Crosswalk pair

FedRAMP 20x and ISO/IEC 42001, control by control

3 canonical controls in Keel’s library satisfy clauses of both FedRAMP 20x and ISO/IEC 42001. Implement each once, attach the evidence once, and it counts toward each standard. The overlap is the work you don’t repeat.

The overlap

What the two libraries have in common

Every figure here counts canonical controls in Keel’s library, not clauses of either standard. Each standard’s own authored count is on its framework page.

3

Controls that satisfy both

Canonical controls that crosswalk to at least one clause of each.

27

In Keel’s library for FedRAMP 20x

11% of them also map to ISO/IEC 42001.

38

In Keel’s library for ISO/IEC 42001

8% of them also map to FedRAMP 20x.

9

Evidence artifacts expected

Across the shared controls, from Keel’s evidence guidance. Gathered once.

  • FedRAMP 20x Key Security Indicators, 2026 11%

    3 controls of 27 in Keel’s library for FedRAMP 20x also map to ISO/IEC 42001.

  • ISO/IEC 42001 2023 8%

    3 controls of 38 in Keel’s library for ISO/IEC 42001 also map to FedRAMP 20x.

The mapping

Controls that satisfy both

Each row is one control in Keel’s library and the clauses it answers on each side. Do the work once; both columns are then evidenced by the same artifacts.

FedRAMP 20x and ISO/IEC 42001 controls that satisfy both, with the clauses each maps to
Canonical control FedRAMP 20x clauses ISO/IEC 42001 clauses
Governance & Risk
Continual improvement Improvement of the management system is run as an activity with a record, not held as an intention. Opportunities are captured from everywhere they arise - audit findings, the results of measurement and evaluation, decisions out of management reviews, incidents and near misses, and suggestions from the people actually doing the work - and held in one place instead of in the meeting each came out of. Each is evaluated and either taken forward with an owner and a date or closed with the reason it was not, so a rejected idea is a decision rather than a silence. Once an improvement is made, its effect on the suitability, adequacy and effectiveness of the system is checked, so improvement is something that can be shown to have happened rather than asserted at the next audit. The routine execution of the work counts as a source in its own right: what the operational processes, procedures and activities themselves show while they are being run - the step that is always skipped, the check that never fires, the manual workaround everybody has quietly adopted - is captured on the same terms as a finding from an audit, because the people running a process daily see more of it than any evaluation does. Where the thing being improved is an AI system, the improvement activity is built into the system’s own update cycle and is measurable: an update carries the improvement it is meant to deliver and the measure that will show whether it did, checked afterwards rather than asserted, and interested parties - the people who operate the system, the people it is used on, and those who represent them - are engaged regularly as part of that cycle rather than consulted once at launch. The opportunities are not confined to the system: what the organization delivers is in scope too. Improving products and services to meet known requirements and to address needs and expectations that are coming rather than current, correcting, preventing or reducing undesired effects, and improving how the system itself performs are all determined and selected against as improvement opportunities, rather than run as three unrelated programs. And the standing question - what in the system’s suitability, adequacy and effectiveness should be improved next - is answered from evidence rather than appetite: the results of analysis and evaluation and the outputs of management review are considered together to decide whether there is a need or an opportunity that has to be addressed. KSI-SVC-EIS 10.1
Leadership commitment & accountability Top management is accountable for whether the management system works, and the accountability is exercised rather than asserted. It approves the policy and the objectives and satisfies itself that they fit the direction the organization is actually going in; it requires the system’s requirements to be built into how the business already runs rather than bolted alongside it; it makes sure the resources the system needs are available; it tells the organization why conforming to the system matters, in its own voice; it directs and supports the people whose work makes the system effective; it promotes improvement; and it backs other managers in exercising leadership over the parts of the system that are theirs. What it decided, when, and on what basis is recorded, so the commitment is evidenced by acts rather than by a signature on a policy. Leadership is accountable for cybersecurity risk itself and not only for the system that manages it, and it fosters the culture that has to go with that: risk-aware, ethical, and expected to keep improving rather than to hold a standard once reached. It also requires cybersecurity risk management activities and their outcomes to be carried inside the organization’s enterprise risk management process - the same register, the same reporting line, the same committee that hears the other risks - rather than in a security-only record that never reaches the people who allocate capital against it. It promotes two habits by name rather than by implication: the process approach, meaning the work is understood, run and improved as connected processes with defined inputs, outputs and owners; and risk-based thinking, meaning what could go wrong is considered while the work is being planned rather than after it has gone wrong. And it satisfies itself that the system achieves the results it was set up to achieve - the intended outcomes, checked - so leadership answers for the system’s effect and not only for its existence. KSI-PIY-RES 5.1
Resources for the management system The resources the management system needs in order to be established, run, kept running and improved are determined and provided, not assumed: the people and the time they are actually given rather than the time the plan says they have, the tools and technology, the information, and the budget. The determination distinguishes what the organization can meet from its own capability from what it has to obtain from outside, and it is written down so a shortfall is visible as a shortfall. It is revisited when the system’s scope, its workload or the organization changes, so a system that has grown is not still resourced for the size it was when it started. Security and privacy are budgeted as a discrete line rather than absorbed into a general technology allocation. The high-level security and privacy requirements for a system or a service are determined while the business process it serves is being planned, rather than after the design is fixed; what it will cost to protect it is then determined, documented and allocated as part of the organization’s capital planning and investment process; and that amount appears as a discrete line item in the programming and budgeting record - so an underfunded control is a visible decision rather than an unexplained gap. Adequacy is judged against the risk strategy rather than against last year’s allocation: what is provided is set commensurate with the risks the organization has said it will manage, the roles it has assigned and the policies it has issued - and where it is not, the shortfall is recorded against the part of the strategy it fails to fund. People are determined as their own class of resource rather than counted inside a budget line: the persons necessary for the system to be implemented effectively, and for its processes to be operated and controlled, are identified from the work that has to be done and are then actually provided - so a process with nobody assigned to run it is visible before it fails rather than after. Where the management system depends on data and on computing capacity - not only on people, tools and money - those are determined and provided as resource classes in their own right, so a system planned without the data it needs, or without the compute to run what it plans, is a visible shortfall rather than a later discovery. KSI-PIY-RIS 7.1

