This guide synthesises NIST SP 800-207, CISA’s Zero Trust Maturity Model 2.0, the U.S. Department of Defense Zero Trust Reference Architecture v2.0, and ENISA’s zero trust architecture study into a phased roadmap that maps directly to CIS Controls v8, ISO/IEC 27001:2022, and PCI DSS 4.0 obligations.NIST SP 800-207CISA ZTMM 2.0DoD ZT RA v2.0ENISA Zero Trust Architecture
Updated to incorporate CISA’s identity-centric maturity milestones, DoD automation requirements, and ENISA’s organisational prerequisites for policy decision points.
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Zero trust architecture (ZTA) is no longer optional for regulated operators. NIST SP 800-207 defines a control plane of policy decision and enforcement points that must continuously evaluate trust on every request, while CISA’s Zero Trust Maturity Model 2.0 expands those expectations across identity, devices, networks, applications, data, and cross-cutting visibility.NIST SP 800-207CISA ZTMM 2.0
The U.S. Department of Defense’s Zero Trust Reference Architecture v2.0 sets 45 target capabilities across seven pillars and emphasises automation, orchestration, and continuous monitoring to reach the “target” and “advanced” levels demanded in the 2027 DoD zero trust mandate.DoD ZT RA v2.0 ENISA’s 2021 study reinforces that zero trust transformations require governance baselines—asset inventories, policy codification, and segmentation blueprints—before technical controls produce measurable risk reduction.ENISA Zero Trust Architecture
Mapping these frameworks to operational controls ensures audit readiness. CIS Controls v8 mandates identity, device, and network management fundamentals; ISO/IEC 27001:2022 codifies access control, monitoring, and supplier requirements; PCI DSS 4.0 demands authenticated access, segmentation, and logging around cardholder data environments.CIS Controls v8ISO/IEC 27001:2022PCI DSS 4.0
Structure zero trust delivery into four phases so strategy, deployment, measurement, and innovation remain synchronised with regulatory checkpoints and organisational capacity.
Establish the prerequisites each framework expects before deploying enforcement technology. NIST SP 800-207 requires enterprise-wide asset inventories, policy decision algorithms, and continuous communications between policy decision and enforcement points. CISA’s maturity model demands authoritative identity proofing, device discovery, and policy definitions to progress beyond the traditional stage, while ENISA emphasises executive sponsorship, data classification, and segmentation planning.NIST SP 800-207CISA ZTMM 2.0ENISA Zero Trust Architecture
Translate governance foundations into enforcement platforms. DoD’s reference architecture requires policy enforcement points across user, device, network/environment, application/workload, data, automation, and analytics pillars, with orchestration to maintain consistent policy decisions. CISA’s maturity milestones stress continuous evaluation, adaptive access, and encryption for data in transit and at rest.DoD ZT RA v2.0CISA ZTMM 2.0
Embed measurable outcomes so leadership and auditors can confirm progress. CISA’s maturity model recommends metrics for device compliance, identity assurance, and policy automation. DoD’s reference architecture defines performance levels for every target capability and requires continuous analytics feeding automation and orchestration pillars.CISA ZTMM 2.0DoD ZT RA v2.0
Anticipate how new architectures—edge computing, 5G, operational technology (OT), and SaaS ecosystems—alter zero trust assumptions. DoD’s automation and orchestration pillar requires integrating threat intelligence and configuration baselines into continuous workflows, while ENISA highlights multi-cloud governance and supply chain dependencies.
Zero trust programmes must prove they can detect, contain, and report incidents at the speed regulators demand. Align playbooks with NIST SP 800-61r2 and the U.S. Securities and Exchange Commission’s Regulation S-K Item 106 disclosure requirements so cyber incidents tied to zero trust controls are handled consistently.NIST SP 800-61r2SEC Regulation S-K Item 106
Automated evidence capture. Instrument SOAR and case-management platforms to capture identity risk scores, policy enforcement logs, and KEV remediation timestamps. This satisfies DoD automation outcomes and supports SEC disclosure-ready evidence packs.DoD ZT RA v2.0SEC Regulation S-K Item 106
Detection engineering baselines. Align MITRE ATT&CK and D3FEND mappings from Zeph Tech briefings with SIEM and XDR content libraries so containment steps are proven before board reporting.Cloud-native threat hunting briefingNIST OT security briefing
Organisations across the public and private sectors have published detailed accounts of their zero trust deployments. Analysing these case studies helps programme leaders calibrate investment, avoid pitfalls, and accelerate control adoption. The examples below draw from authoritative reports, inspector general assessments, and public briefings that document measurable outcomes.
