Framework overlap

Does ISO 41001:2018 cover PCI P2PE?

You hold ISO 41001:2018 and have been told to do PCI P2PE. Here is how much overlaps, control by control.

34% of PCI P2PE you already have

ISO 41001:2018 already covers about 34% of PCI P2PE, leaving 29 of 44 controls as genuinely new work.

Already covered 3 Likely covered 12 New work 29

What is genuinely new work

Nothing in ISO 41001:2018 reaches these. This is the list to scope.

Annex-A
Symmetric Key Distribution Using Asymmetric Techniques
Annex-B
Key Injection Facility Requirements
Domain-1.1
POI Device Approval Status
Domain-1.2
Account Data Encryption at POI
Domain-1.3
POI Device Tampering Protection
Domain-2.1
POI Application Security
Domain-2.2
POI Device Authentication
Domain-3.1
POI Device Management
Domain-3.2
Merchant POI Device Deployment
Domain-4.1
Decryption Environment Logical Security
Domain-4.2
Decryption Environment Physical Security
Domain-5.1
Key Generation
Domain-5.2
Key Distribution and Injection
Domain-5.3
Key Storage
Domain-5.4
Key Usage and Cryptoperiods
Domain-5.5
Key Destruction
Domain-6.1
P2PE Solution Documentation
Domain-6.2
Annual Reassessment and Change Management
Domain-6.3
Merchant Self-Assessment Support
PCI-P2PE-01
Information security program management
PCI-P2PE-02
Board and management oversight
PCI-P2PE-03
Risk appetite and tolerance for IT risk
PCI-P2PE-04
Security policy framework
PCI-P2PE-13
Third-party dependency management
PCI-P2PE-15
Communication and escalation procedures
PCI-P2PE-17
Contractual security requirements
PCI-P2PE-20
Exit strategy and transition planning
PCI-P2PE-23
Regulatory reporting requirements
PCI-P2PE-24
Customer notification procedures
Show the 15 you already have
PCI-P2PE-05
Roles and responsibilities definition
PCI-P2PE-11
Business continuity planning and testing
PCI-P2PE-12
Disaster recovery procedures
PCI-P2PE-06
Network security and segmentation
PCI-P2PE-07
Endpoint protection and detection
PCI-P2PE-08
Application security controls
PCI-P2PE-09
Encryption and key management
PCI-P2PE-10
Secure configuration standards
PCI-P2PE-14
Critical service identification
PCI-P2PE-16
Due diligence and onboarding
PCI-P2PE-18
Ongoing monitoring and assessment
PCI-P2PE-19
Concentration risk management
PCI-P2PE-21
Incident detection and classification
PCI-P2PE-22
Incident response and containment
PCI-P2PE-25
Post-incident review and improvement

How this is calculated

Already covered means a mapping runs from a control in ISO 41001:2018 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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