Operational Resilience
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NY DFS 23 NYCRR 500 — New York Cybersecurity Regulation

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Overview

NY DFS 23 NYCRR 500 is a cybersecurity regulation that establishes minimum security requirements for financial institutions operating under New York State jurisdiction to safeguard sensitive customer data and ensure resilient cyber risk management. The regulation focuses on protecting the confidentiality and integrity of information systems that support financial operations.

Issued by the New York State Department of Financial Services (NYDFS), 23 NYCRR 500 applies to banks, insurance companies, and other covered entities regulated by NYDFS. The rule mandates robust cybersecurity controls, including risk assessments, incident response planning, audit trails, multi-factor authentication, and third-party service provider oversight, reflecting the sector’s focus on operational resilience and regulatory compliance.

Organizations implement 23 NYCRR 500 by developing a cybersecurity program aligned with its requirements, appointing a Chief Information Security Officer (CISO), conducting regular risk assessments, and maintaining documentation to support regulatory examinations. The regulation complements other cybersecurity standards such as NIST and ISO, and serves as a foundational component of compliance programs within the financial sector.

Why it Matters

NY DFS 23 NYCRR 500 establishes a rigorous cybersecurity baselinethat helps financial institutions safeguard information systems andmeet regulatory obligations.

Key benefits include:

  • Strengthen cybersecurity governance

Support thedevelopment of comprehensive security oversight by requiringleadership accountability and formal risk assessments.

  • Enhance regulatory alignment

Promoteconsistency with state-mandated requirements, ensuring financialorganizations maintain compliance with New York regulatoryexpectations.

  • Improve incident response readiness

Mandate incidentresponse planning and reporting, accelerating threat detection,containment, and required communications during cyber events.

  • Boost third-party risk management

Require oversightof service providers to reduce supply chain vulnerabilities andensure vendors meet appropriate security standards.

  • Increase audit and examination preparedness

Standardizedocumentation and processes to simplify compliance validation andfacilitate smoother regulatory inspections and audits.

How it Works

The NY DFS 23 NYCRR 500 regulation structures its requirements into aseries of regulatory mandates and cybersecurity program elementsspecific to financial services organizations. It establishesgovernance domains such as risk assessment, access controls,encryption, incident response, and reporting obligations. Theframework requires ongoing board involvement, continuous riskmanagement processes, and the implementation of defined securitycontrols and policies tailored to the unique risks faced by coveredentities.

Organizations implement NY DFS 23 NYCRR 500 by conducting regularrisk assessments, developing and maintaining cybersecurity policies,instituting technical and administrative controls, and ensuringemployee training. Compliance activities include monitoring securitypractices, maintaining audit trails, managing incident responseplans, and preparing for annual certification submissions to the NewYork Department of Financial Services (DFS). Ongoing compliancemonitoring and adjustments are essential to address evolving threatsand regulatory expectations.

With SmartSuite, organizations operationalize NY DFS 23 NYCRR 500through integrated control libraries, a centralized risk register,automated compliance tracking, and streamlined evidence collection.SmartSuite supports policy governance and facilitates remediationworkflows, while reporting dashboards aid in audit readiness and theeffective management of ongoing cyber risk and regulatoryobligations.

Key Elements

  • Cybersecurity Program Structure

Specifiesrequirements for developing and maintaining a documentedcybersecurity program addressing information security risks.

  • Governance and Oversight Functions

Establishesaccountability through designated roles, such as the ChiefInformation Security Officer, and regular board reporting.

  • Risk Assessment Processes

Describesstructured evaluation and analysis of cybersecurity threats andvulnerabilities relevant to business operations.

  • Access and Authentication Controls

Definesmechanisms for securing systems and data, including requirements formulti-factor authentication and access management.

  • Incident Response and Recovery

Outlinesprotocols for detecting, reporting, and recovering from cybersecurityincidents, ensuring organizational resilience.