President Biden’s Executive Order 14028 and the Office of Management and Budget’s Memorandum M-22-09 set a fiscal year 2024 deadline for U.S. federal civilian agencies to implement phishing-resistant MFA, enterprise logging, and application segmentation across high-value assets. Agencies briefed during the Federal Zero Trust Summit described how they sequenced these requirements: establishing authoritative identity sources, rolling out passwordless authentication for privileged users, and implementing secure access service edge (SASE) platforms to satisfy Trusted Internet Connections (TIC) 3.0 objectives.
OMB’s strategy directs Chief Financial Officers Act agencies to map investments to five zero trust pillars and to demonstrate progress through quarterly Cybersecurity Risk Determination Reports.OMB Memorandum M-22-09 CISA supports these efforts with reference architectures, maturity assessments, and shared services that help agencies accelerate deployment while preserving audit trails for the Federal Information Security Modernization Act (FISMA) programme.
The Defense Information Systems Agency (DISA) launched the Thunderdome prototype in 2022 to modernise the Department of Defense Information Network (DoDIN) security architecture. The pilot combined secure access service edge (SASE) capabilities, software-defined wide area networking (SD-WAN), and policy enforcement using identity attributes. According to DISA’s 2023 strategic plan, Thunderdome reduced reliance on legacy perimeter Joint Regional Security Stacks, improved network performance for remote users by routing traffic directly to cloud applications, and provided continuous trust evaluations based on device posture.
Parallel fit-for-purpose pilots across the Army, Navy, and Air Force explored microsegmentation of mission systems and just-in-time privileged access to tactical networks.DoD Zero Trust Strategy Lessons learned emphasised the importance of integrating zero trust principles into DevSecOps pipelines (for example, Platform One’s hardened container images) and leveraging conditional access policies to secure collaboration tools used by joint task forces. The Department’s 2024 progress update confirmed that every military service had established a zero trust portfolio office, baselined capabilities against the 45 DoD target capabilities, and scheduled annual assessments using automated testing scripts.
Capital One’s migration to cloud-native infrastructure after the 2019 enforcement action has been widely studied. The bank published a zero trust architecture overview describing how it uses short-lived authentication tokens, automated policy enforcement on infrastructure as code, and micro-perimeters around sensitive workloads. Security engineering teams treat identity as the new perimeter by issuing mTLS certificates to workloads, enforcing dynamic least privilege using HashiCorp Vault, and applying behavioural analytics to detect anomalous access. Capital One’s adoption of continuous compliance pipelines for PCI DSS and FFIEC guidelines demonstrates how regulated financial institutions can align zero trust outcomes with audit evidence.
Google’s BeyondCorp model, now commercialised as BeyondCorp Enterprise, provides a repeatable playbook for enterprises subject to industry regulations. Customer case studies highlight how zero trust network access replaces VPN concentrators, enforces device posture checks, and delivers detailed audit logs for compliance teams. Financial institutions adopting BeyondCorp-style architectures emphasise metrics such as percentage of applications fronted by identity-aware proxies, reduction in legacy VPN usage, and automated policy deployment via infrastructure-as-code pipelines.
The United Kingdom’s National Health Service (NHS) Digital, now NHS England, released a zero trust architecture blueprint in partnership with the National Cyber Security Centre (NCSC) to secure patient data across thousands of trusts.NHS Digital Cyber and Data Security The programme prioritised identity governance for clinicians, integrating smartcard authentication with Azure Active Directory, and enforcing least privilege access to clinical applications. Network microsegmentation was implemented in partnership with NHS Secure Boundary, reducing lateral movement risks in hospitals. NHS also adopted centralised logging with the Splunk platform to satisfy the UK Data Security and Protection Toolkit monitoring requirements.
