SystemIT/OT Security & Compliance

Compliance Control Mapping

Compliance control mapping for utilities: one control, every framework it meets, tested once

Test once, comply with every framework.

See one case, screen by screen ↓
demo11gapsfound in 762 requirements across five frameworks before the audit season, each with a proposed fix, an owner and the person who decides
estimated$1.1Ma year of duplicate control testing avoided: 398 tests × about 22 hours × $125 an hour
demo214testsfor the season, one per control, in place of last season's 612, each with the strictest auditor's sample
demo2daysto map the water cyber rule's new amendment, against 11 weeks for the last NIST CSF re-map by hand
The problem

Why the same control is tested four times a year

A utility that runs a grid and a water system answers to several security frameworks at once: NERC CIP for its bulk electric system, IEC 62443 for its industrial control systems, NIST CSF as the board's yardstick, ISO/IEC 27001 for its certified IT, and a state rule for its water side. They ask for the same things in different words. “Change passwords every 15 calendar months”, “Strength of password-based authentication”, “Identities and credentials are managed” and “Authentication information” all land on one password control.

Yet each audit tests that control again, with its own sample, its own evidence request and its own spreadsheet. At Lumina Utilities, the sample utility in the working solution, four audit programmes ran 612 control tests on 214 controls last season, and the password control alone was tested four times. The mapping lives in a spreadsheet that ages with every new version: the last NIST CSF re-map took 11 weeks with consultants. And a requirement no one mapped to a control stays invisible until an auditor samples it. Under CIP that is a possible violation; under ISO, a nonconformity against the certificate.

typical$10Mpenalty in one NERC CIP settlement that covered 127 violations
demo612testsrun last season on 214 controls for four audit programmes, the password control four times
demo11weeksto re-map NIST CSF 2.0 by hand with consultants
Where the GRC team's working days go before an audit seasonestimated
By hand112 days
With the solution11 days
  • Re-mapping a new framework version into the crosswalk55 → 2 d
  • Checking each control's evidence against each framework's wording20 → 3 d
  • Finding requirements with partial coverage or no control10 → 1 d
  • Collecting the same evidence again for each auditor15 → 3 d
  • Building a separate test plan and sample for each programme12 → 2 d

Estimated split for one control library and one audit season, in working days, by hand and with the solution. The re-mapping row uses the working solution's own figures: 11 weeks for the last CSF re-map by hand, 2 days for the water rule amendment with agents.

How it works

How a control is mapped and tested once

Six agents read the frameworks, map every control, check the evidence and plan one test per control; the GRC lead confirms every link.

What comes in
Sources in5 frameworks · texts, controls, evidence
Agents at work
Framework reader762 requirements
Change watchernew versions
Then
Crosswalk mapperlinks quote both texts
Then
Evidence matcher
Gap finder
Then
Test plannerone test per control
A person decides
Head of GRC and internal auditconfirm links, sign the plan
What comes out
Unified control matrix
Coverage heatmap
One test per control
One case, step by step

One password control, from four tests to one

Tuesday 13 October 2026 at Lumina Utilities. The audit season is close: ISO 27001 surveillance in November, the IEC 62443 assessment of the Halden Ridge water SCADA in December, the water cyber attestation due 31 December, and the NERC CIP audit on site 18–29 January 2027. Here is what happens to one control, screen by screen, in the working solution.

  1. 01Morning

    The crosswalk opens on the password control

    Rhea Castellanos · Head of Cyber GRC

    Rhea owns Lumina's library of 214 controls. Overnight, from 02:10 to 02:31, the agents checked the library against 762 requirements in five frameworks. LUC-IAM-04, password and shared-account management, owned by Sanjay Rao, sits at the centre of the web, linked to 7 requirements in 4 frameworks: three in NERC CIP, two in IEC 62443, one each in NIST CSF and ISO 27001. One link is waiting for her.

    “tested once · was 4” · Owner Sanjay Rao · Identity and access · quarterly

  2. 0202:22

    One link re-proposed, with both texts side by side

    Crosswalk mapper

    The framework reader found that the ISO 27001 Statement of Applicability v2026.2 reworded three controls, so the crosswalk mapper proposed the ISO 27001 A.5.17 link again. Rhea clicks the node and reads the requirement and Lumina's control side by side, with the mapper's reason and the evidence against the requirement: the vault workflow's issue, reset and rotation procedure, on page 5.

