NYDFS 500: How to Make Sure You Comply

Gain Clarity and Achieve Compliance with a Trusted Partner


Feeling overwhelmed by the NYDFS 500 Cybersecurity Regulation amendments? You're not alone.

This regulation sets strict requirements for financial institutions in New York State to protect customer data and safeguard their information systems. As of the end of 2023, the DFS finalized its latest amendment to the regulation.

But don't worry. WithSecure Consulting is here to help you navigate the complexities of the NYDFS 500 and its latest amendment and ensure your institution remains compliant.

The 2023 Amendments in a Nutshell

The November 2023 amendments to the NYDFS 500 introduced several significant changes, amplifying the focus on accountability and risk management.

Key changes include:

Enhanced Governance

The amendments call for enhanced governance structures, including board-level oversight and establishing a cyber security committee. This committee is responsible for providing guidance and direction on cyber security matters.

Cybersecurity Policy

Data retention must now be codified in policy and a security awareness and training policy is now required as per the latest amendments.

Annual Audit

Class A entities must conduct independent annual audits of their cyber security program.

Ransomware Reporting

A new requirement mandates reporting ransomware attacks to the NYDFS within 72 hours of detection, regardless of their perceived impact on the covered entity.

Asset Management and Data Retention

The latest amendment requires affected entities to produce and maintain a complete, accurate and documented asset inventory updated at a defined frequency and which tracks key information for each asset.

Certification Signed by the CEO

The annual certification of compliance must be signed by the CEO of the entity.

Does the NYDFS 500 Apply to You?

The NYDFS 500 applies to various financial institutions operating in the State of New York.

This includes:

Banks, Trust Companies, and Banking Organizations

This category includes traditional banks, trust companies, and any organization defined as a bank under the New York State Banking Law.

Insurance Companies

The regulation covers all insurance companies licensed to transact business in New York State.

Charterers and Licensed Lenders

Entities authorized by the NYDFS to act as money transmitters or engage in similar financial activities are covered.

Pension Brokers and Fund Administrators

Pension brokers and employee welfare fund administrators licensed by the NYDFS must comply.

Foreign Banks with a New York Branch

Foreign banks operating a branch in New York State must adhere to the regulation’s requirements.

The regulation also holds the following parties accountable:

C-suite executives (CEO)

Ultimately responsible for signing the annual compliance certification.

Board of Directors (BoD)

Holds the ultimate responsibility for cyber risk management and must possess cyber security knowledge.

Legal, Regulatory Compliance, and Risk Management

Ensure regulation adherence and cyber risk management.

IT and Cyber Security Decision Makers (CIO, CISO)

Tasked with implementing and maintaining the cyber security program.

How WithSecure Consulting Can Help You Stay Compliant

We’re security builders with a proven track record of over 30 years in the cyber security industry. Our research-driven consultants don't just identify problems—they solve them by thinking like attackers themselves.

We believe in co-security, working as an extension of your team to achieve your goals.

WithSecure Consulting is your trusted partner because we believe in the following:

Clear and Concrete Advice: We give clear, concise explanations of the regulation, cutting through the jargon and empowering you to make informed decisions.

Tailored and Actionable Solutions: We go beyond theory, offering practical guidance and proven solutions to address your specific needs.

Experience You Can Trust: With over 30 years of cyber security experience, we have a proven track record of helping organizations, including some of the world’s largest financial institutions, achieve compliance and mitigate cyber risks.

The WithSecure Consulting NYDFS 500 Service Offerings

We understand the complexities of the NYDFS 500 and its challenges.

That's why we offer a comprehensive suite of services designed to help you achieve and maintain compliance efficiently.

Cyber Security Program Design | Security Strategy

Our experts help you design and implement a robust cyber security program that meets the regulation’s requirements.

This service helps you fulfill the §500.02 Cybersecurity Program (b) requirement.

Annual Independent Audit of the Cyber Security Program | Cyber Security Maturity Assessment (CMA)

We conduct thorough cyber security maturity assessments (CMAs) modeled after our proven PCI DSS compliance assessments.

This service helps you fulfill the §500.02 Cybersecurity Program (c) requirement.

Remediation Plan Development | Security & Risk Management

Following a CMA, we'll help you craft a comprehensive remediation plan to address identified gaps.

This service helps you fulfill the §500.17 Notices to Superintendent (b)(1)(ii) requirement.

Penetration Testing | Security Assurance

We offer penetration testing services to identify and address vulnerabilities in your information systems.

This service helps you fulfill the §500.05 Vulnerability Management (a) requirement.

Incident Response Plan Testing | Incident Readiness Exercises

We conduct realistic incident response plan testing exercises to ensure your team is prepared to handle security incidents effectively.

This service helps you fulfill the §500.16 Incident Response Plan (d)(1) requirement.

Annual Reporting | Board of Directors Reporting Package

After a CMA, we can help you create a BoD reporting package that meets NYDFS requirements.

This service helps you fulfill the §500.04 Cybersecurity governance (b) requirement.

Examination Support

We help you throughout the NYDFS examination process, including pre-examination preparation and post-examination support.

Take the First Step to NYDFS 500 Compliance With a Clear Picture of Your Exposure

Navigating the NYDFS 500 can be daunting. That’s why our trusted advisors and no-nonsense experts help you achieve compliance.

We combine industry-leading security solutions with a deep understanding of the regulation to give practical guidance and actionable solutions.


Starter Package: What's Your DFS 500 Exposure?


This package includes interviews with key executives and service owners to define your company’s NYDFS 500 scope and a high-level roadmap to address the most significant gaps.


Don’t wait until a cyber attack strikes. Proactively ensure you’re compliant with NYDFS 500. Contact WithSecure Consulting today, and let us guide you on the path to a secure future.


Get in Touch

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Not Sure Yet? Let’s Talk!

We offer a free 60-minute consultation with our cyber security experts to discuss your NYDFS 500 compliance needs.

Further Resources

Stay informed and learn more. For a deeper dive, we recommend checking out the following resources.


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During this webinar, WithSecure will review and summarize the key changes to the Second Amendment, offering recommendations and advice on how organizations can ensure they remain compliant.

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