Standards Comparison

    ISO 22301

    Voluntary
    2019

    International standard for business continuity management systems

    VS

    23 NYCRR 500

    Mandatory
    2017

    New York regulation for financial services cybersecurity.

    Quick Verdict

    ISO 22301 offers global BCMS certification for resilience across industries, while 23 NYCRR 500 mandates cybersecurity compliance for NY financial entities with strict enforcement. Organizations adopt ISO 22301 voluntarily for best practices; NYCRR 500 to avoid penalties.

    Business Continuity

    ISO 22301

    ISO 22301:2019 Business Continuity Management Systems

    Cost
    €€€
    Complexity
    High
    Implementation Time
    6-12 months

    Key Features

    • PDCA cycle for continual BCMS improvement
    • Business Impact Analysis prioritizing critical functions
    • Annex SL structure enabling standard integrations
    • Risk-based operational planning and testing
    • Leadership commitment with policy and roles
    Financial Services

    23 NYCRR 500

    23 NYCRR Part 500

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

    Key Features

    • Annual CISO/CEO dual-signature compliance certification
    • 72-hour cybersecurity incident notification to NYDFS
    • Risk-based cybersecurity program and assessments
    • Phishing-resistant MFA for privileged and remote access
    • Third-party service provider security policy and oversight

    Detailed Analysis

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

    ISO 22301 Details

    What It Is

    ISO 22301:2019 is an international certification standard for Business Continuity Management Systems (BCMS). It provides requirements to plan, establish, implement, operate, monitor, review, maintain, and continually improve resilience against disruptions. The standard follows a risk-based PDCA (Plan-Do-Check-Act) approach across 10 clauses.

    Key Components

    • Clauses 4-10 form the core: context, leadership, planning (including BIA and risk assessment), support, operation (recovery strategies), evaluation, and improvement.
    • No prescriptive controls; flexible, tailored to organizational context.
    • Built on Annex SL high-level structure.
    • Certification valid for 3 years with annual surveillance audits.

    Why Organizations Use It

    Enhances resilience, reduces downtime and financial losses, ensures regulatory compliance (e.g., NIS Directive), builds stakeholder trust, and provides competitive edges like procurement advantages. Addresses threats like cyberattacks, pandemics, and supply chain failures.

    Implementation Overview

    Start with gap analysis, BIA, policy development, training, testing, and audits. Applicable to all sizes/sectors; certification via two-stage process (6-8 weeks). Tools automate for efficiency.

    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 2023 amendments. It establishes risk-based cybersecurity requirements for financial services entities to protect nonpublic information (NPI) and information systems, emphasizing governance, controls, and reporting.

    Key Components

    • 14 core requirements including cybersecurity program (§500.2), CISO oversight (§500.4), risk assessments (§500.9), MFA (§500.12), encryption (§500.15), TPSP management (§500.11), and 72-hour incident notification (§500.17).
    • Built on risk assessment-centric architecture; annual CISO/CEO certification with 5-year record retention.
    • Enhanced for Class A Companies (e.g., >$20M NY revenue, >2,000 employees) with audits and EDR.

    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.

    Implementation Overview

    • Phased roadmap: gap analysis, asset inventory, MFA rollout, TPSP contracts; up to 24 months.
    • Applies to NY-regulated firms globally; no certification but annual filing and DFS examinations.

    Key Differences

    Scope

    ISO 22301
    Business continuity management system (BCMS)
    23 NYCRR 500
    Cybersecurity for financial information systems

    Industry

    ISO 22301
    All sectors worldwide
    23 NYCRR 500
    NY financial services entities

    Nature

    ISO 22301
    Voluntary international certification standard
    23 NYCRR 500
    Mandatory NY state regulation

    Testing

    ISO 22301
    BIA, exercises, annual audits
    23 NYCRR 500
    Annual pen testing, vulnerability scans

    Penalties

    ISO 22301
    Loss of certification
    23 NYCRR 500
    Multi-million dollar fines, enforcement

    Frequently Asked Questions

    Common questions about ISO 22301 and 23 NYCRR 500

    ISO 22301 FAQ

    23 NYCRR 500 FAQ

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