Compliance Briefing — NYDFS Cybersecurity amendment deadline nears
Covered entities must finish implementing New York’s amended 23 NYCRR 500 requirements by 1 November 2025, including tightened privileged access controls, endpoint detection, and independent audits.
Executive briefing: The New York Department of Financial Services (NYDFS) amended its 23 NYCRR Part 500 Cybersecurity Regulation in November 2023. The final transition period ends on , when most new controls—including expanded multi-factor authentication, endpoint detection and response, and annual independent audits—become mandatory.
What is due by 1 November 2025
- Privileged access and MFA. Article 500.12 now requires MFA for privileged accounts and remote access unless a CISO-approved compensating control is documented.
- Enhanced monitoring. Article 500.14 mandates endpoint detection and response, centralized logging, and documented alert triage.
- Independent assessments. Annual independent audits of the cybersecurity program replace the prior triennial penetration test cadence in Article 500.5.
Program actions
- Finalize MFA rollouts for privileged users and contractors, including break-glass procedures approved by the CISO.
- Validate endpoint detection coverage across servers, desktops, and cloud workloads with alert routing to a staffed SOC.
- Schedule an independent audit that covers policy alignment, control effectiveness testing, and evidence collection ahead of the 2025 certification filing.
- Refresh Board reporting to reflect amended definitions of material cybersecurity incident and CISO authority.
Sources
Continue in the Compliance pillar
Return to the hub for curated research and deep-dive guides.
Latest guides
-
Third-Party Risk Oversight Playbook — Zeph Tech
Operationalize OCC, Federal Reserve, EBA, and MAS outsourcing expectations with lifecycle controls, continuous monitoring, and board reporting.
-
Compliance Operations Control Room — Zeph Tech
Implement cross-border compliance operations that satisfy Sarbanes-Oxley, DOJ guidance, EU DORA, and MAS TRM requirements with verifiable evidence flows.
-
SOX Modernization Control Playbook — Zeph Tech
Modernize Sarbanes-Oxley (SOX) compliance by aligning PCAOB AS 2201, SEC management guidance, and COSO 2013 controls with data-driven testing, automation, and board reporting.