Standards Comparison

    NIST CSF

    Voluntary
    2024

    Voluntary framework for managing cybersecurity risks organization-wide

    VS

    FDA 21 CFR Part 11

    Mandatory
    1997

    FDA regulation for trustworthy electronic records and signatures

    Quick Verdict

    NIST CSF offers voluntary cybersecurity risk management for all organizations, while FDA 21 CFR Part 11 mandates electronic record/signature controls for life sciences. Companies adopt NIST for strategic posture, Part 11 for regulatory compliance.

    Cybersecurity

    NIST CSF

    NIST Cybersecurity Framework (CSF) 2.0

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

    Key Features

    • Introduces Govern function as central governance hub
    • Creates Current and Target Profiles for gap analysis
    • Defines 4 Implementation Tiers for maturity assessment
    • Provides common language for stakeholder risk communication
    • Maps 112 subcategories to standards like ISO 27001
    Electronic Records

    FDA 21 CFR Part 11

    21 CFR Part 11 Electronic Records; Electronic Signatures

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

    Key Features

    • Risk-based validation of computerized systems
    • Secure time-stamped audit trails for changes
    • Electronic signatures equivalent to handwritten
    • Closed and open system access controls
    • Predicate rule scoping for narrow applicability

    Detailed Analysis

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

    NIST CSF Details

    What It Is

    NIST Cybersecurity Framework (CSF) 2.0 is a voluntary, risk-based guideline developed by the U.S. National Institute of Standards and Technology. It provides organizations a flexible structure to identify, protect against, detect, respond to, recover from, and govern cybersecurity risks, applicable across all sizes, sectors, and maturity levels.

    Key Components

    • **Six Core FunctionsGovern (new), Identify, Protect, Detect, Respond, Recover.
    • 22 Categories and 112 Subcategories organized hierarchically with informative references to standards like ISO 27001 and NIST SP 800-53.
    • Implementation Tiers (Partial to Adaptive) for assessing risk management sophistication.
    • Profiles for aligning current and target states; no formal certification, self-attestation suffices.

    Why Organizations Use It

    Enhances risk prioritization, fosters common cybersecurity language for executives and partners, demonstrates due care, supports compliance (mandatory for U.S. federal), reduces supply chain threats, and builds stakeholder trust through measurable outcomes.

    Implementation Overview

    Start with Current Profile assessment, conduct gap analysis to Target Profile, prioritize via Tiers. Involves policy development, training, tooling integration; suitable for all organizations globally; audits optional via third parties. (178 words)

    FDA 21 CFR Part 11 Details

    What It Is

    FDA 21 CFR Part 11 is a US federal regulation setting criteria under which electronic records and electronic signatures are considered trustworthy, reliable, and equivalent to paper records and handwritten signatures. It targets FDA-regulated activities in pharma, devices, and biologics where electronic records replace paper under predicate rules. Employs a risk-based approach with narrow scope via 2003 FDA guidance, exercising discretion on validation, audit trails, retention.

    Key Components

    • **Subpart AScope, definitions; **BClosed (§11.10)/open (§11.30) system controls (access, audit trails, checks); **CSignatures (manifestation §11.50, linking §11.70, uniqueness §11.100).
    • ~20 core controls including validation, secure audit trails, multi-component signatures.
    • Built on data integrity (ALCOA+), non-repudiation.
    • Compliance via computerized system validation (CSV), no certification but FDA inspection.

    Why Organizations Use It

    • Mandatory for electronic reliance in regulated records.
    • Prevents warning letters, ensures data integrity.
    • Enables efficiency, paperless ops, faster inspections.
    • Builds trust, supports digital transformation.

    Implementation Overview

    • Phased: scoping, risk assessment, CSV (IQ/OQ/PQ), SOPs/training, monitoring.
    • Life sciences orgs; global via harmonization.
    • FDA verifies via inspections.

    Key Differences

    Scope

    NIST CSF
    Cybersecurity risk management across all functions
    FDA 21 CFR Part 11
    Electronic records/signatures trustworthiness controls

    Industry

    NIST CSF
    All sectors worldwide, any size
    FDA 21 CFR Part 11
    Life sciences, pharma, medical devices US-regulated

    Nature

    NIST CSF
    Voluntary risk framework, no certification
    FDA 21 CFR Part 11
    Mandatory regulation for electronic records

    Testing

    NIST CSF
    Self-assessment, profiles, tiers
    FDA 21 CFR Part 11
    System validation IQ/OQ/PQ, audit trails

    Penalties

    NIST CSF
    No legal penalties, reputational risk
    FDA 21 CFR Part 11
    Warning letters, fines, product holds

    Frequently Asked Questions

    Common questions about NIST CSF and FDA 21 CFR Part 11

    NIST CSF FAQ

    FDA 21 CFR Part 11 FAQ

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