23 NYCRR 500
NYDFS regulation for financial cybersecurity programs
CIS Controls
Prioritized cybersecurity framework of 18 controls.
Quick Verdict
23 NYCRR 500 mandates prescriptive cybersecurity for NY financial entities with fines and audits, while CIS Controls offers voluntary, prioritized best practices for all organizations. Firms adopt 500 for compliance, CIS for resilient hygiene.
23 NYCRR 500
23 NYCRR Part 500 Cybersecurity Regulation
Key Features
- Dual CEO/CISO annual compliance certification by April 15
- 72-hour notification for material cybersecurity incidents
- Mandatory qualified CISO with direct board reporting
- Risk-based third-party service provider security policy
- Phased phishing-resistant MFA rollout to universal coverage
CIS Controls
CIS Critical Security Controls v8.1
Key Features
- 18 prioritized controls with 153 actionable safeguards
- Implementation Groups (IG1-IG3) for scalability
- Technology-agnostic, offense-informed best practices
- Mappings to NIST CSF, PCI DSS, HIPAA frameworks
- Free tools like Benchmarks and CIS-CAT for automation
Detailed Analysis
A comprehensive look at the specific requirements, scope, and impact of each standard.
23 NYCRR 500 Details
What It Is
23 NYCRR Part 500 is the New York Department of Financial Services (NYDFS) Cybersecurity Regulation, a prescriptive regulatory framework for financial services entities. It mandates risk-based cybersecurity programs to protect nonpublic information (NPI) and information systems, emphasizing governance, controls, and evidence-based compliance.
Key Components
- 14 core requirements including cybersecurity program, policy, CISO designation, risk assessments, MFA, encryption, TPSP oversight, penetration testing, incident response, and annual certification.
- Risk-based approach with phased deadlines (e.g., universal MFA by Nov 2025).
- Dual CEO/CISO certification filed April 15 annually, with 5-year record retention.
- Enhanced obligations for Class A Companies (e.g., independent audits, EDR).
Why Organizations Use It
Covered entities face multimillion-dollar fines (e.g., Robinhood $30M). Compliance reduces incident risk, ensures business continuity, builds stakeholder trust, and aligns with enterprise risk management. It differentiates in vendor negotiations and lowers insurance costs.
Implementation Overview
Phased roadmap: appoint CISO, conduct risk assessment, inventory assets, rollout MFA/PAM, update TPSP contracts, test IR plans. Applies to NY-licensed financial firms (banks, insurers); no certification but NYDFS examinations and enforcement.
CIS Controls Details
What It Is
CIS Critical Security Controls (CIS Controls) v8.1 is a community-driven cybersecurity framework providing prioritized, actionable best practices. It focuses on reducing cyber risks through 18 controls and 153 safeguards, emphasizing pragmatic, technology-agnostic measures derived from real-world attacks.
Key Components
- 18 Controls covering asset inventory, secure configuration, vulnerability management, logging, incident response, and penetration testing.
- Implementation Groups (IG1-IG3) scaling safeguards by organizational maturity: IG1 (56 essentials), IG2 (foundational), IG3 (advanced).
- Built on offense-informed principles; maps to NIST CSF, PCI DSS, HIPAA.
- No formal certification; self-assessment via tools like CIS RAM.
Why Organizations Use It
Drives risk reduction (85% of common attacks mitigated), regulatory compliance, operational efficiency, and insurance discounts. Builds stakeholder trust, enables Safe Harbor in some U.S. states, and provides competitive edge via proven hygiene.
Implementation Overview
Phased roadmap: governance (0-2 months), discovery/gaps (1-3 months), IG1 execution (3-9 months), IG2/3 expansion (6-18 months), ongoing validation. Applies to all sizes/industries; tools like Benchmarks, CIS-CAT automate. No mandatory audits; continuous metrics track progress. (178 words)
Key Differences
| Aspect | 23 NYCRR 500 | CIS Controls |
|---|---|---|
| Scope | Prescriptive cybersecurity for financial entities; governance, MFA, TPSP, incident reporting | Prioritized best practices; 18 controls across asset mgmt, vuln mgmt, monitoring |
| Industry | NY financial services; banks, insurers, licensees | All industries worldwide; sector-agnostic |
| Nature | Mandatory state regulation; enforced by NYDFS fines | Voluntary framework; no direct enforcement |
| Testing | Annual pen testing, vuln assessments; continuous monitoring option | Risk-based pen testing, vuln scans per IG; self-assessed |
| Penalties | Multi-million fines, consent orders, license actions | None; reputational, insurance impacts only |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about 23 NYCRR 500 and CIS Controls
23 NYCRR 500 FAQ
CIS Controls FAQ
You Might also be Interested in These Articles...
Top 10 Reasons ISO 27701 is the Ultimate Privacy Boost for Your ISO 27001 ISMS in 2025
Extend ISO 27001 with ISO 27701 for ultimate privacy governance amid GDPR & AI regs. Discover top 10 advantages like integrated audits to future-proof your ISMS
CIS Controls v8.1, Operationalized: Top 10 Reasons Compliance Monitoring Software Accelerates Real-World Implementation
Operationalize CIS Controls v8.1 with compliance monitoring software. Turn checklists into dashboards, tickets, and audit-proof workflows. Top 10 reasons it acc
How to Implement CIS Controls v8.1 as a ‘Control Backbone’ for NIS2 & DORA (Step-by-Step Implementation Guide)
Deploy CIS Controls v8.1 as a control backbone for NIS2 & DORA compliance. Step-by-step roadmap (IG1→IG2), deliverables, metrics & evidence model for hybrid/clo
Run Maturity Assessments with GRADUM
Transform your compliance journey with our AI-powered assessment platform
Assess your organization's maturity across multiple standards and regulations including ISO 27001, DORA, NIS2, NIST, GDPR, and hundreds more. Get actionable insights and track your progress with collaborative, AI-powered evaluations.
Check out these other Gradum.io Standards Comparison Pages
HIPAA vs HITRUST CSF
Compare HIPAA vs HITRUST CSF: HIPAA enforces privacy/security/breach rules for PHI; HITRUST delivers certifiable assurance harmonizing 60+ standards. Boost compliance now.
EPA vs FERPA
Unravel EPA vs FERPA: Compare Clean Air/Water Acts, RCRA standards with student privacy rights. Master compliance risks, enforcement, best practices. Safeguard your operations now!
PCI DSS vs ISO 27032
Compare PCI DSS vs ISO 27032: PCI secures card payments, ISO guides cyberspace risks. Discover differences, compliance benefits & choose your framework today!