that did not hold

281 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.

7.1.2NIST800-AC-1
Access control policy and procedures

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.

7.2.5NIST800-AC-2
Account management

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.

7.2.5NIST800-AC-3
Access enforcement

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.

1.4.2NIST800-AC-4
Information flow enforcement

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.

7.2.4NIST800-AC-5
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.

7.2.5NIST800-AC-5
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.

12.6.3NIST800-AT-1
Policy and procedures for awareness and training

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.

12.6.3NIST800-AT-4
Training records

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.

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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