Beyond the pair

Where else this work counts

A framework is lit when a shared control above also maps to it. Unlit means none of them do, which is an absence rather than a judgment about that standard.

Also reached by these 3 controls

  • AI Governance Essentials not reached
  • Amazon Appstore Child-Directed Apps not reached
  • Apple App Store Kids Category not reached
  • CIS Critical Security Controls not reached
  • COPPA not reached
  • ESG Essentials not reached
  • EU AI Act not reached
  • FedRAMP Consolidated Rules not reached
  • FedRAMP Rev5 Class B also reached
  • FedRAMP Rev5 Class C also reached
  • FedRAMP Rev5 Class D also reached
  • GDPR not reached
  • Google Play Families not reached
  • HIPAA not reached
  • ISO 9001 also reached
  • ISO/IEC 27001 also reached
  • NIST AI Risk Management Framework also reached
  • NIST Cybersecurity Framework also reached
  • NIST SP 800-171 not reached
  • NIST SP 800-53 also reached
  • PCI DSS not reached
  • PIPEDA not reached
  • SOC 2 not reached
  • SOX (Sarbanes-Oxley) Section 404 not reached
  • US Employment Law - Federal Baseline not reached

The thesis

Why this is one project, not two

On a crosswalk-native model, ISO/IEC 42001 mostly lights up controls you already built for FedRAMP 20x. You’re not re-uploading the same screenshot for a second audit. You apply the framework and see the genuine delta worth working. That’s the whole idea behind collect once, comply everywhere.

Next step

Add ISO/IEC 42001 to the work you already did

Apply both frameworks in one workspace and see the overlap measured against the controls you already hold.