Standards Comparison

    TOGAF

    Voluntary
    2022

    Vendor-neutral framework for enterprise architecture development

    VS

    23 NYCRR 500

    Mandatory
    2017

    New York regulation for financial services cybersecurity.

    Quick Verdict

    TOGAF provides proven enterprise architecture methodology for global organizations aligning business and IT, while 23 NYCRR 500 mandates cybersecurity controls for NY financial entities. Companies use TOGAF for strategic alignment; Part 500 for regulatory compliance and risk reduction.

    Enterprise Architecture

    TOGAF

    TOGAF® Standard, 10th Edition

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

    Key Features

    • Iterative ADM lifecycle for architecture development
    • Content Framework with metamodel for standardized artifacts
    • Enterprise Continuum enabling reusable architecture assets
    • Architecture Capability Framework for governance structures
    • Reference models like TRM, SIB, and III-RM
    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
    • Comprehensive third-party service provider oversight
    • Risk-based annual penetration testing requirements

    Detailed Analysis

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

    TOGAF Details

    What It Is

    TOGAF® Standard, 10th Edition is a vendor-neutral enterprise architecture framework developed by The Open Group. Its primary purpose is to provide proven methodology for designing, planning, implementing, and governing enterprise-wide change across business and IT. The core approach is the iterative Architecture Development Method (ADM), supporting tailoring to organizational contexts.

    Key Components

    • **ADM phasesPreliminary, A-H, plus continuous Requirements Management.
    • **Content FrameworkDeliverables, artifacts, building blocks, and metamodel with core entities like actors, services, data entities.
    • Enterprise Continuum, Architecture Repository, Reference Models (TRM, SIB, III-RM).
    • Architecture Capability Framework for governance, skills, maturity. No formal certification for organizations; practitioner certifications available.

    Why Organizations Use It

    Drives strategic alignment, reuse, risk reduction, ROI improvement. Enables consistent standards, avoids vendor lock-in, supports agility. Builds stakeholder trust through governed, traceable architectures; applicable to large enterprises across industries.

    Implementation Overview

    Phased rollout: Preliminary capability setup, ADM iteration via pilots, governance embedding. Suited for mid-to-large organizations; requires tailoring, repository, training. No mandatory audits; self-assessed maturity via ACMM.

    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 evidence-based compliance.

    Key Components

    • 14 core requirements including cybersecurity program, CISO appointment, MFA, encryption, risk assessments, penetration testing, third-party oversight, and 72-hour incident reporting.
    • Built on risk-assessment-centric architecture with annual CISO/CEO certification and five-year record retention.
    • Class A companies (high revenue/employees) face enhanced audits and controls; limited exemptions for small entities.

    Why Organizations Use It

    • Mandatory for NY-licensed financial entities (banks, insurers, etc.) to avoid multimillion-dollar fines (e.g., Robinhood $30M).
    • Enhances resilience, vendor management, and executive accountability; aligns with NIST CSF.
    • Builds stakeholder trust and reduces incident risks.

    Implementation Overview

    • Phased roadmap: governance, risk assessment, MFA rollout, asset inventory, testing.
    • Applies to NY-regulated firms regardless of location; DFS provides templates.
    • No external certification but annual filing and examinations require auditable evidence (~180 words).

    Key Differences

    Scope

    TOGAF
    Enterprise architecture lifecycle and governance
    23 NYCRR 500
    Cybersecurity program and controls for financial entities

    Industry

    TOGAF
    All industries worldwide, any organization size
    23 NYCRR 500
    NY financial services, licensed entities primarily

    Nature

    TOGAF
    Voluntary EA methodology and framework
    23 NYCRR 500
    Mandatory state regulation with enforcement

    Testing

    TOGAF
    Maturity assessments, compliance reviews optional
    23 NYCRR 500
    Annual pen testing, vulnerability scans required

    Penalties

    TOGAF
    No legal penalties, certification optional
    23 NYCRR 500
    Fines, consent orders, license actions possible

    Frequently Asked Questions

    Common questions about TOGAF and 23 NYCRR 500

    TOGAF FAQ

    23 NYCRR 500 FAQ

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