    Why they match, full: “The Annex A control asks for a management process for authentication information; the control’s vault workflow is that process.”

  3. 03One click

    Rhea confirms the link

    Rhea Castellanos · Head of Cyber GRC

    Nothing counts toward coverage until a person confirms it. Rhea confirms the link, and it is recorded under her name; she can still challenge it later. The other links waiting for her across the library stay in her queue.

    “ISO 27001 A.5.17 confirmed · 26 links still waiting across the library”

  4. 04Trace the evidence

    One report meets all seven requirements

    Evidence matcher

    Rhea presses Trace the evidence. EV-2026-0912, the Keystone Vault password policy and rotation report for 1 Jul–30 Sep 2026, runs out along every link, and each requirement's own parameter is ticked as it lands: length 14 against CIP's 8 with three character types, the oldest password 11 months against 15, lockout after 5 tries with an alert, 23 default accounts changed, 1,284 accounts managed.

    “One evidence item, 7 requirements, 4 frameworks · collected once”

  5. 05Page by page

    Every passage tied to the requirement it satisfies

    Evidence matcher

    In the evidence view, the report's passages carry margin notes. The 37 local accounts on Calder Electric CR-400 relays at six substations support at most 6 characters; they are set to the device maximum under technical feasibility exception TFE-2024-031, which CIP-007-6 R5.5 allows. Of 1,906 evidence items this cycle, 683 satisfy requirements in two or more frameworks, so they are collected once.

    CIP-007-6 R5.5: “or the maximum the Cyber Asset supports”, TFE on file

  6. 06The whole library

    Eleven gaps, before the auditor finds them

    Gap finder

    The coverage heatmap shows every family of every framework, sized by its requirements and coloured by how well Lumina's controls cover it: 751 of 762 requirements fully covered, 7 partial and 4 with no control. IEC 62443 FR 1 shows 42 of 44, with SR 1.11 partial and SR 1.13 without a control. The overlap grid shows why testing once works: 179 controls serve both NERC CIP and ISO 27001.

    “751 of 762 requirements fully covered · 7 partial · 4 no control”

  7. 07Before 7 Dec

    A compensating control, accepted with an end date

    Daniel Mwangi · CISO

    Gap G-04: the 14 HMI workstations in the Halden Ridge control room alert the SOC after 5 failed logins but do not lock out, because a locked HMI mid-shift would leave the operator blind to the filters and dosing. Elif Demir, the control owner, proposes LUC-IAM-11c: alert on 5 failures in 10 minutes, the SOC calls the shift supervisor within 15 minutes, and lockout comes with the HMI upgrade in March 2027. Daniel accepts it until 31 March 2027.

    “Accepted until 31 Mar 2027 · Daniel Mwangi · on the audit trail”

  8. 0802:31

    One test per control, with the strictest sample

    Test planner

    The test planner merges every programme's test of the same control: 214 tests this season, not 612, feeding 426 audit samples across five programmes, with testing from 19 Oct to 13 Nov. T-IAM-04 takes a sample of 60 accounts for 1 Jul–30 Sep 2026 and feeds NERC CIP, IEC 62443, NIST CSF and ISO 27001.

    “398 duplicate tests avoided · $1.1M a year, estimated · 398 × 22 h × $125”

  9. 09Sent to sign

    The plan goes to internal audit

    Rhea Castellanos · Head of Cyber GRC

    Rhea sends the season's plan to Hugo Lindqvist with a note: samples are set to the strictest auditor for each control, and LUC-IAM-04 uses 60 accounts for CIP-007 R5 and the 62443 assessment.

    “Signed plans cannot be changed, only revised.”

  10. 10Signed

    One signed plan for the season

    Hugo Lindqvist · Internal Audit Manager, IT/OT

    Hugo signs plan v1. Testing runs from 19 October to 13 November, and each control is tested once for every programme it feeds: the ISO 27001 surveillance audit, the IEC 62443 assessment, the water cyber attestation, the NERC CIP audit and the CSF self-assessment.

    “Hugo Lindqvist signed the plan · 214 tests, testing starts 19 Oct”

Who it’s for

Built for everyone who answers an auditor.

