Framework overlap

Does CISA Cross-Sector Cybersecurity Performance Goals (CPG) 2.0 cover PCAOB AS 2201?

You hold CISA Cross-Sector Cybersecurity Performance Goals (CPG) 2.0 and have been told to do PCAOB AS 2201. Here is how much overlaps, control by control.

50% of PCAOB AS 2201 you already have

CISA Cross-Sector Cybersecurity Performance Goals (CPG) 2.0 already covers about 50% of PCAOB AS 2201, leaving 4 of 8 controls as genuinely new work.

Already covered 0 Likely covered 4 New work 4

No control in CISA Cross-Sector Cybersecurity Performance Goals (CPG) 2.0 maps directly to one in PCAOB AS 2201. 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 CISA Cross-Sector Cybersecurity Performance Goals (CPG) 2.0 reaches these. This is the list to scope.

ASTWO-2
Materiality, Significant Accounts, Disclosures, Transaction Flows
ASTWO-4
Walkthroughs, Control Selection, Design Effectiveness Testing
ASTWO-5
Operating Effectiveness Testing: Nature, Timing, Extent
ASTWO-6
Engagement Quality Review and Subsequent Events
Show the 4 you already have
ASTWO-1
Audit Planning, Scaling, Risk Assessment, and Integration
ASTWO-3
Entity-Level Controls and Period-End Financial Reporting Process
ASTWO-7
Deficiency Evaluation, Material Weakness, and Communication
ASTWO-8
ICFR Opinion, Basis, Definition, Limitations, Combined vs Separate Reports

How this is calculated

Already covered means a mapping runs from a control in CISA Cross-Sector Cybersecurity Performance Goals (CPG) 2.0 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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