What is the primary objective of ISO 27017?

**ISO 27017 provides cloud-specific implementation guidance for ISO 27002 controls and introduces seven additional cloud-focused controls.** It addresses shared responsibilities, multi-tenancy, virtual machine hardening, and customer monitoring in cloud environments for both CSPs and CSCs.

Who is legally or professionally required to comply with ISO 27017?

**No organizations are legally required to comply with ISO 27017 as it is a voluntary code of practice.** CSPs and CSCs adopt it professionally to demonstrate cloud security maturity, meet procurement requirements, and align with regulations like GDPR via enhanced controls.

Does ISO 27017 require an external audit or third-party certification?

**ISO 27017 does not offer standalone certification and is assessed within ISO 27001 audits.** Auditors evaluate its controls as part of an organization's ISMS scope during Stage 1 and Stage 2 external audits by accredited bodies.

How often should an assessment for ISO 27017 be performed?

**ISO 27017 controls should be assessed annually through ISO 27001 surveillance audits and continuously via monitoring tools.** Internal audits occur periodically, with full re-certification every three years, plus ongoing evidence collection for cloud changes.

What are the consequences of non-compliance with ISO 27017?

**Non-compliance with ISO 27017 has no direct legal penalties as it is voluntary, but it risks lost contracts and higher breach exposure.** CSPs may fail procurement RFPs, and organizations face indirect regulatory fines if cloud gaps violate laws like GDPR.

Can ISO 27017 be mapped to other international frameworks?

**Yes, ISO 27017 maps directly to ISO 27001/27002, CSA STAR, and NIST 800-53 for cross-framework compliance.** Its 37+7 controls align with FedRAMP, PCI-DSS, and Zero Trust via shared responsibility and cloud monitoring mappings.

What is the first step to begin implementing ISO 27017?

**The first step is conducting a cloud-specific risk assessment within your ISO 27001 ISMS.** Identify threats like multi-tenancy and shared responsibilities, then select applicable controls from ISO 27017 guidance for your Statement of Applicability.

What is the primary objective of 23 NYCRR 500?

**23 NYCRR Part 500 safeguards nonpublic information and operational integrity of NYDFS-regulated financial entities.** It establishes minimum risk-based cybersecurity requirements, including governance, technical controls like MFA and encryption, and incident reporting to counter threats from nation-states and cybercriminals.

Who is legally or professionally required to comply with 23 NYCRR 500?

**Covered Entities under NY Banking, Insurance, or Financial Services Law must comply.** This includes state-chartered banks, insurers, mortgage brokers, virtual currency licensees, HMOs, and NY branches of foreign banks handling NPI; limited exemptions apply to small entities with <10 employees, <$5M NY revenue, or <$10M assets.

Does 23 NYCRR 500 require an external audit or third-party certification?

**Class A Companies require independent audits; others do not mandate external certification.** Enhanced obligations for entities with >$20M NY revenue and >2,000 employees or >$1B global revenue include audits, EDR, and PAM; all must retain 5-year evidence for annual CEO/CISO certification and DFS examinations.

How often should an assessment for 23 NYCRR 500 be performed?

**Risk assessments must be conducted annually and updated upon material changes.** Section 500.9 requires documented evaluations of threats, vulnerabilities, and controls using frameworks like NIST CSF, informing program design, testing scope, and remediation priorities.

What are the consequences of non-compliance with 23 NYCRR 500?

**Non-compliance triggers multimillion-dollar fines, consent orders, and remediation mandates.** NYDFS enforcement includes penalties like $30M against Robinhood Crypto, $4.25M against OneMain Financial, and orders for deficient governance, TPSP oversight, MFA, and incident reporting.

Can 23 NYCRR 500 be mapped to other international frameworks?

**Yes, 23 NYCRR 500 aligns with NIST CSF, CRI Profile, and ISO 27001.** Its risk-based structure facilitates integration with enterprise risk management, with controls for MFA, encryption, pen testing, and TPRM mapping directly to these frameworks for multi-jurisdictional compliance.

What is the first step to begin implementing 23 NYCRR 500?

**Determine Covered Entity status using NYDFS flowchart and appoint a qualified CISO.** Confirm applicability, assemble a compliance roadmap per phased deadlines (e.g., MFA by Nov 2025), and initiate a risk assessment focusing on critical assets, privileged accounts, and TPSPs.

ISO 27017 vs 23 NYCRR 500

Q: Does 23 NYCRR 500 require an external audit or third-party certification?

**Class A Companies require independent audits; others do not mandate external certification.** Enhanced obligations for entities with >$20M NY revenue and >2,000 employees or >$1B global revenue include audits, EDR, and PAM; all must retain 5-year evidence for annual CEO/CISO certification and DFS examinations.

