White House Issues 2023 National Cybersecurity Strategy Implementation Plan

The White House released the National Cybersecurity Strategy Implementation Plan (NCSIP) on 13 July 2023, translating the March 2023 strategy into 65 concrete initiatives distributed across 18 federal lead agencies. Coordinated by the Office of the National Cyber Director (ONCD), the plan assigns timelines, performance metrics, and interagency coordination mechanisms under the strategy’s five pillars: defend critical infrastructure, disrupt and dismantle threat actors, shape market forces, invest in resilience, and build international partnerships. Boards and executive teams across regulated industries must interpret the plan as a signal of impending regulatory action—particularly mandates for minimum cybersecurity requirements, incident reporting, software liability, and data protection. They should adjust governance structures, implementation roadmaps, and DSAR playbooks so cyber incidents and compliance evidence remain defensible when regulators, customers, or litigants request information.

The NCSIP clarifies federal priorities for the next 12–24 months. Highlights include: developing cyber performance goals for critical infrastructure sectors; implementing the Cyber Incident Reporting for Critical Infrastructure Act (CIRCIA); harmonising federal regulatory requirements; expanding Joint Cyber Defense Collaborative operations; promoting secure-by-design software development; modernising public-sector cyber procurement; accelerating post-quantum cryptography migration; and deepening partnerships with allies on ransomware, supply chain, and digital rights. Each initiative identifies a lead agency—such as the Department of Homeland Security (DHS), Cybersecurity and Infrastructure Security Agency (CISA), National Institute of Standards and Technology (NIST), Department of Justice (DOJ), Department of Commerce, or Department of State—and supporting partners, giving industry participants a roadmap for stakeholder engagement.

Governance adjustments for industry

Boards should incorporate the NCSIP into enterprise risk management. Critical infrastructure operators—energy, healthcare, financial services, transportation, and water utilities—should expect sector risk management agencies (SRMAs) to translate federal cyber performance goals into enforceable regulations or contract requirements. Governance bodies must ensure management maps existing controls to forthcoming standards such as the North American Electric Reliability Corporation (NERC) CIP enhancements, Transportation Security Administration (TSA) security directives, or Health and Human Services (HHS) hospital resilience measures. Board technology committees should request quarterly briefings on agency rulemaking, public-private pilot programmes, and grant opportunities (for example, the State and Local Cybersecurity Grant Program) that can defray investment costs.

The plan underscores the administration’s intent to shift liability for insecure software toward manufacturers and service providers. Corporate secretaries should brief directors on potential legal reforms, including safe-harbour frameworks tied to compliance with NIST Secure Software Development Framework (SSDF) practices and software bills of materials (SBOMs). Governance policies should require procurement teams to collect attestations on secure development, vulnerability disclosure, and data-protection commitments from vendors. Boards overseeing cloud service providers or managed security firms should verify that contract templates anticipate enhanced oversight from the Federal Acquisition Regulatory (FAR) Council and the Office of Management and Budget (OMB), particularly around incident reporting and supply-chain transparency.

Implementation planning

Operational leaders should align cybersecurity programmes with specific NCSIP initiatives. For example, the plan directs CISA and the Environmental Protection Agency (EPA) to develop sector-specific cyber performance goals for the water sector by FY 2024. Water utilities should prioritise asset inventories, network segmentation, and OT incident response drills to demonstrate readiness. Healthcare providers should track HHS’s implementation of the Healthcare Sector Cybersecurity Strategy, including financial incentives for adopting minimum practices and penalties for non-compliance. Financial institutions should monitor the Treasury Department’s efforts to explore systemic incident management exercises and to expand adoption of the Financial Sector Cybersecurity Profile.

Implementation should also cover workforce and training commitments. The NCSIP tasks the Department of Labor and the National Science Foundation with scaling registered apprenticeships and K-12 cyber education. Companies can align by expanding apprenticeship programmes, partnering with community colleges, and supporting CyberCorps: Scholarship for Service graduates. Workforce dashboards should record diversity, certification attainment, and retention metrics—data that may be requested in DSARs by employees seeking confirmation of training or disciplinary records after cyber incidents.

Incident response plans must reflect the administration’s renewed emphasis on public-private collaboration. The plan highlights CISA’s expansion of the Joint Cyber Defense Collaborative (JCDC) and the FBI’s leadership in ransomware disruption. Organisations should ensure incident communications runbooks include contacts for JCDC engagement, FBI field offices, and the Treasury’s Financial Crimes Enforcement Network (FinCEN) for ransom payment reporting. Plans should also reference forthcoming CIRCIA rules (due by 2024) requiring covered entities to report substantial incidents within 72 hours and ransom payments within 24 hours. Implementation teams must build logging, forensic preservation, and DSAR retrieval capabilities that can support simultaneous regulatory reporting and privacy-rights fulfilment.

Data protection and DSAR implications

Cyber incidents often generate large volumes of personal data—system logs, access records, forensic images, and communications. The NCSIP’s push for mandatory reporting and cross-sector information sharing heightens the need for robust privacy governance. Organisations should update data inventories to classify incident response artefacts as personal data where applicable, noting legal bases for processing under regimes such as GDPR, CCPA, HIPAA, or GLBA. DSAR procedures must anticipate requests from employees, customers, or partners seeking confirmation of whether their data was compromised. Privacy teams should work with security operations to define retention periods for incident data, balancing regulatory hold requirements with minimisation principles. Where the plan encourages participation in cyber threat intelligence exchanges, companies must ensure shared indicators are properly anonymised or aggregated to respect privacy commitments.

The implementation plan also references digital identity, privacy-preserving technologies, and data security research. Agencies such as NIST, the National Science Foundation, and the Department of Energy are tasked with advancing post-quantum cryptography, zero-trust architectures, and secure cloud adoption. Organisations should align their encryption roadmaps with NIST’s post-quantum algorithms, maintain DSAR documentation showing cryptographic safeguards applied to personal data, and update consent notices when deploying new identity solutions like phishing-resistant multi-factor authentication. Records of processing should reflect any cross-border transfers associated with international cyber exercises or intelligence sharing, ensuring DSAR responses describe safeguards such as standard contractual clauses.

Engagement and assurance

Corporate affairs teams should map stakeholders for each relevant initiative. For instance, telecommunications providers should engage with the Federal Communications Commission (FCC) on plans to secure border gateway protocol (BGP) routing, while software publishers should participate in Commerce Department consultations on secure software self-attestation. Multinationals should liaise with the Departments of State and Commerce as the United States pursues agreements on cybercrime, ransomware, and digital trade, aligning company policies with commitments under the Counter-Ransomware Initiative and the Freedom Online Coalition.

Internal audit and compliance functions should develop assurance programmes linked to the NCSIP. Auditors can test whether cybersecurity investments align with federal incentives, verify that incident-response exercises include DSAR rehearsals, and evaluate contract clauses implementing software supply-chain requirements. Compliance should maintain a regulatory tracker covering forthcoming rules from agencies such as TSA (pipeline and rail security), the Securities and Exchange Commission (cyber incident disclosures), the Federal Trade Commission (commercial surveillance), and state authorities implementing consumer privacy laws. Metrics should include progress against the 65 initiatives, budget allocations, number of reportable incidents, and DSAR fulfilment times for breach-related requests.

By treating the NCSIP as a binding roadmap rather than an aspirational document, organisations can position themselves ahead of regulatory change, improve incident resilience, and demonstrate accountability. Coordinated governance, disciplined implementation, and privacy-aware evidence management will help enterprises respond effectively as federal agencies operationalise the National Cybersecurity Strategy in the months ahead.