Framework overlap

Does ISO 37001 cover ISO 37301:2021?

You hold ISO 37001 and have been told to do ISO 37301:2021. Here is how much overlaps, control by control.

43% of ISO 37301:2021 you already have

ISO 37001 already covers about 43% of ISO 37301:2021, leaving 24 of 42 controls as genuinely new work.

Already covered 8 Likely covered 10 New work 24

What is genuinely new work

Nothing in ISO 37001 reaches these. This is the list to scope.

4.2
Understanding the needs and expectations of interested parties
4.3
Determining the scope of the compliance management system
4.4
Compliance management system
4.6
Compliance risk assessment
5.1
Leadership and commitment
5.1.3
Compliance governance
5.3.4
Personnel
6.1
Actions to address risks and opportunities
6.2
Compliance objectives and planning to achieve them
6.3
Planning of changes
7.1
Resources
7.2
Competence
7.2.2
Employment process
7.2.3
Training
7.3
Awareness
7.4
Communication
7.5
Documented information
7.5.2
Creating and updating documented information
7.5.3
Control of documented information
9.1.3
Development of indicators
9.1.4
Compliance reporting
9.1.5
Record-keeping
9.2
Internal audit
9.2.2
Internal audit programme
Show the 18 you already have
10.2
Nonconformity and corrective action
4.1
Understanding the organization and its context
8.1
Operational planning and control
8.3
Raising concerns
9.1
Monitoring, measurement, analysis and evaluation
9.3
Management review
9.3.2
Management review inputs
9.3.3
Management review results
10.1
Continual improvement
4.5
Compliance obligations
5.1.1
Governing body and top management
5.1.2
Compliance culture
5.2
Compliance policy
5.3
Roles, responsibilities and authorities
5.3.2
Compliance function
8.2
Establishing controls and procedures
8.4
Investigation processes
9.1.2
Sources of feedback on compliance performance

How this is calculated

Already covered means a mapping runs from a control in ISO 37001 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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