Standards Comparison

    CMMC

    Mandatory
    2021

    DoD certification verifying cybersecurity maturity for DIB

    VS

    23 NYCRR 500

    Mandatory
    2017

    NY regulation for financial services cybersecurity

    Quick Verdict

    CMMC mandates tiered DoD contractor certification for FCI/CUI via NIST controls, ensuring supply chain security. 23 NYCRR 500 requires NY financial entities' risk-based programs with MFA, encryption, annual testing for NPI protection. Both drive compliance; CMMC gates contracts, Part 500 avoids fines.

    Cybersecurity Maturity

    CMMC

    Cybersecurity Maturity Model Certification (CMMC) 2.0

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

    Key Features

    • Three cumulative maturity levels aligned to threat
    • Verification through C3PAO and DIBCAC assessments
    • NIST SP 800-171 110 controls for Level 2
    • SPRS scoring with annual affirmations required
    • POA&Ms limited to 180-day closure timelines
    Financial Services

    23 NYCRR 500

    23 NYCRR Part 500 Cybersecurity Regulation

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

    Key Features

    • Annual CISO/CEO dual-signature certification
    • 72-hour cybersecurity incident notification
    • Phishing-resistant MFA for high-risk access
    • Third-party service provider security policy
    • Risk-based penetration testing and vulnerability management

    Detailed Analysis

    A comprehensive look at the specific requirements, scope, and impact of each standard.

    CMMC Details

    What It Is

    Cybersecurity Maturity Model Certification (CMMC) 2.0 is a U.S. Department of Defense (DoD) certification framework verifying cybersecurity practices for the Defense Industrial Base (DIB). It operationalizes FAR 52.204-21 and NIST SP 800-171/172 requirements through a tiered model with three levels: Foundational (Level 1 for FCI), Advanced (Level 2 for CUI), and Expert (Level 3 for APT defense). The risk-based approach ensures protections match data sensitivity.

    Key Components

    • 14 domains mirroring NIST families (e.g., Access Control, Incident Response).
    • **Level 117 FAR practices; Level 2: 110 NIST 800-171 controls; Level 3: +24 NIST 800-172 selections.
    • Built on NIST standards with assessment guides using interview/examine/test methods.
    • Certification via self-assessment (Level 1/2 select), C3PAO (Level 2), or DIBCAC (Level 3), valid 3 years with annual affirmations in SPRS/eMASS.

    Why Organizations Use It

    Mandated for DoD contractors handling FCI/CUI, ensuring contract eligibility. Reduces supply-chain risks, enhances resilience, lowers breach costs, and provides competitive edge via verified maturity. Builds prime-sub trust and supports M&A diligence.

    Implementation Overview

    Phased: governance, scoping/gap analysis, remediation, assessment prep, certification, sustainment. Applies to all DIB primes/subs; small/mid/large firms use enclaves for scoping. Requires SSP, POA&Ms (180-day close), evidence automation. (178 words)

    23 NYCRR 500 Details

    What It Is

    23 NYCRR Part 500 is the New York Department of Financial Services (NYDFS) Cybersecurity Regulation, a state-level mandate effective March 2017 with amendments in 2023. It establishes minimum, risk-based cybersecurity requirements for financial services entities to protect nonpublic information (NPI) and information systems. Its approach emphasizes governance, evidence-based outcomes, and prescriptive controls like MFA and incident reporting.

    Key Components

    • 14 core requirements including cybersecurity program, CISO appointment, risk assessments, MFA, encryption, TPSP oversight, penetration testing, and 72-hour incident notification.
    • Built on risk assessment architecture; annual dual CISO/CEO certification with five-year record retention.
    • Class A companies face enhanced audits and controls; no formal certification but NYDFS examinations enforce compliance.

    Why Organizations Use It

    • Mandatory for NY-licensed financial entities (banks, insurers, etc.) to avoid multimillion-dollar fines (e.g., Robinhood $30M).
    • Enhances resilience, reduces incident risk, builds stakeholder trust, and aligns with NIST CSF.
    • Provides competitive edge in vendor selection and insurance premiums.

    Implementation Overview

    • Phased roadmap: gap analysis, asset inventory, MFA rollout, TPSP contracts, testing; up to 24 months.
    • Applies to Covered Entities in NY financial sector; small exemptions available.
    • Involves governance setup, evidence repositories, and annual filings by April 15. (178 words)

    Key Differences

    Scope

    CMMC
    FCI/CUI protection via NIST controls across 14 domains
    23 NYCRR 500
    NPI protection via risk-based program and 14 requirements

    Industry

    CMMC
    Defense Industrial Base contractors/subcontractors
    23 NYCRR 500
    NY financial services licensees/regulated entities

    Nature

    CMMC
    Mandatory DoD certification with tiered assessments
    23 NYCRR 500
    Mandatory NYDFS regulation with annual certification

    Testing

    CMMC
    Self/C3PAO/DIBCAC assessments every 3 years
    23 NYCRR 500
    Annual pen testing, vulnerability assessments, risk reviews

    Penalties

    CMMC
    Contract ineligibility, debarment, no direct fines
    23 NYCRR 500
    Civil penalties, fines, license actions, consent orders

    Frequently Asked Questions

    Common questions about CMMC and 23 NYCRR 500

    CMMC FAQ

    23 NYCRR 500 FAQ

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