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    NYDFS Part 500

    NYDFS Part 500 Compliance for Covered Entities

    NYDFS Part 500 (23 NYCRR 500) is New York's cybersecurity regulation for banks, insurers, lenders and other entities licensed by the Department of Financial Services. The amended rule requires a CISO, a risk-based program, MFA, an asset inventory, 72-hour incident notice and an annual certification by April 15. Defensible helps you meet it from 48 Wall Street.

    Founded by former Stroz Friedberg leaders. This page is a practical summary, not legal advice.

    Part 500 work we support
    CISO function·Risk assessment·MFA·Asset inventory·Penetration testing·Annual certification
    Who Is Covered

    Who Is Covered by NYDFS Part 500?

    A covered entity is any person operating, or required to operate, under a license, registration, charter or similar authorization under New York's Banking, Insurance or Financial Services Laws. That includes many small insurance agencies and mortgage brokers.

    Smaller entities may qualify for a limited exemption based on headcount, New York revenue or total assets. An exemption reduces the requirements but does not remove them all, and it must be filed with DFS.

    MFA gaps

    Legacy systems, shared mailboxes and service accounts get missed.

    A CISO in name only

    Regulators expect real oversight and an annual written report to the board.

    Untested plans

    Incident response and continuity plans must be tested at least annually.

    Certifying without evidence

    If you sign in April, you need the documents behind it.

    +71%
    Increase in attacks using valid credentials (IBM X-Force Threat Intelligence Index, 2024)
    30%
    Of breaches involved a third party (Verizon DBIR, 2025)
    $4.44M
    Global average cost of a data breach (IBM Cost of a Data Breach Report, 2025)
    ≈$2.77B
    In reported BEC losses (FBI IC3, 2024)
    The Amended Rule

    What Changed in the Amended Rule?

    DFS adopted amendments to Part 500 in November 2023 and phased them in through November 2025. Governance expectations rose and larger Class A companies took on extra duties.

    Board oversight

    The board must understand cyber risk well enough to oversee it.

    MFA for all users

    Required for any individual accessing any information system of the covered entity.

    Asset inventory

    A maintained inventory of information systems and their owners.

    Notice deadlines

    72 hours to notify DFS of a reportable incident, and 24 hours for an extortion payment.

    How We Help

    How Does Defensible Help You Comply?

    The CISO function and the technical work behind it.

    CISO and Governance

    A qualified security leader who owns the program and reports to your board.

    • vCISO — Program ownership, policies and the annual written board report
    • Policy set — Written policies approved at least annually
    • Third-party oversight — Vendor due diligence and minimum control requirements

    Risk and Testing

    The assessments and tests the rule expects at least annually.

    • Risk assessment — Documented, and updated on material change
    • Penetration testing — By a qualified independent party

    Controls

    Closing common technical gaps.

    • MFA — Coverage across users, remote access and privileged accounts
    • Asset inventory — Systems, owners, classification and support dates

    Response and Certification

    Tested plans and a solid evidence pack.

    • IR and BC/DR plans — Written, tested and rehearsed with a tabletop
    • Evidence pack — Organized for the CEO and CISO to sign
    Requirements

    What Does the Amended Rule Require?

    A summary of the core obligations. Confirm your specific obligations with counsel and the current regulation text on dfs.ny.gov.

    RequirementSectionWhat you need in place
    CISO500.4A qualified CISO, who may be employed by an affiliate or a third-party provider, reporting to the board at least annually
    Risk assessment500.9Documented, reviewed and updated at least annually
    Penetration testing500.5At least annually, plus automated vulnerability scans
    Multi-factor authentication500.12MFA for any individual accessing any information system
    Asset inventory500.13A complete, maintained inventory of information systems
    IR and BC/DR plans500.16Written plans, tested at least annually
    Notification500.17(a)Notify DFS within 72 hours of determining a reportable incident
    Annual certification500.17(b)By April 15: compliance certification or acknowledgment of non-compliance, signed by the CEO and CISO
    Covered Entities We Support

    Who We Help With Part 500

    Covered entities that need the CISO function without a full-time hire.

