What is the primary objective of NIST 800-171?

**NIST 800-171 provides recommended security requirements for protecting the confidentiality of Controlled Unclassified Information (CUI) in nonfederal systems and organizations.** It ensures consistent safeguards for CUI processed, stored, or transmitted by contractors, tailored from SP 800-53 moderate baseline without full federal FISMA obligations.

Who is legally or professionally required to comply with NIST 800-171?

**Nonfederal organizations handling CUI via federal contracts, grants, or agreements must implement NIST 800-171.** This includes DoD contractors under DFARS 252.204-7012 for covered defense information (CDI), subcontractors, and supply chain entities; compliance is contractually mandated, not universally statutory.

Does NIST 800-171 require an external audit or third-party certification?

**NIST 800-171 does not mandate external audits but requires SSP/POA&M documentation and assessments per SP 800-171A.** DoD enforces via self-assessments (Basic), reviews (Medium/High), or CMMC Level 2 C3PAO certification for prioritized contracts.

How often should an assessment for NIST 800-171 be performed?

**Organizations should perform NIST 800-171 assessments annually or upon significant changes, aligning with DoD SPRS reaffirmation.** CMMC Level 2 requires triennial third-party certification with annual affirmations; continuous monitoring supports ongoing compliance.

What are the consequences of non-compliance with NIST 800-171?

**Non-compliance with NIST 800-171 risks contract ineligibility, termination, SPRS score penalties, and CMMC disqualification.** DoD may impose remediation demands, False Claims Act liability, reputational damage, and exclusion from $150B+ procurement opportunities.

Can NIST 800-171 be mapped to other international frameworks?

**Yes, NIST 800-171 maps directly to SP 800-53, ISO 27001, and NIST CSF via Appendix D.** R3 aligns with SP 800-53R5; supports integration with enterprise ISMS while maintaining CUI-specific tailoring.

What is the first step to begin implementing NIST 800-171?

**The first step is defining CUI scope by identifying systems processing/storing/transmitting CUI and isolating a security domain.** Conduct gap analysis against 97 R3 requirements, prioritizing SSP development and high-impact controls like MFA and logging.

What is the primary objective of 23 NYCRR 500?

**23 NYCRR 500 establishes minimum cybersecurity standards for financial services entities to protect nonpublic information and information systems.** Adopted in 2017 with 2023 amendments, it requires Covered Entities—NY-licensed banks, insurers, and others—to implement risk-based programs addressing governance, access controls, testing, and incident response to safeguard operations and customer data from cyber threats.

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

**23 NYCRR 500 applies to all Covered Entities operating under NY Banking, Insurance, or Financial Services Law licenses.** This includes state-chartered banks, insurers, mortgage brokers, virtual currency licensees, HMOs, and NY branches of foreign banks handling NPI; limited exemptions exist for small entities with <10 employees, <$5M NY revenue, or <$10M assets, but core obligations like risk assessments remain.

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

**No, 23 NYCRR 500 does not mandate external audits or third-party certifications for all entities, but Class A companies require independent audits.** NYDFS conducts examinations; entities must retain five-year evidence for annual CEO/CISO certifications and provide penetration testing reports, with TPSP oversight including audit rights in contracts.

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

**Risk assessments under 23 NYCRR 500 must be performed annually and updated upon material changes.** Section 500.9 requires documented, repeatable methodologies (e.g., NIST CSF) evaluating threats, vulnerabilities, and controls, informing program design, testing, and remediation.

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

**Non-compliance with 23 NYCRR 500 results in multimillion-dollar fines, consent orders, and remediation mandates from NYDFS.** Enforcement examples include Robinhood Crypto ($30M), OneMain Financial ($4.25M), and Healthplex ($2M), targeting governance failures, weak TPSP oversight, and deficient MFA/encryption.

Can 23 NYCRR 500 be mapped to other international frameworks?

**Yes, 23 NYCRR 500 aligns closely with NIST CSF, CRI Profile, and ISO 27001 for risk assessments and controls.** Its requirements for MFA, encryption, penetration testing, and incident response map directly, enabling integrated compliance with enterprise risk management frameworks while meeting NYDFS prescriptive elements.

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

**The first step for 23 NYCRR 500 implementation is determining Covered Entity status and conducting a gap analysis against the 14 core requirements.** Use NYDFS exemption flowchart, appoint a qualified CISO with board access, and perform an initial risk assessment on critical assets, privileged accounts, and TPSPs to build a prioritized remediation roadmap.

NIST 800-171 vs 23 NYCRR 500

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

**No, 23 NYCRR 500 does not mandate external audits or third-party certifications for all entities, but Class A companies require independent audits.** NYDFS conducts examinations; entities must retain five-year evidence for annual CEO/CISO certifications and provide penetration testing reports, with TPSP oversight including audit rights in contracts.

Standards Comparison

NIST 800-171

Mandatory

2020

U.S. standard protecting CUI in nonfederal systems

23 NYCRR 500

Mandatory

2017

New York regulation for financial services cybersecurity.

Quick Verdict

NIST 800-171 mandates CUI safeguards for defense contractors via contracts, while 23 NYCRR 500 enforces cybersecurity for NY financial firms with fines. Firms adopt NIST for federal eligibility; NYCRR for regulatory compliance.