The same control, seen by the five people who map it, own it, test it and decide its gaps — what their season looked like, and what it looks like now.

RC
Rhea CastellanosHead of Cyber GRC · owns the control library, confirms links, approves new framework versions
Head of Cyber GRC
Before
Owns 214 controls and four audits this season, each with its own spreadsheet. “I have one password control. Four auditors test it four times and ask for it four ways.”
Now
Opens each control at the centre of its web, reads both texts for every link and confirms the ones waiting for her in the morning.
DM
Daniel MwangiCISO · reports cyber risk to the board, accepts or rejects risk on gaps
CISO
Before
Hears about uncovered requirements when an auditor samples them. “Show me the requirements nothing covers. Not the ones everything covers.”
Now
Gets each gap with what is missing, the proposed fix, the owner and the audit at risk, and decides it with an expiry date.
HL
Hugo LindqvistInternal Audit Manager, IT/OT · plans and signs the control tests, owns the sample sizes
Internal audit
Before
Plans a test, a sample and an evidence request for each programme. “If one sample satisfies the strictest auditor, it satisfies them all. Prove it to me.”
Now
Signs one plan for the season, with each test's programmes, sample and period on one line.
SR
Sanjay RaoIdentity and Access Lead · owns 22 controls and the privileged access vault
Control owner
Before
Exports the vault rotation report once a quarter, then sends it to every auditor. “I produced the rotation report once. Why am I emailing it four times?”
Now
Attests the report once and sees each passage tied to the requirements it satisfies, in every framework.
ED
Elif DemirOT Security Engineer, water · owns the Halden Ridge treatment works SCADA controls
OT security, water
Before
Carries IEC 62443 findings that do not fit an operating control room. “The HMIs alert on failed logins. They cannot lock out an operator mid-shift.”
Now
Proposes a compensating control on the gap itself, with the work order and the date the HMI upgrade closes it.
Built on the engine

6 agents. Each with one job, and hard limits.

Six agents read the frameworks, map every control, check the evidence and plan one test per control; the GRC lead confirms every link.

Framework reader

Reads each framework's text and version into atomic requirements with their parameters: lengths, clocks, counts and scope.

  • Keeps the verbatim text and clause; never paraphrases a requirement
  • Versions are kept, never overwritten
Crosswalk mapper

Proposes each control-to-requirement link with a strength, full or partial, and a reason that quotes both texts. Full only when every parameter is met.

  • Proposes only; a person confirms every new link
  • Quotes both texts in every reason
Evidence matcher

Reads each evidence item against every linked requirement's parameters, period and scope, and marks the passages in the margin with page and passage.

  • Never edits evidence
  • Never accepts evidence outside the audit period; flags evidence older than the maximum age
Gap finder

Finds requirements with no control or only partial coverage, and drafts each gap with a proposed fix, owner and due date before the audit that tests it.

  • Never closes a gap
  • Risk acceptance only by the CISO
Test planner

Builds one test per control with the sample size and period of the strictest auditor among the audits it feeds, scheduled before the first audit.

  • Never lowers a sample below any auditor's minimum
  • Internal audit signs the plan
Change watcher

Checks the publishers of the five frameworks every night, compares a new version or amendment clause by clause with the one in force and queues the changed requirements for re-mapping.

  • Never retires a requirement still in an active audit period
Head of GRC, internal audit, CISO

Confirm, sign, accept risk. The agents propose; a named person decides.

Ask in plain words

Ask about any control, requirement or gap

Ask about any control, requirement, evidence item or gap, or say what to change. Each answer opens the screen it comes from.

What does the password control satisfy?

LUC-IAM-04 satisfies 7 requirements across 4 frameworks: CIP-007-6 R5.5, R5.6 and R5.7, IEC 62443-3-3 SR 1.5 and SR 1.7, NIST CSF PR.AA-01 and ISO 27001 A.5.17. One evidence item, EV-2026-0912, the Keystone Vault rotation report, meets every parameter: length 14 against 8, oldest password 11 months against 15. The ISO link is waiting for you: the 2026 Statement of Applicability reworded the control.

What would the CIP auditor find today?

Three CIP requirements are not fully covered, and Meridian Reliability Council is on site 18–29 Jan: CIP-003-9 Att. 1 Sec. 6, no control yet for vendor remote access at the 19 low-impact substations; CIP-013-2 R1.2.5, relay firmware arrives without a published hash; CIP-010-4 R1.6, the software source is not recorded for 6 gateway changes.

