Does Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (UAE PDPL) cover AICPA Privacy Management Framework (PMF)?

77% of AICPA Privacy Management Framework (PMF) you already have

Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (UAE PDPL) already covers about 77% of AICPA Privacy Management Framework (PMF), leaving 6 of 26 controls as genuinely new work.

Already covered 6 Likely covered 14 New work 6

What is genuinely new work

Nothing in Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (UAE PDPL) reaches these. This is the list to scope.

PMF-A.2

Access Request Process

PMF-AN.1

Privacy Notice

PMF-AN.3

Privacy Agreements

PMF-D.1

Third-Party Disclosure Controls

PMF-M.2

Privacy Policies and Procedures

PMF-ME.1

Privacy Program Monitoring

Show the 20 you already have

PMF-DI.1

Data Accuracy

PMF-DI.2

Data Quality Processes

PMF-M.3

Privacy Risk Assessment

PMF-M.4

Privacy Incident Management

PMF-ME.2

Complaint Handling

PMF-SP.3

Security Testing and Monitoring

PMF-A.1

Individual Access Rights

PMF-AN.2

Purpose Specification

PMF-CC.1

Lawful and Fair Collection

PMF-CC.2

Collection Limitation

PMF-CC.3

Consent Mechanisms

PMF-D.2

Third-Party Agreements

PMF-D.3

Onward Transfer Accountability

PMF-M.1

Privacy Program Governance

PMF-ME.3

Enforcement and Remediation

PMF-SP.1

Information Security Program

PMF-SP.2

Security Safeguards

PMF-URD.1

Use Limitation

PMF-URD.2

Retention Periods

PMF-URD.3

Secure Disposal

How this is calculated

Already covered means a mapping runs from a control in Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (UAE PDPL) 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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