ONCD Releases National Cybersecurity Strategy Implementation Plan — July 13, 2023

The White House Office of the National Cyber Director (ONCD) released the National Cybersecurity Strategy Implementation Plan (NCSIP) on 13 July 2023, translating the March 2023 National Cybersecurity Strategy into 69 discrete initiatives with assigned lead agencies, supporting partners, and target completion windows. The plan clusters actions into the strategy’s five pillars—defending critical infrastructure, disrupting threat actors, shaping market forces, investing in resilience, and forging international partnerships—and highlights 18 “high-impact” deliverables slated for completion within 12 months. Because the NCSIP will shape forthcoming rulemakings, funding allocations, and interagency coordination, corporate governance teams need a playbook for aligning board oversight, regulatory horizon scanning, and privacy operations, including DSAR readiness, to the plan’s cadence.

Each initiative is cross-referenced to existing statutory authorities and policy commitments. For example, CISA and the Sector Risk Management Agencies must publish sector-specific cybersecurity performance goals, TSA will extend pipeline and rail directives, and HHS will launch a strategy to shore up hospital cyber resilience. Treasury and Justice are instructed to expand joint disruption campaigns against ransomware operators, while OMB leads efforts to operationalise secure software development attestations across federal suppliers. The Commerce Department, NIST, and other science agencies must drive adoption of post-quantum cryptography and trusted infrastructure baselines, and State’s Bureau of Cyberspace and Digital Policy must formalise international partnerships. For boards, these tasks foreshadow concrete regulatory impacts such as mandatory incident reporting for critical infrastructure (stemming from the forthcoming CIRCIA rule), software supply-chain attestations, and sector-specific performance metrics that will be referenced by examiners and investors.

Governance actions for directors and risk committees

Boards should treat the NCSIP as a forward-looking regulatory calendar. Governance committees can map the 69 initiatives to enterprise risk registers, highlighting where agencies intend to issue rules, expand supervision, or update performance expectations. The plan’s four-business-day Form 8-K alignment for public companies, the anticipated update to TSA’s pipeline directives, the Environmental Protection Agency’s (EPA) water-system support actions, and new voluntary-but-highly-influential performance goals all create oversight responsibilities. Directors should require management to present quarterly updates on the federal initiatives that overlap with their sectors, emphasising how the company is preparing for new reporting obligations, investing in secure-by-design practices, and coordinating with Information Sharing and Analysis Centers (ISACs) or Sector Coordinating Councils.

• Assign accountable executives. Because many initiatives implicate multiple corporate functions—security engineering, compliance, privacy, procurement, and legal—boards should ask the CEO to designate accountable executives for each cluster: incident reporting, secure software development, critical infrastructure resilience, and international data flows. Those executives must maintain evidence logs that demonstrate how the company is preparing to comply with expected rules, such as CIRCIA reporting playbooks and SEC incident disclosure procedures.
• Integrate DSAR oversight. The NCSIP emphasises data stewardship and public trust, particularly in Pillar 3’s focus on reshaping market forces toward accountability. Directors should insist that privacy officers demonstrate how incident response and DSAR fulfilment processes intersect. The board’s risk committee can review metrics on DSAR turnaround time, identity verification controls, and cross-border data localisation so that any new reporting requirements do not compromise the organisation’s ability to honour privacy requests within statutory timelines.
• Track funding incentives. Pillar 4 instructs Commerce, Energy, and Homeland Security to leverage federal grants and the Infrastructure Investment and Jobs Act to accelerate secure infrastructure deployments. Boards should monitor these programmes to identify co-funding opportunities for OT segmentation, zero-trust pilots, and workforce development that can simultaneously strengthen DSAR-supporting data inventories.

Implementation roadmap mapped to the five pillars

Security leaders should organise their programme updates using the plan’s pillars. For Pillar 1 (Defend Critical Infrastructure), CISA must issue the National Cyber Incident Response Plan update, codify cross-sector performance goals, and support SRMAs in implementing sector risk assessments. Private operators can pre-position resources by aligning internal control frameworks with the forthcoming goals, testing incident reporting orchestration, and rehearsing DSAR communications that might accompany a notifiable event. Pillar 2 (Disrupt and Dismantle Threat Actors) directs FBI, CISA, and Treasury to expand joint task forces and sanctions. Companies should prepare for increased law enforcement requests and ensure that data retention policies, evidence-handling protocols, and DSAR exception handling are documented so collaboration with authorities remains proportionate and privacy-preserving.

Pillar 3 (Shape Market Forces) may be the most consequential for software-producing organisations. OMB’s memorandum M-22-18 already requires self-attestation of secure software development practices; the NCSIP tasks OMB with establishing a repository to collect those attestations and to formalise third-party assessment requirements by fiscal year 2025. Procurement and engineering teams should inventory software bill of materials (SBOM) coverage, verify provenance for open-source dependencies, and ensure that DSAR tooling retains visibility into data transformations across updated services. For Pillar 4 (Invest in a Resilient Future), initiatives include expanding the National Cyber Workforce and Education Strategy, developing post-quantum migration roadmaps, and funding research on secure-by-design hardware. Organisations can prepare by drafting migration runbooks that consider how DSAR archives and encryption key management will evolve in a post-quantum context.

