Compliance Briefing — NYDFS Cybersecurity amendment deadline nears

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 1 November 2025, 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

• NYDFS Cybersecurity Regulation, Title 23 NYCRR Part 500 (adopted 1 November 2023)
• NYDFS Cybersecurity Resource Center