Framework overlap

Does AICPA Privacy Management Framework (PMF) cover DORA?

You hold AICPA Privacy Management Framework (PMF) and have been told to do DORA. Here is how much overlaps, control by control.

19% of DORA you already have

AICPA Privacy Management Framework (PMF) already covers about 19% of DORA, leaving 21 of 26 controls as genuinely new work.

Already covered 0 Likely covered 5 New work 21

No control in AICPA Privacy Management Framework (PMF) maps directly to one in DORA. Everything counted as covered is covered because both map to the same third standard, which is what a crosswalk is, but it is an inference rather than a lookup.

What is genuinely new work

Nothing in AICPA Privacy Management Framework (PMF) reaches these. This is the list to scope.

DORA-Art.10
Detection
DORA-Art.12
Backup policies and procedures, restoration and recovery
DORA-Art.13
Learning and evolving
DORA-Art.14
Communication
DORA-Art.16
Simplified ICT risk management framework
DORA-Art.18
Classification of ICT-related incidents and cyber threats
DORA-Art.19
Reporting of major ICT-related incidents
DORA-Art.23
Operational or security payment-related incidents
DORA-Art.24
General requirements for the performance of digital operational resilience testing
DORA-Art.27
Requirements for testers for the carrying out of TLPT
DORA-Art.28
ICT third-party risk: general principles
DORA-Art.29
Preliminary assessment of ICT concentration risk at entity level
DORA-Art.30
Key contractual provisions
DORA-Art.31
Designation of critical ICT third-party service providers
DORA-Art.45
Information-sharing arrangements on cyber threat information and intelligence
DORA-Art.5
Governance and organisation
DORA-Art.50
Administrative penalties and remedial measures
DORA-Art.6
ICT risk management framework
DORA-Art.7
ICT systems, protocols and tools
DORA-Art.8
Identification
DORA-Art.9
Protection and prevention
Show the 5 you already have
DORA-Art.11
Response and recovery
DORA-Art.17
ICT-related incident management process
DORA-Art.25
Testing of ICT tools and systems
DORA-Art.26
Advanced testing of ICT tools, systems and processes based on TLPT
DORA-Art.56
Data protection

How this is calculated

Already covered means a mapping runs from a control in AICPA Privacy Management Framework (PMF) to that control. Likely covered means no direct mapping exists but both frameworks map to the same control in a third standard. New work means neither. We keep those separate rather than adding them into one friendlier number, because blending them would present a two-hop inference as a verified fact.

Coverage is not symmetric. Run it the other way and you will get a different number; both are correct.

From 332,959 cross-framework control mappings across 723 frameworks, 531 of them verified against their source documents. It does not tell you that you are compliant: a mapped control means the two standards ask for the same thing, not that you have done it.

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