Standards Comparison

ISO 27017

Voluntary

2015

Cloud-specific code of practice for information security controls

23 NYCRR 500

Mandatory

2017

New York regulation for financial services cybersecurity.

Quick Verdict

ISO 27017 provides voluntary cloud security guidance globally, while 23 NYCRR 500 mandates strict cybersecurity for NY financial firms with fines. CSPs adopt 27017 for trust; NY firms use 500 to avoid multimillion penalties.

Cloud Security

ISO 27017

ISO/IEC 27017:2015 Code of practice for cloud services

Cost

€€€

Complexity

High

Implementation Time

6-12 months

Key Features

Adds seven cloud-specific controls to ISO 27002
Clarifies shared responsibilities between CSPs and customers
Addresses multi-tenancy and virtual environment segregation
Provides cloud guidance for 37 ISO 27002 controls
Integrates directly into ISO 27001 ISMS audits

Financial Services

23 NYCRR 500

23 NYCRR Part 500 Cybersecurity Regulation

Cost

€€€€

Complexity

High

Implementation Time

18-24 months

Key Features

72-hour cybersecurity incident notification to NYDFS
Qualified CISO with annual board reporting
Risk-based annual assessments and penetration testing
Phishing-resistant MFA for high-risk access
Third-party provider security policy and oversight

Detailed Analysis

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

ISO 27017 Details

What It Is

ISO/IEC 27017:2015 is a code of practice extending ISO/IEC 27002 with cloud-specific guidance for information security controls. Its primary purpose is to address unique cloud risks like shared responsibility and multi-tenancy across IaaS, PaaS, and SaaS models. It uses a risk-based approach integrated into an ISO 27001 ISMS.

Key Components

Guidance on 37 ISO 27002 controls adapted for cloud environments.
Seven additional CLD controls covering responsibility delineation, virtual machine configuration, segregation, monitoring, and asset lifecycle.
Built on ISO 27001/27002; not standalone certifiable.
Dual perspective for CSPs and CSCs.

Why Organizations Use It

Enhances trust in cloud services, meets procurement demands, supports GDPR/CCPA alignment, reduces breach risks from misconfigurations, and differentiates CSPs in competitive markets.

Implementation Overview

Conduct cloud risk assessment, map controls to ISMS, implement via automation/tools. Applies to CSPs/CSCs of all sizes; assessed in ISO 27001 audits (9-12 months joint timeline).

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 adopts a risk-based approach to protect nonpublic information (NPI) and ensure operational integrity, applying to Covered Entities licensed under NY Banking, Insurance, or Financial Services Law.

Key Components

14 core requirements including cybersecurity program, CISO governance, risk assessments, MFA, encryption, asset inventories, TPSP oversight, penetration testing, incident response, and annual certification.
Built on NIST CSF or equivalent frameworks.
Class A Companies (high revenue/employees) face enhanced controls like independent audits; dual CEO/CISO annual certification with 5-year record retention.

Why Organizations Use It

Mandatory for NY-regulated financial firms to avoid multimillion-dollar fines (e.g., Robinhood $30M).
Enhances resilience, reduces incident risk, builds stakeholder trust, lowers insurance premiums, and differentiates in vendor selection.

Implementation Overview

Phased roadmap: gap analysis, CISO appointment, risk assessment, MFA rollout, TPSP contracts, testing, evidence repository.
Targets NY financial services; small entities have limited exemptions.
No universal certification but annual filing and DFS examinations.

Key Differences

Aspect	ISO 27017	23 NYCRR 500
Scope	Cloud-specific security controls and guidance	Financial services cybersecurity program requirements
Industry	All industries using cloud services globally	NYDFS-regulated financial services entities only
Nature	Voluntary international code of practice	Mandatory state regulation with enforcement
Testing	Integrated into ISO 27001 audits, no standalone cert	Annual pen testing, vulnerability assessments required
Penalties	Loss of certification, no legal penalties	Multi-million dollar fines and consent orders

Scope

ISO 27017

Cloud-specific security controls and guidance

23 NYCRR 500

Financial services cybersecurity program requirements

Industry

ISO 27017

All industries using cloud services globally

23 NYCRR 500

NYDFS-regulated financial services entities only

Nature

ISO 27017

Voluntary international code of practice

23 NYCRR 500

Mandatory state regulation with enforcement

Testing

ISO 27017

Integrated into ISO 27001 audits, no standalone cert

23 NYCRR 500

Annual pen testing, vulnerability assessments required

Penalties

ISO 27017

Loss of certification, no legal penalties

23 NYCRR 500

Multi-million dollar fines and consent orders

Frequently Asked Questions

Common questions about ISO 27017 and 23 NYCRR 500

ISO 27017 FAQ

23 NYCRR 500 FAQ

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