Framework overlap

Does CISA Industrial Control Systems (ICS) Security Guidance cover C2M2?

You hold CISA Industrial Control Systems (ICS) Security Guidance and have been told to do C2M2. Here is how much overlaps, control by control.

68% of C2M2 you already have

CISA Industrial Control Systems (ICS) Security Guidance already covers about 68% of C2M2, leaving 7 of 22 controls as genuinely new work.

Already covered 0 Likely covered 15 New work 7

No control in CISA Industrial Control Systems (ICS) Security Guidance maps directly to one in C2M2. 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 Industrial Control Systems (ICS) Security Guidance reaches these. This is the list to scope.

RESPONSE-1
Detect and Analyze Cybersecurity Events
RESPONSE-3
Plan for Continuity of Operations
RISK-2
Identify and Analyze Cyber Risk
SITUATION-2
Establish and Maintain a Common Operating Picture
THREAT-1
Identify and Respond to Cyber Threats
THREAT-2
Reduce Cybersecurity Vulnerabilities
WORKFORCE-1
Establish Cybersecurity Responsibilities and Workforce
Show the 15 you already have
ACCESS-1
Establish and Maintain Identities
ACCESS-2
Control Logical and Physical Access
ARCH-1
Establish a Cybersecurity Architecture Strategy
ARCH-2
Implement Network Protections
ARCH-3
Implement Data Security
ASSET-1
Manage IT and OT Asset Inventory
ASSET-2
Manage Asset Configuration and Changes
PROGRAM-1
Establish and Maintain the Cybersecurity Program
RESPONSE-2
Respond to and Recover from Cybersecurity Incidents
RISK-1
Establish a Cyber Risk Management Strategy and Program
RISK-3
Manage and Respond to Cyber Risk
SITUATION-1
Perform Logging and Monitoring
THIRD-1
Identify and Manage Third-Party Risk
THIRD-2
Manage Supplier Relationships and Incident Notification
WORKFORCE-2
Develop Cybersecurity Workforce and Awareness

How this is calculated

Already covered means a mapping runs from a control in CISA Industrial Control Systems (ICS) Security Guidance 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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