The seven high-level CSF steps generally align to the high-level phases of the COBIT 2019 implementation guide, which are: What are the drivers?; Where are we now?; Where do we want to be?; What needs to be done?; How do we get there?; Did we get there?; and How do we keep the momentum going?12. These phases provide a structured approach for implementing a governance system using COBIT 2019, and can be mapped to the CSF steps of Prioritize and Scope, Orient, Create a Current Profile, Conduct a Risk Assessment, Create a Target Profile, Determine, Analyze and Prioritize Gaps, and Implement Action Plan34.

References: 1: COBIT 2019 Implementation Guide 2: COBIT 2019 Implementation - ISACA 3: Implementing the NIST Cybersecurity Framework Using COBIT 2019 | ISACA 4: REVIEW OF IMPLEMENTING THE NIST CYBERSECURITY FRAMEWORK USING COBIT 2019.