  • Audit Trail and Monitoring

Provides mandatesfor monitoring activity, maintaining logs, and establishing audittrails of critical systems and data.

  • Third-Party Risk Management

Organizescontrols addressing cybersecurity due diligence and oversight forexternal service providers with access to sensitive information.

Framework Scope

NY DFS 23 NYCRR 500 is adopted by banks, insurance firms, andfinancial service providers subject to New York State regulation. Thestandard governs the confidentiality, integrity, and availability ofinformation systems supporting financial operations, and is typicallyimplemented when meeting cybersecurity regulatory obligations andsupporting compliance oversight and operational resilience within thefinancial sector.

Framework Objectives

NY DFS 23 NYCRR 500 sets forth minimum cybersecurity standards tostrengthen risk management and regulatory compliance for financialinstitutions.

Safeguard sensitive customer data and maintain the confidentiality offinancial information

Enhance risk management practices through continuous cybersecurityassessment and oversight

Strengthen governance and accountability with executiveresponsibility for security controls

Support regulatory compliance by establishing clear documentation andaudit processes

Improve operational resilience against cyber threats and disruptions

Enable ongoing data protection through robust policies and continuousmonitoring NY DFS 23 NYCRR 500 is a New York state regulation forfinancial services, requiring organizations to implement and maintainrobust cybersecurity programs. It aligns with frameworks like NISTCybersecurity Framework, GLBA Safeguards Rule, and FFIEC CAT.Regulated entities use it primarily for meeting legal compliance,managing operational risk, and demonstrating resilience to stateregulators.

Framework in Context

NY DFS 23 NYCRR 500is a New York state regulation for financial services, requiringorganizations to implement and maintain robust cybersecurityprograms. It aligns with frameworks like NIST CybersecurityFramework, GLBA Safeguards Rule, and FFIEC CAT. Regulated entitiesuse it primarily for meeting legal compliance, managing operationalrisk, and demonstrating resilience to state regulators.

Common Framework Mappings

NY DFS 23 NYCRR 500 is often mapped to other leading cybersecurityand regulatory frameworks to streamline compliance, enhance riskmanagement, and improve alignment with industry best practices in thefinancial services sector.

Mapped frameworks include:

CIS Critical Security Controls

FFIEC Cybersecurity Assessment Tool

Gramm-Leach-Bliley Act (GLBA) Safeguards Rule

ISO/IEC 27001

NIST Cybersecurity Framework

NIST SP 800-53

PCI DSS

SOC 2

At a Glance
NYDFS 23 NYCRR 500
  • checklist
    Classification
    Category
    info
    Operational Resilience
    Domain
    info
    Financial Services Regulation
    Framework Family
    info
    Other
  • info
    Regulatory Context
    Type
    info
    Regulation
    Legal Instrument
    info
    Regulation
    Sector
    info
    Financial Sector
    Industry
    info
    Financial Services
  • arrow_upload_ready
    Region / Publisher
    Region
    info
    North America
    Region Detail
    info
    New York
    Publisher
    info
    New York State Department of Financial Services
  • published_with_changes
    Versioning
    Version
    info
    23 NYCRR Part 500 (2023 Amendment 2)
    Effective Date
    info
    November 1, 2023
    Issue Date
    info
    November 1, 2023
  • graph_3
    Adoption
    Adoption Model
    info
    Regulatory Compliance
    Implementation Complexity
    info
    High
  • captive_portal
    Official Reference
License Information

License included / downloadable: Yes

The NYDFS Cybersecurity Regulation is publicly available through the New York Department of Financial Services.

Official Resources
NYDFS Cybersecurity Regulation (23 NYCRR 500)
Defines the cybersecurity program requirements for financial institutions under New York jurisdiction.
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SMARTSUITE

How SmartSuite Supports US - NY DFS 23 NYCRR500 2023 Amd 2

Centralize controls, evidence, and audit workflows to stay continuously SOC 2–ready.

