Manage NYDFS 23 NYCRR 500 Compliance Software

The NYDFS cybersecurity regulation applies to covered entities, including financial services companies such as banks, insurers, mortgage brokers, and other institutions licensed or authorized to operate in New York. Compliance is mandatory for organizations under NYDFS jurisdiction, even if their headquarters are located outside the state. Covered entities must implement cybersecurity programs specifically designed to protect information systems and sensitive customer data.

NYDFS 23 NYCRR 500 outlines detailed cybersecurity requirements for financial institutions, including periodic risk assessments, maintenance of a risk register, management of asset and vendor inventories, implementation of access controls, and the development of incident response plans. Covered entities must also establish business continuity and disaster recovery strategies to minimize disruptions caused by cybersecurity events. Each requirement is designed to strengthen cybersecurity resilience and protect nonpublic information.

Isora GRC helps covered entities meet NYDFS requirements by centralizing risk assessments, tracking identified risks in a living risk register, maintaining asset and vendor inventories, and generating audit-ready compliance reports. Instead of relying on spreadsheets or disconnected surveys, institutions can streamline how they document cybersecurity risks, protect nonpublic information, and prepare for board and regulatory reviews with workflows built for security and compliance teams.

Yes. NYDFS 23 NYCRR 500 requires financial services companies to maintain an audit trail that records cybersecurity activities, risk assessments, access to critical systems, and incident response actions. Covered entities must keep these records for at least five years to support accountability, ensure traceability of cybersecurity events, and demonstrate compliance during regulatory examinations.

The regulation requires covered entities to implement written third-party service provider policies based on risk assessments. These policies must include minimum cybersecurity practices, due diligence evaluations, and periodic reassessments to ensure the security of nonpublic information managed by external vendors. Maintaining a dynamic vendor inventory and conducting regular risk reviews are essential to fulfilling NYDFS third-party risk management requirements.

Yes. Covered entities must appoint a Chief Information Security Officer (CISO) or another qualified information security officer responsible for overseeing the institution’s cybersecurity program. The CISO must report regularly to the board or senior officers on the institution’s cybersecurity risks, incident response efforts, and overall program maturity, ensuring leadership maintains visibility into cybersecurity governance and risk management efforts.

If a covered entity experiences a cybersecurity event, it must activate its incident response plan and notify NYDFS within 72 hours of determining that the event has a reasonable likelihood of materially harming operations. Institutions must also review and update their cybersecurity programs based on lessons learned, maintain an audit trail of the event, and report outcomes to leadership and regulators as part of the ongoing compliance process.

NYDFS 23 NYCRR 500 requires covered entities to develop and maintain business continuity and disaster recovery plans that specifically address cybersecurity risks. These plans must ensure the institution can continue critical operations, recover nonpublic information, and restore information systems after cybersecurity events. Regular testing, updates, and staff training are essential parts of maintaining operational resilience and satisfying regulatory expectations.