Framework overlap

Does PCI P2PE cover ISO 22301:2019?

You hold PCI P2PE and have been told to do ISO 22301:2019. Here is how much overlaps, control by control.

38% of ISO 22301:2019 you already have

PCI P2PE already covers about 38% of ISO 22301:2019, leaving 24 of 39 controls as genuinely new work.

Already covered 1 Likely covered 14 New work 24

What is genuinely new work

Nothing in PCI P2PE reaches these. This is the list to scope.

10.1
Continual improvement
10.2
Nonconformity and corrective action
4.2
Understanding the needs and expectations of interested parties
4.4
Management system
5.2
Policy
5.3
Roles, responsibilities and authorities
6.2
Objectives and planning to achieve them
7.1
Resources
7.2
Competence
7.3
Awareness
7.5
Documented information
7.5.2
Creating and updating
7.5.3
Control of documented information
8.2.2
Business impact analysis
8.3.2
Identification of strategies and solutions
8.3.3
Selection of strategies and solutions
8.3.5
Implementation of solutions
8.4.2
Response structure
8.4.3
Warning and communication
8.4.5
Recovery
8.5
Exercise programme
8.6
Evaluation of business continuity documentation and capabilities
9.1
Monitoring, measurement, analysis and evaluation
9.2
Internal audit
Show the 15 you already have
7.4
Communication
4.1
Understanding the organization and its context
4.3
Determining the scope of the management system
5.1
Leadership and commitment
6.1
Actions to address risks and opportunities
6.1.2
Risk assessment
6.1.3
Risk treatment
8.1
Operational planning and control
8.2
Business impact analysis and risk assessment
8.2.3
Risk assessment
8.3
Business continuity strategies and solutions
8.3.4
Resource requirements
8.4
Business continuity plans and procedures
8.4.4
Business continuity plans
9.3
Management review

How this is calculated

Already covered means a mapping runs from a control in PCI P2PE 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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