Johnson & Johnson’s zero trust journey, highlighted during the HIMSS Zero Trust Healthcare summit, focused on protecting sensitive research and manufacturing environments. The company deployed microsegmentation to separate operational technology from enterprise IT, enforced conditional access for third-party collaborators, and used continuous risk scoring to manage access to laboratory systems. Key metrics include the percentage of manufacturing sites with enforced least privilege, reduction in high-privilege service accounts, and the number of validated recovery drills for critical production lines.
Zero trust is a strategy, not a product. However, selecting interoperable tooling is essential for enforcing policies consistently. The following comparisons examine widely adopted technologies within each pillar and highlight differentiators relevant to compliance, scalability, and automation. Reference independent evaluations such as MITRE ATT&CK Evaluations, Gartner Market Guides, and national cybersecurity authority assessments when conducting procurement reviews.
Microsoft Entra ID, Okta Workforce Identity Cloud, and Ping Identity remain leading options for centralised workforce identity. Entra ID offers native integration with Conditional Access policies, device compliance checks via Microsoft Intune, and built-in FIDO2 support.Microsoft Conditional Access Overview Okta differentiates with broad application integrations, an extensible identity workflow automation engine, and phishing-resistant Okta FastPass on supported platforms.Okta FastPass Whitepaper Ping Identity appeals to regulated industries through on-premises deployment options, attribute-based access control (ABAC) policy support, and integration with legacy directories.Ping Identity Zero Trust Architecture
For privileged access, CyberArk and BeyondTrust provide session isolation, credential rotation, and just-in-time elevation tied to zero trust policies.CyberArk Zero Trust PrivilegeBeyondTrust Zero Trust Guide Evaluate whether vendors support hardware security keys, Risk-Based Conditional Access, and integration with Security Assertion Markup Language (SAML), OpenID Connect (OIDC), and System for Cross-domain Identity Management (SCIM) standards required by regulators.
Secure access service edge (SASE) platforms such as Zscaler, Palo Alto Networks Prisma Access, and Cisco Secure Access deliver zero trust network access (ZTNA) and cloud firewalling with integrated data protection. Zscaler’s Zero Trust Exchange emphasises brokered connections and inline policy enforcement, while Prisma Access integrates with Palo Alto’s Cortex XDR for unified analytics.Palo Alto Networks Zero Trust Enterprise Cisco Secure Access, built on the Duo acquisition and cloud security acquisitions, provides granular device and application controls integrated with ThousandEyes for performance monitoring.Cisco Zero Trust Report
Organisations with significant on-premises workloads often complement SASE with microsegmentation platforms such as Illumio, Cisco Secure Workload (Tetration), and Akamai Guardicore Segmentation. These tools provide policy visualisation, enforcement based on labels rather than IP addresses, and integration with DevOps pipelines.Illumio Zero Trust SegmentationAkamai Guardicore Segmentation Evaluate telemetry export options for SIEM integration and ensure tooling supports both IT and OT assets when required by regulations such as NIS2 or TSA pipeline directives.
Data-centric zero trust requires discovery, classification, and encryption tied to access policies. Tools like Symantec Data Loss Prevention, Microsoft Purview Information Protection, and BigID provide classification engines and policy enforcement across cloud and on-premises data stores.Microsoft Purview Information ProtectionBroadcom Symantec DLPBigID Zero Trust Data Security Combine these platforms with customer-managed encryption keys, hardware security modules (HSMs), and transparent data access auditing to meet PCI DSS Requirement 3, HIPAA safeguards, and GDPR Article 32 obligations.
Logging and analytics are critical for continuous verification. Security information and event management (SIEM) platforms such as Splunk Enterprise Security, Microsoft Sentinel, and Google Chronicle provide the scale and automation to ingest identity signals, device posture, and enforcement events. Evaluate native support for OCSF, MITRE ATT&CK mappings, and SOAR workflows. Splunk’s Zero Trust Security Architecture blueprint emphasises detection-as-code and guardrails for regulated industries, while Microsoft Sentinel’s Zero Trust guidance highlights native integration with Entra ID and Defender XDR. Chronicle, built on Google’s planet-scale infrastructure, offers long-term telemetry retention aligned with compliance needs for forensic investigations.
Continuous security validation ensures zero trust controls remain effective as threat actors evolve. Breach and attack simulation (BAS) platforms like AttackIQ and SafeBreach map tests to MITRE ATT&CK techniques, enabling teams to evaluate detection and response workflows.AttackIQ EnterpriseSafeBreach Platform Penetration testing automation tools such as Randori (IBM) and Cymulate extend coverage to external attack surfaces and phishing resilience. For identity controls, Picus Security and Semperis provide validation of Active Directory and Azure AD configurations against known attack paths.
