Standards Comparison

    23 NYCRR 500

    Mandatory
    2017

    NY regulation for financial services cybersecurity

    VS

    EU AI Act

    Mandatory
    2024

    EU regulation for risk-based AI governance

    Quick Verdict

    23 NYCRR 500 mandates cybersecurity for NY financial entities, while EU AI Act regulates high-risk AI systems EU-wide with conformity assessments. Firms adopt 500 for NY compliance; AI Act for safe AI market access and risk mitigation.

    Financial Services

    23 NYCRR 500

    23 NYCRR Part 500 Cybersecurity Regulation

    Cost
    €€€€
    Complexity
    High
    Implementation Time
    12-18 months

    Key Features

    • Mandates qualified CISO with annual board reporting
    • Requires 72-hour cybersecurity incident notification
    • Enforces risk-based cybersecurity program design
    • Demands MFA for external network access
    • Imposes annual CEO/CISO compliance certification
    Artificial Intelligence

    EU AI Act

    Artificial Intelligence Act (Regulation (EU) 2024/1689)

    Cost
    €€€
    Complexity
    Medium
    Implementation Time
    18-24 months

    Key Features

    • Risk-based four-tier AI classification framework
    • Prohibitions on unacceptable AI practices
    • High-risk conformity assessment and CE marking
    • GPAI model transparency and systemic risk duties
    • Lifecycle risk management and post-market monitoring

    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) regulation establishing minimum cybersecurity standards for financial services entities. It is a mandatory regulation for Covered Entities, adopting a risk-based approach to protect information systems and nonpublic information (NPI) confidentiality, integrity, and availability.

    Key Components

    • Seven pillars: governance, risk assessment, policies, controls, monitoring/testing, third-party management, incident response/reporting.
    • 20+ sections including CISO designation (§500.4), MFA (§500.12), encryption (§500.15), annual certification (§500.17).
    • Built on periodic risk assessments (§500.9) informing all controls.
    • Compliance via annual filings, no external certification but NYDFS examinations and enforcement.

    Why Organizations Use It

    • Legal compliance for NYDFS-licensed entities (banks, insurers, etc.).
    • Mitigates cyber risks, ensures customer data protection.
    • Builds board accountability, reduces enforcement risks (fines, consent orders).
    • Enhances resilience, vendor oversight, market trust.

    Implementation Overview

    • Phased rollout with risk assessments first, then controls like MFA/encryption.
    • Involves CISO appointment, policy development, testing, training.
    • Applies to all sizes of Covered Entities in NY financial services; limited exemptions for small entities.
    • Retain records 3-5 years for NYDFS review.

    EU AI Act Details

    What It Is

    The EU Artificial Intelligence Act (Regulation (EU) 2024/1689) is a comprehensive regulation establishing the world's first horizontal framework for AI governance. Its primary purpose is to ensure AI systems are safe, transparent, and rights-respecting across sectors, using a risk-based approach that prohibits unacceptable risks, regulates high-risk systems, mandates transparency for limited-risk, and minimally regulates others.

    Key Components

    • **Four risk tiersunacceptable (prohibited), high-risk (Annex I/III), limited-risk (transparency), minimal-risk.
    • Core obligations include risk management (Article 9), data governance (Article 10), documentation, human oversight, cybersecurity (Article 15), conformity assessments, CE marking.
    • Built on product safety principles; GPAI models under Chapter V with systemic risk duties.
    • Compliance via self-assessment or notified bodies, presumption from harmonized standards.

    Why Organizations Use It

    • Mandatory for EU-market AI providers/deployers; avoids fines up to 7% global turnover.
    • Enhances risk management, builds trust, enables market access.
    • Competitive edge in regulated sectors like healthcare, finance.

    Implementation Overview

    Phased rollout (6-36 months); starts with AI inventory/classification, builds lifecycle controls, conformity processes. Applies EU-wide to providers/deployers; high-risk needs audits/CE marking. (178 words)

    Key Differences

    Scope

    23 NYCRR 500
    Cybersecurity for financial info systems
    EU AI Act
    Risk-based AI systems lifecycle governance

    Industry

    23 NYCRR 500
    NY financial services licensees
    EU AI Act
    All sectors using high-risk AI in EU

    Nature

    23 NYCRR 500
    Mandatory NY state regulation
    EU AI Act
    Mandatory EU-wide AI regulation

    Testing

    23 NYCRR 500
    Annual pen testing, bi-annual vuln scans
    EU AI Act
    Conformity assessments, adversarial testing

    Penalties

    23 NYCRR 500
    Consent orders, monetary fines
    EU AI Act
    Up to 7% global turnover fines

    Frequently Asked Questions

    Common questions about 23 NYCRR 500 and EU AI Act

    23 NYCRR 500 FAQ

    EU AI Act FAQ

    You Might also be Interested in These Articles...

    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.

    100+ Standards & Regulations
    AI-Powered Insights
    Collaborative Assessments
    Actionable Recommendations

    Check out these other Gradum.io Standards Comparison Pages