Regulation Requirement Library

Track DFS 500 requirements with owners, scope, and implementation evidence.

Risk Assessments and Governance Reporting

Run periodic risk assessments and maintain board/management reporting evidence.

Control Testing and Evidence Capture

Schedule testing, monitoring, and evidence capture for key cybersecurity controls.

Incident Escalation and Reporting

Track events, escalation decisions, and reporting readiness with full documentation.

Vendor Due Diligence and Ongoing Monitoring

Manage vendor due diligence, contract requirements, and ongoing monitoring.

Audit and Examination Reporting

Report readiness, gaps, and evidence coverage for audits and regulator exams.

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FFIEC CAT

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GLBA Safeguards Rule (16 CFR Part 314)

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ISO 27001:2022

ISO/IEC 27001:2022 is an international ISMS standard that helps organizations manage information security risks and protect data.

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NIST CSF 2.0

NIST Cybersecurity Framework (CSF) v2.0 is a risk-based framework that helps organizations manage and reduce cybersecurity risks.

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SOC 2

SOC 2 assesses and reports on a service organization's controls for security, availability, processing integrity, confidentiality, and privacy.

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ONBOARDING FAQS

Frequently Asked Questions For NY DFS 23 NYCRR 500 (New York Cybersecurity Regulation)

What is NY DFS 23 NYCRR 500 used for?

NY DFS 23 NYCRR 500 establishes minimum cybersecurity requirements for financial institutions regulated by the New York State Department of Financial Services. Its primary purpose is to protect the confidentiality, integrity, and availability of sensitive nonpublic information and financial systems against evolving cyber threats.

Is NY DFS 23 NYCRR 500 mandatory for all organizations?

NY DFS 23 NYCRR 500 is mandatory for entities regulated by NYDFS, including banks, insurance companies, and certain financial service providers operating in New York. There are limited exemptions, but most covered entities must comply with all applicable sections of the regulation.

What organizations are in scope for NY DFS 23 NYCRR 500?

The regulation applies to all “covered entities” overseen by NYDFS, such as state-chartered banks, licensed lenders, insurance companies, trust companies, and mortgage brokers. Third-party service providers that handle sensitive data on behalf of these entities are also subject to specific oversight requirements.

What are the key control requirements of NY DFS 23 NYCRR 500?

Entities must implement a comprehensive cybersecurity program, conduct regular risk assessments, ensure access controls and data encryption, deploy multi-factor authentication, maintain audit trails, and develop incident response and business continuity plans. Oversight of third-party service providers and regular cybersecurity training are also required.

How does an organization implement NY DFS 23 NYCRR 500?

Implementation involves developing formal cybersecurity policies and procedures, appointing a qualified Chief Information Security Officer (CISO), mapping controls to regulatory requirements, and establishing documentation to evidence compliance. Regular testing, risk-based security controls, and board-level reporting are fundamental steps in the process.

How does NY DFS 23 NYCRR 500 relate to other cybersecurity frameworks such as NIST or ISO 27001?

NY DFS 23 NYCRR 500 incorporates similar concepts to NIST and ISO 27001, such as risk management, access controls, and incident response, but is specific to New York-regulated financial institutions. Organizations often align their compliance programs to address overlaps and maintain consistency across multiple frameworks.

How would SmartSuite support NY DFS 23 NYCRR 500?

SmartSuite enables organizations to manage NY DFS 23 NYCRR 500 compliance by centralizing risk registers, mapping and tracking controls, collecting and attaching evidence to compliance tasks, and automating remediation workflows. Its audit readiness templates and configurable dashboards help monitor compliance posture, streamline reporting, and facilitate regulatory examinations.

Operationalize NYDFS 23 NYCRR 500 with Connected Workflows

Manage controls, risks, evidence, and audits in one platform designed for modern governance, risk, and compliance.

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