Framework overlap

Does NIST AI Risk Management Framework (AI RMF 1.0) cover German Supply Chain Due Diligence Act (LkSG)?

You hold NIST AI Risk Management Framework (AI RMF 1.0) and have been told to do German Supply Chain Due Diligence Act (LkSG). Here is how much overlaps, control by control.

36% of German Supply Chain Due Diligence Act (LkSG) you already have

NIST AI Risk Management Framework (AI RMF 1.0) already covers about 36% of German Supply Chain Due Diligence Act (LkSG), leaving 7 of 11 controls as genuinely new work.

Already covered 2 Likely covered 2 New work 7

What is genuinely new work

Nothing in NIST AI Risk Management Framework (AI RMF 1.0) reaches these. This is the list to scope.

LkSG-BAFA-Enforcement-Sanctions
BAFA Enforcement, EUR 8M + 2% Sanctions and Public Procurement Exclusion
LkSG-Coord-Hinweisgeberschutz-Sectoral
Coordination with German Whistleblower Protection (HinSchG), Sectoral Frameworks and ESG
LkSG-Crosswalk-CSDDD-UNGPs-OECD
Crosswalk to EU CSDDD, UN Guiding Principles, OECD MNE Guidelines and German NAP
LkSG-EU-CSDDD-Coordination-Status
EU Corporate Sustainability Due Diligence Directive (CSDDD) Coordination + LkSG 2024-2025 Status
LkSG-HumanRights-Environmental-Risks
Protected Human Rights + Environmental Risks (Sections 2(2)-(3))
LkSG-Implementation-Roadmap-Org
LkSG Compliance Program Implementation - Organizational Roles, Tooling and Metrics
LkSG-Scope-Threshold-GroupCascade
Scope, Applicability Thresholds (>3,000 then >1,000 employees) and Group Cascade
Show the 4 you already have
LkSG-Sec4-RiskMgmt-Sec5-RiskAnalysis
Section 4 Risk Management System + Section 5 Annual Risk Analysis
LkSG-Sec6-Policy-Preventive
Section 6 Policy Statement and Preventive Measures (Own + Direct Suppliers)
LkSG-Sec7-IndirectSupplier-Sec8-Remedial
Section 7 Indirect Supplier DD + Substantiated Knowledge Trigger + Section 8 Remedial Action
LkSG-Sec9-Complaints-Sec10-Doc-Report
Section 9 Complaints Procedure + Section 10 Documentation + Annual Reporting

How this is calculated

Already covered means a mapping runs from a control in NIST AI Risk Management Framework (AI RMF 1.0) 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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