Controlled Unclassified Information

NIST 800-171

NIST SP 800-171R3: Protecting CUI in Nonfederal Systems

Cost

€€€€

Complexity

Medium

Implementation Time

6-12 months

Key Features

Tailored 110 controls for CUI confidentiality protection
Scoped to nonfederal systems processing/storing/transmitting CUI
Requires System Security Plan (SSP) and POA&M
Supports CUI security domain isolation for scoping
Derived from SP 800-53 moderate baseline

Financial Services

23 NYCRR 500

23 NYCRR Part 500

Cost

€€€€

Complexity

High

Implementation Time

18-24 months

Key Features

Annual CEO/CISO compliance certification with five-year retention
72-hour notification for material cybersecurity incidents
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.

NIST 800-171 Details

What It Is

NIST SP 800-171 Revision 3 is a U.S. government framework providing security requirements for protecting Controlled Unclassified Information (CUI) confidentiality in nonfederal systems. It tailors controls from SP 800-53 moderate baseline for contractors and supply chains, emphasizing risk-commensurate safeguards without full federal FISMA obligations.

Key Components

97 requirements across 17 families (e.g., Access Control, Audit, Supply Chain Risk Management).
Derived from FIPS 200 and SP 800-53R5; eliminates basic/derived split.
Requires System Security Plan (SSP) and Plan of Action and Milestones (POA&M).
Assessment via SP 800-171A R3 (examine/interview/test); DoD scoring (up to 110 points).

Why Organizations Use It

Mandatory via contracts (e.g., DFARS 252.204-7012) for DoD CUI handlers.
Enables contract eligibility, CMMC Level 2 certification.
Reduces breach risk, builds supply chain trust.
Supports FedRAMP Moderate equivalence for cloud.

Implementation Overview

Scope CUI enclave; gap analysis; remediate high-impact controls (MFA, logging).
Develop SSP/POA&M; continuous monitoring.
Applies to federal contractors; 3-36 months typical, varying by size.

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 for financial services entities. It establishes minimum, risk-based cybersecurity requirements to protect nonpublic information (NPI) and information systems. The approach emphasizes governance, evidence-based controls, and adaptability to evolving threats.

Key Components

14 core requirements including cybersecurity program, policy, CISO appointment, MFA, encryption, risk assessments, penetration testing, TPSP oversight, and incident response.
Built on risk assessment as the foundation, with annual certifications and 72-hour incident notifications.
Phased compliance for Class A companies with enhanced audits and controls; five-year record retention.

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 negotiations and insurance premiums.

Implementation Overview

Applies to Covered Entities in NY financial services; scalable by size/complexity.
Phased roadmap: gap analysis, asset inventory, MFA rollout, TPSP contracts, testing, evidence repository.
No external certification but NYDFS examinations and annual CEO/CISO attestations required. (178 words)

Key Differences

Aspect	NIST 800-171	23 NYCRR 500
Scope	CUI protection in nonfederal systems, 17 families	Financial services cybersecurity, NPI protection
Industry	Defense contractors, federal supply chain, US-focused	NY-licensed financial entities, state-specific
Nature	NIST recommendation, contractually mandatory via DFARS	Mandatory state regulation with fines/enforcement
Testing	SP 800-171A procedures, CMMC assessments, self/3PAO	Annual pen testing, vulnerability assessments, risk-based
Penalties	Contract ineligibility, SPRS scoring impacts awards	Monetary fines, consent orders, license actions

Scope

NIST 800-171

CUI protection in nonfederal systems, 17 families

23 NYCRR 500

Financial services cybersecurity, NPI protection

Industry

NIST 800-171

Defense contractors, federal supply chain, US-focused

23 NYCRR 500

NY-licensed financial entities, state-specific

Nature

NIST 800-171

NIST recommendation, contractually mandatory via DFARS

23 NYCRR 500

Mandatory state regulation with fines/enforcement

Testing

NIST 800-171

SP 800-171A procedures, CMMC assessments, self/3PAO

23 NYCRR 500

Annual pen testing, vulnerability assessments, risk-based

Penalties

NIST 800-171

Contract ineligibility, SPRS scoring impacts awards

23 NYCRR 500

Monetary fines, consent orders, license actions

Frequently Asked Questions

Common questions about NIST 800-171 and 23 NYCRR 500

NIST 800-171 FAQ

23 NYCRR 500 FAQ

You Might also be Interested in These Articles...

Top 5 Reasons Automation Tools Like Vanta Slash SOC 2 Type 2 Timelines from Months to Weeks

Automation tools like Vanta cut SOC 2 Type 2 prep from 6 months to 6 weeks, saving 70% costs. See SignWell examples, AWS/Okta/GitHub integrations. CISOs: Get fi

ISO 27701 Implementation Roadmap: Step-by-Step Guide for Extending Your ISO 27001 ISMS to PIMS

Extend ISO 27001 ISMS to ISO 27701 PIMS with this step-by-step roadmap. Master role-specific controls, avoid pitfalls, meet certification evidence needs for pri

Step-by-Step Implementation Guide to ISO 27701: Building a Privacy Information Management System (PIMS) on Your ISO 27001 Foundation

Implement ISO 27701 on your ISO 27001 foundation with this actionable guide. Tackle PII controls, audit evidence, GDPR integration. Templates, checklists for 20

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

HIPAA vs MLPS 2.0 (Multi-Level Protection Scheme)

Discover HIPAA vs MLPS 2.0: US privacy rules meet China's cybersecurity scheme. Unlock key differences, compliance strategies & risk insights for global health data protection now.

ISO 17025 vs MAS TRM

Explore ISO 17025 vs MAS TRM: Compare lab competence standards with Singapore's tech risk guidelines for accreditation, governance & resilience. Optimize now!

COBIT vs ISO 14064

Explore COBIT vs ISO 14064: IT governance framework meets GHG emissions standards. Tailor enterprise risk, compliance & sustainability. Discover key diffs & best fit now!