    Insurance agencies

    Licensed producers holding client data.

    Mortgage brokers and lenders

    Firms handling borrower financial data.

    Banks and money transmitters

    Institutions under DFS oversight.

    Service providers

    Vendors whose covered-entity clients expect Part 500-aligned controls.

    Compliance Roadmap

    What Is Our Compliance Roadmap?

    From classification to a certification you can sign.

    1. STEP 1
      Classify

      Confirm whether you are a standard, exempt or Class A entity.

    2. STEP 2
      Appoint the CISO

      Contract a vCISO or support your existing one.

    3. STEP 3
      Assess

      Run the risk assessment, inventory systems and test against the rule.

    4. STEP 4
      Remediate

      Close MFA gaps, update policies, test plans and run the penetration test.

    5. STEP 5
      Certify

      Compile the evidence pack, brief the board and prepare the April 15 filing.

    Class A Companies

    What Extra Rules Apply to Class A Companies?

    Class A companies carry additional obligations on top of the core requirements. The thresholds combine New York revenue with total employees or total revenue, including affiliates, so check the definition in section 500.1 with counsel.

    • Independent audits — Independent audits of the cybersecurity program, based on its risk assessment.
    • Privileged access — A privileged access management solution and automated blocking of commonly used passwords.
    • Detection — Endpoint detection and response plus centralized logging and security event alerting, unless the CISO approves equivalent controls in writing.
    vCISO

    How Does a vCISO Fill the CISO Requirement?

    A Defensible vCISO acts as your designated CISO. They own the program, approve policies with leadership, direct the risk assessment and testing, and deliver the annual written report to your board. Your senior personnel oversee the engagement.

    Our CEO, Steve Doty, served as an outsourced CISO for numerous organizations as a Managing Director at Stroz Friedberg. If an incident does happen, our incident response team is on the same side of the table: our 24/7 hotline is (646) 349-4252, and a senior responder engages within one hour.

    vCISO in Practice

    Containing a Server Breach for a vCISO Client

    • Customer: A long-term vCISO client in the nonprofit sector
    • Challenge: Suspicious activity on an internet-facing Confluence server shortly after it moved to Microsoft Azure
    • Result: Defensible already knew the environment, confirmed the incident was limited in scope and contained, and found no signs of attacker persistence or spread
    See the Full Story

    "Defensible Technology has proven to be a trusted and capable provider of services in the fields of Information Technology implementation and services, as well as Security Services. I have known and worked closely with Defensible's CEO, Steve Doty, and his colleagues for years. They are excellent professionals and it is a pleasure working with them. I recommend Defensible without hesitation for any organization that is seeking experienced high quality talent that can be trusted to deliver the valuable services they offer."

    — Ed Stroz, Founder of Consilience 360, LLC and Stroz Friedberg, LLC

    NYDFS FAQ

    Frequently Asked Questions

    Can a virtual CISO satisfy the NYDFS CISO requirement?+

    Yes. Part 500 allows the CISO to be employed by an affiliate or a third-party service provider. The covered entity keeps responsibility for compliance and must designate senior personnel to oversee the third-party CISO.

    When is the NYDFS annual certification due?+

    By April 15 each year, covering the prior calendar year. You file either a certification of material compliance or an acknowledgment of non-compliance with a remediation plan, signed by the CEO or highest-ranking executive and the CISO.

    What is a Class A company?+

    Class A companies are the largest covered entities, defined by New York revenue combined with total employees or total revenue across the company and its affiliates. They must also conduct independent audits of the program and implement privileged access management and endpoint detection with centralized logging.

    We're a small agency. Are we exempt?+

    Possibly in part. Limited exemptions are based on headcount, New York revenue and total assets. An exempt entity still has core obligations and must file a notice of exemption. Confirm your status with counsel.

    What must be reported within 72 hours?+

    Covered entities must notify DFS within 72 hours of determining that a reportable cybersecurity incident has occurred. Extortion payments must be reported within 24 hours, with a written explanation within 30 days.

    Certifying This April?

    Get Your Part 500 Program Ready to Certify

    We provide the CISO function, the testing and the evidence pack, from 48 Wall Street.