Compliance Briefing — November 1, 2023
New York’s Department of Financial Services adopted sweeping amendments to its cybersecurity regulation, adding class-based requirements, tighter governance standards, and new incident reporting triggers with phased deadlines through 2025.
Executive briefing: On 1 November 2023 the New York State Department of Financial Services (NYDFS) finalised the second amendment to 23 NYCRR 500. Covered entities must meet enhanced governance obligations, implement endpoint detection and response, perform independent audits, and comply with new 24-hour notification requirements for ransomware payments.
Key compliance checkpoints
- Class A designation. Identify whether total assets exceed $20 billion or over 2,000 employees, triggering additional requirements (e.g., privileged access management, automated EDR, annual external audits).
- Governance. Ensure the board or equivalent receives annual training, approves cybersecurity programs, and that the CISO reports material issues within 10 days.
- Incident reporting. Notify NYDFS within 72 hours of cybersecurity events and within 24 hours of making ransomware payments, followed by a 30-day payment report.
Operational priorities
- Timeline planning. Map the staged compliance deadlines (30, 180, 365, and 540 days from November 1, 2023) and assign control owners.
- Control enhancements. Deploy multi-factor authentication for privileged accounts, implement asset inventories, and document vulnerability management SLAs.
- Independent testing. Schedule annual penetration tests, scenario-based exercises, and third-party audits as mandated.
Enablement moves
- Establish program dashboards tracking milestone completion, exception management, and board reporting.
- Update incident response plans with ransomware payment reporting workflows and tabletop exercises.
- Coordinate with affiliates to harmonise policies where limited exemptions apply.
Sources
Zeph Tech drives NYDFS cybersecurity readiness with control gap analyses, roadmap execution, and board-level reporting tailored to the amended regulation.