When selecting tooling, document integration requirements, data residency constraints, and regulator expectations. For example, DoD programmes must comply with Impact Level 5 (IL5) hosting requirements, while EU DORA mandates data localisation and operational resilience testing obligations for critical third parties. Establish exit strategies and secondary suppliers to satisfy DORA Article 28 business continuity clauses.
Zero trust frameworks demand ongoing evidence that controls operate as designed. Develop repeatable validation playbooks aligned to your risk appetite, regulatory obligations, and threat landscape. The following approach combines purple teaming, automated testing, and governance checkpoints.
Begin by defining the control areas to test—identity, device, network, application, and data—along with the expected outcomes. Align objectives with CISA ZTMM milestones, DoD target capabilities, and ENISA prerequisites. For example, if the goal is to verify phishing-resistant MFA, the validation objective might be “all privileged identities enforce FIDO2 or certificate-based authentication, with no bypass mechanisms.” Document the systems in scope, data classification levels, and regulatory requirements (such as NYDFS 23 NYCRR 500.12 for MFA or DORA Article 11 for incident handling) that necessitate the control.
Create a validation calendar that sequences activities quarterly. Pair each roadmap milestone with a validation event—such as testing microsegmentation policies when a new production environment launches or verifying data loss prevention coverage before migrating a regulated dataset to the cloud.
Collaborate with threat intelligence analysts to craft adversary scenarios that exercise the control under test. Use MITRE ATT&CK techniques relevant to your sector; for instance, T1556 (Modify Authentication Process) for identity attacks or T1021 (Remote Services) for lateral movement. If referencing state-backed threats, cite advisories from CISA, the UK NCSC, or ENISA describing the behaviours. Document success criteria, such as “policy enforcement point denies access from unmanaged device” or “adaptive access raises risk score above blocking threshold.”
Conduct tabletop walk-throughs before live exercises to align stakeholders on detection points, escalation paths, and safe testing parameters. Capture approvals from legal, privacy, and compliance teams, especially when tests could touch personal data or regulated workloads.
Instrument SIEM, SOAR, and identity platforms to capture logs, screenshots, and case notes automatically during testing. Use automation frameworks such as MITRE CALDERA, Atomic Red Team, and Stratus Red Team to execute repeatable attack scripts in cloud and on-premises environments. Store outputs in a central evidence repository aligned with your GRC tooling. Tag artefacts with control IDs, ATT&CK technique numbers, and ticket references for audit traceability.
For data security tests, combine synthetic (non-production) datasets with anonymised production logs to avoid privacy violations while still validating encryption, tokenisation, and access controls. Ensure that testing adheres to applicable privacy laws such as GDPR and HIPAA.
Score each test using a consistent rubric (for example, pass, partial, fail). Document root causes for failures and assign remediation owners. Integrate results into backlog management tools and track mean time to remediate (MTTRem) by control family. Regulators frequently request evidence of corrective actions; maintain a ledger of remediation tickets, change requests, and verification steps linked to specific regulations.
When controls fail, run a follow-up validation within an agreed SLA. For critical issues affecting regulated services, aim for validation within 30 days. Record lessons learned in retrospectives and adjust detection rules, access policies, or automation scripts accordingly.
Prepare executive-level summaries that translate validation results into risk language: probability of compromise, potential impact on business services, and regulatory exposure. Provide granular data to operations teams, including log excerpts, detection timelines, and recommended configuration changes. Supply auditors with detailed evidence packages referencing control catalogs (CIS Controls, ISO/IEC 27001 Annex A, PCI DSS, NIST CSF) and regulatory clauses. Highlight progress over time using trend charts for detection latency, incident containment, and access policy enforcement.
Finally, feed validation insights back into training programmes. Update runbooks, develop tabletop scenarios for executives, and refine incident communication templates based on observed gaps. Continuous validation keeps zero trust programmes resilient against evolving threats and ensures compliance commitments remain credible.
Review the newest Zeph Tech dispatches covering KEV deadlines, MITRE ATT&CK updates, and automation benchmarks before presenting roadmap updates.
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