Pillar 5 (Forge International Partnerships) charges State, Commerce, and USAID to operationalise the Declaration for the Future of the Internet, advance mutual assistance on ransomware, and drive global privacy-protective data flows. Multinationals should align their cross-border data transfer impact assessments with these diplomatic efforts, ensuring DSAR processes account for new memoranda of understanding, mutual legal assistance treaties, and data localisation constraints highlighted in the plan. Privacy officers should harmonise regulatory intelligence across EU, UK, Indo-Pacific, and Latin American jurisdictions to anticipate how U.S. diplomatic stances may influence adequacy decisions and data-sharing conditions.

DSAR and privacy operations integration

The NCSIP’s initiatives intersect with DSAR operations in several ways. First, CIRCIA’s rulemaking will likely expand the need for precise data classification and event evidence, which DSAR teams rely on to locate and redact personal data. Companies should update their data inventories to tag systems participating in federal reporting pilots—such as industrial control system logging or health sector dashboards—so DSAR workflows know where regulated personal and operational data co-reside. Second, OMB’s secure software requirements will push suppliers to document data flows and security testing artefacts; privacy teams can leverage those attestations to verify that DSAR exports accurately reflect application behaviour post-upgrade.

• Incident-to-DSAR handoffs. Develop joint runbooks between incident response and privacy teams describing how to handle DSARs that arrive after a material cyber incident. The runbooks should specify when to pause fulfilment because of law enforcement holds, how to communicate delays consistent with state privacy laws, and how to preserve logs needed both for regulatory reporting and DSAR evidence.
• Vendor governance. Many NCSIP tasks direct agencies to tighten third-party risk expectations. Enterprises should update vendor questionnaires so that critical suppliers demonstrate DSAR throughput, residency controls, and ability to support expedited access or deletion requests during federal investigations.
• Metrics and assurance. Boards will expect dashboards that show DSAR completion times, exception rates, and correlations with security incidents. Privacy leaders should adopt key risk indicators (KRIs) that map to NCSIP milestones—such as the number of systems lacking system security plans, or vendors missing SBOM attestations—to prove that DSAR services remain reliable as cybersecurity controls evolve.

Program management and change enablement

The ONCD emphasises transparency: the NCSIP commits to annual updates and promises to mark initiatives as completed or delayed. Programme managers should establish a tracking mechanism—such as an OKR board or Gantt chart—that mirrors the federal matrix, noting lead and partner agencies. This enables timely impact analysis when agencies publish notices of proposed rulemaking or issue binding operational directives. Communications teams should craft briefing materials for investors and customers explaining how the organisation supports national cyber priorities while safeguarding personal data rights. Human resources leaders can align workforce development initiatives with the National Cyber Workforce Strategy, ensuring training catalogues cover DSAR tooling, secure coding, and incident collaboration.

Budget offices should pair the NCSIP with the Office of Management and Budget’s Circular A-11 guidance, which now requires agencies to integrate cyber risk into performance plans. Private CFOs can adopt similar practices by linking cyber investment cases to measurable outcomes: reduced incident detection time, DSAR throughput improvements, or compliance readiness for sectoral rules. Internal audit should schedule readiness assessments around key deadlines, such as TSA’s directive updates or OMB’s software attestation portal launch, verifying that policies, procedures, and evidence repositories are complete.

Monitoring external dependencies

Because many initiatives rely on cross-agency collaboration, organisations should monitor potential bottlenecks. For instance, the Environmental Protection Agency’s efforts to bolster water utility cybersecurity may be influenced by ongoing litigation over its withdrawn memorandum; companies reliant on municipal water services should evaluate contingency plans. Likewise, the plan references the Cyber Safety Review Board’s investigations and the Joint Ransomware Task Force’s disruption activities—private sector threat intelligence teams should prepare to participate in information exchanges and adjust indicators of compromise. Privacy teams must stay informed about any new frameworks for trusted cross-border data flows emerging from the State Department’s diplomatic work, ensuring DSAR responses reflect updated transfer mechanisms.

Finally, the NCSIP underscores the federal commitment to collaborative governance. Enterprises can demonstrate good faith participation by joining public-private working groups, contributing to standards development (such as NIST’s secure software development practices or post-quantum migration guides), and sharing anonymised incident learnings where legally permissible. By integrating these activities with DSAR transparency dashboards and privacy impact assessments, organisations can evidence to regulators, customers, and employees that they are simultaneously strengthening cybersecurity and upholding individual rights. Establishing this dual accountability now will make subsequent NCSIP updates easier to incorporate, reducing change fatigue and maintaining resilience across regulatory cycles.