Compliance Briefing — October 20, 2025
New York DFS cybersecurity amendments hit their final compliance deadline on 27 October 2025, requiring covered entities to evidence enhanced third-party risk governance, asset inventories, and incident notification testing.
Executive briefing: The New York Department of Financial Services (NYDFS) finalized amendments to 23 NYCRR 500 in November 2023. The last transition date—27 October 2025—now approaches, bringing into force requirements for comprehensive asset inventories (Section 500.13), enhanced third-party service provider oversight (Section 500.11), and annual incident response and business continuity plan testing (Section 500.16). Covered entities must certify compliance in their next annual filing and be prepared for targeted examinations.
Key compliance checkpoints
- Asset inventory accuracy. Maintain a dynamic inventory of information systems, including cloud services, SaaS platforms, and unstructured data repositories, with risk classification and ownership metadata.
- Third-party controls. Ensure contracts mandate MFA, encryption, prompt incident notice, and rights to audit; document risk assessments and tiering for each service provider.
- Plan testing evidence. Record results of incident response, business continuity, and disaster recovery exercises held within the past 12 months, including lessons learned and remediation actions.
Operational priorities
- Certification readiness. Compile board or senior officer certifications, demonstrating oversight of the cybersecurity program and material compliance exceptions.
- Metrics reporting. Build dashboards covering privileged access reviews, vulnerability remediation timelines, and third-party issue closure to share with CISOs and boards.
- Examination playbooks. Prepare document packages, including policies, inventories, and service provider monitoring logs, to respond quickly to DFS exam requests.
Enablement moves
- Coordinate tabletop exercises that include third-party breach scenarios and test notification routes to DFS within the 72-hour requirement.
- Update training content for procurement, vendor management, and business owners on new contract clauses and monitoring duties.
Sources
- NYDFS cybersecurity regulation amendments
- NYDFS cybersecurity resource center
- Morgan Lewis summary of NYDFS amendments
Zeph Tech steers NYDFS compliance programs with automated asset inventories, third-party oversight tooling, and certification-ready evidence.