Why is SR 1.11 only partial at Halden Ridge?

The 14 HMI workstations in the Halden Ridge control room alert after 5 failed logins but do not lock out: a locked HMI mid-shift would leave the operator blind to filters and dosing. Elif Demir proposes a compensating control until the HMI upgrade in March 2027. It needs Daniel Mwangi's decision before the Ardent Assurance assessment on 7 Dec.

How much testing does one plan save?

Last season Lumina ran 612 control tests for four programmes; this season the plan has 214, one per control. That is 398 tests avoided, an estimated $1.1M a year at about 22 hours and $125 an hour per test. Each test uses the strictest sample of the audits it feeds.

Every screen

The working solution, as it ships.

13 screens from the working solution, on its sample data. Pick one to see it large.

The crosswalk webOne control at the centre, linked to every requirement it satisfies in the five frameworks around it, with its evidence item, last season's four tests and the overnight agent run.
Both texts, side by sideThe requirement and the control in their own words, the mapper's reason and the evidence, for the one link waiting to be confirmed.
A link confirmedConfirmed by the Head of Cyber GRC, recorded under her name and still open to challenge.
One evidence item, seven requirementsThe vault rotation report traced out along every link, each requirement's parameter ticked as it lands.
Evidence reuseThe most reused evidence items, and the report with a margin note tying each passage to the requirement it satisfies.
The unified control matrix214 controls down the side, five frameworks across, each cell holding the requirements the control satisfies there.
The coverage heatmapEvery family of every framework coloured by coverage, the 11 gaps marked, and where the frameworks overlap.
Gaps and decisionsEach gap with the requirement, what is missing, the proposed fix, the owner, the due date and the CISO's decision.
One test plan for the season612 tests last season, 214 this season, the audit calendar and each test with the programmes it feeds, its sample and period.
Send the plan to signThe plan goes to internal audit with a note on the samples; signed plans can only be revised.
Signed by internal auditPlan v1 signed by the Internal Audit Manager, IT/OT, with testing starting on 19 October.
Frameworks and the change watchCoverage for each framework, the version in force, the next audit, and the water rule amendment mapped in 2 days.
Your rulesMapping rules, evidence age and sample size, who decides, and the sources the evidence comes from.
Governance

Built to stand up to every auditor: quoted, confirmed, signed.

Every link quotes both textsEach link carries the requirement's verbatim text and clause, Lumina's control text and the mapper's reason. Every evidence check cites the page and passage of the evidence.
A person confirms every linkThe agents propose; nothing counts toward coverage until the Head of Cyber GRC confirms it. This rule is locked in settings, and a confirmed link can still be challenged.
Risk accepted only by the CISO, with an end dateThe gap finder never closes a gap. A compensating control or accepted risk needs the CISO's decision, with an expiry date, never open-ended.
Internal audit signs the planThe season's test plan is signed by the Internal Audit Manager, IT/OT, before testing starts. Signed plans cannot be changed, only revised, so testing stays independent.
Agents never edit evidence or lower a sampleThe agents read, propose and draft. They never edit evidence, confirm a link, lower a sample below any auditor's minimum or accept risk.
Every step on the audit trailEach agent proposal and each human decision is recorded with its time and who made it. Framework versions are kept, never overwritten, and every settings change is saved as a new version.
Configuration

Your audit rules, not ours

Mapping, evidence and test rules, and who decides, are settings. Every change is saved as a new version.

SettingDefaultChoose from
A person confirms every new linkOn, lockedAlways on: agents propose, nothing counts toward coverage until confirmed
Full only when every parameter is metOnOn · Off — a link that meets the outcome but not a number (length, days, count) is partial
Partial links count as gapsOnOn · Off — they appear on the heatmap and in Gaps until fixed or accepted
Re-map overnightOnOn · Off — every night at 02:10, and within an hour of a new framework version
Maximum evidence age92 daysSet in days, for quarterly controls
Sample size60Set in steps of 5; the strictest auditor's rule, at least 25 or 10% of the population
One test per control per seasonOnOn · Off — the test planner merges every programme's test of the same control
Security level target, IEC 62443SL2SL2 · SL3, for the water SCADA zones
Connections

Works with the frameworks, controls and evidence you already keep

Framework textsNERC CIP, IEC 62443, NIST CSF 2.0, ISO/IEC 27001:2022 and the state water cyber rule, with every version kept
Control libraryyour controls with owner, frequency, procedure text and standards
Privileged access vault and identity systempassword policy, rotation and account reports
Configuration monitor, change tickets and SOCbaselines, change records, log reviews and alerts
Audit calendarevery programme this season, its auditor, dates and sample rules
Auditorsthe crosswalk exported, or read by an auditor as a guest for its own scope
What it changes

The difference, in numbers.

Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.

target
100%
of requirements mapped to a tested control, with every gap found before the auditor arrives
751 of 762 fully covered
11 gaps owned before the season
estimated
$1.1M
a year of duplicate control testing avoided: 612 tests become 214, one per control
Last season612 tests
One per control214 tests
target
2days
to re-map a new framework version, not 11 weeks by hand
By hand11 weeks
With agents2 days

“demo” = seen in the working solution, on its sample utility's data · “estimated” = our arithmetic, inputs shown ($1.1M = 398 avoided tests × about 22 hours × $125 an hour, demo inputs to be replaced by your last audit cycle; the working-days split is our estimate) · “typical” = published figures (a $10M settlement for 127 NERC CIP violations, SecurityWeek, 2019). Frameworks named as context: NERC CIP-007-6, CIP-003-9 (effective 1 Apr 2026), IEC 62443-3-3, NIST CSF 2.0, ISO/IEC 27001:2022. Lumina Utilities and the people, auditors, regulators, suppliers, sites and records named on this page are fictional — characters and sample data in the working solution.

Questions

What GRC teams ask us.

What is compliance control mapping?

Compliance control mapping links each of your security controls to every framework requirement it satisfies, so one control and one piece of evidence can answer several audits. Compliance Control Mapping does it for utilities over NERC CIP, IEC 62443, NIST CSF, ISO 27001 and a state water cyber rule, with each link quoting both texts and saying whether it is full or partial.

How does compliance control mapping work in this solution?

Six agents work every night. The framework reader splits each framework into requirements with their parameters, the crosswalk mapper proposes links from your controls, the evidence matcher checks your evidence against each requirement's numbers, period and scope, the gap finder drafts the gaps and the test planner builds one test per control. The Head of Cyber GRC confirms links, the CISO decides gaps and internal audit signs the plan.

Is it a common controls framework for utilities with both a grid and a water system?

Yes, that is the case it is built for. In the working solution, the grid's control centres and substations are in NERC CIP scope, the water treatment works SCADA is assessed against IEC 62443 at security level 2, corporate IT holds the ISO 27001 certificate, NIST CSF is the board's yardstick and the water side answers to a state cyber rule, all from one library of 214 controls.

How does “test once, comply many” keep the audit sound?

Each test takes the sample size and period of the strictest auditor among the audits it feeds, and the test planner never lowers a sample below any auditor's minimum. Internal audit signs the plan before testing starts, and a signed plan can only be revised, not changed.

What happens when a framework changes, like CIP-003-9 or NIST CSF 2.0?

The change watcher checks the publishers every night, compares the new text with the version in force and queues the changed requirements for the crosswalk mapper. In the working solution, the water cyber rule's amendment added 6 requirements and was mapped in 2 days; one had no control and became a gap. A requirement still in an active audit period is never retired.

Does it find compliance gaps before the auditor does?

That is the point of the coverage heatmap. Requirements with only partial coverage or no control appear there and in Gaps, each with what is missing, a proposed fix, an owner, a due date and the audit at risk. Only the CISO can accept risk on a gap, and only with an expiry date.

Do people stay in control of the mapping?

Yes. The agents read, propose and draft; they never confirm a link, edit evidence, lower a sample or accept risk. Nothing counts toward coverage until a person confirms it, and every proposal and decision is on the audit trail.

How long does it take to go live?

The Agentic Solution Engine builds and deploys it from your requirements and documents: your framework texts, your control library, a sample of last season's evidence and your audit calendar. It goes live once every quality gate has passed. We will walk you through it on your own controls first.

See it on
your controls.

We'll run Compliance Control Mapping on your own control library, your frameworks and last season's evidence.