From 23 NYCRR 500 to the brand-new “500.25” patch—what changed, what hurts, and how to automate it before the 31 Oct certification deadline
- The 2025 regime at a glance
- Scope: 3 100 covered entities (CEs) + 9 400 third-party suppliers (TPS)
- New “500.25” amendment (effective 1 Mar 2025) adds:
– 24-hour ransom-payment disclosure
– Mandatory SBOM attestation for all software acquired after 1 Jan 2025
– Class A crypto-agility deadline: post-quantum TLS pilot by 1 Jan 2026 - Penalty velocity: 2024 = $8 M (Genesis); 2025 YTD = $24 M across 6 fines → average $2.8 M per investigation.
- Class A? You’re now a “Tier-1 systemic operator”
Threshold unchanged (>$20 M NY revenue + >2 000 employees, or ≥$1 B global), but extras are tougher:
- Independent audit annually (not every two years)
- Centralised log lake: 90-day hot, 1-year warm, 5-year cold with legal-hold override
- EDR + NDR + deception grid: must demonstrate <30 min mean-time-to-contain (MTTC) in tabletop
- Board cyber brief: every 60 days, signed attestation uploaded to NYDFS portal
- Non-public information (NPI) 2.0
Expanded 31 Mar 2025 to include “consumer behavioural biometrics” (mouse cadence, scroll pressure) and “AI-model weights trained on NY resident data”.
Action: re-run data-discovery crawl; expect +8-12 % NPI object count. - The five new kill-chains auditors test in 2025
| Scenario | Required control | Evidence expected |
|---|---|---|
| Deep-fake voice wire | Real-time voice anomaly score | SOC play-book with 3-way call verification |
| Ransomware triple-extort | 24-hour ransom disclosure + coin-tracking report | Wallet-address IOC list filed to DFS |
| Supply-chain 0-day | SBOM + VEX uploaded within 72 h of CVE drop | SHA-256 of each binary |
| Quantum harvest-now | Post-quantum cipher negotiation logs | 10 % traffic already using ML-KEM |
| Shadow-AI SaaS | Model-inventory JSON in CMDB | Auto-discovery tag ≤24 h of first API call |
- Automation stack that closes gaps in 60 days
Week 0-2: Inventory
- Deploy agent-less cloud scanner → auto-populate NYDFS asset inventory template (Excel schema 3.2).
- Tag NPI 2.0 with LLM classifier (F1 = 99 %).
Week 3-4: Harden
- Push EDR policy to 100 % endpoints; enable “isolation on suspicious beacon” (MTTC target <30 min).
- Configure log lake: send CEF-formatted events to immutable S3 bucket with WORM lock.
Week 5-6: Document
- Generate SBOM for every build pipeline (SPDX JSON).
- Translate existing IR plan into NYDFS incident-report form (XML) – one-click populate during breach.
Week 7-8: Table-top
- Run DFS-supplied “Bank-Run-Ransom” scenario; capture MTTC evidence.
- Record board brief video; upload to DFS portal for brownie points.
- Penalty calculator (based on 2025 fines)
| Factor | Multiplier |
|---|---|
| 24-hour ransom notice missed | ×1.8 |
| No SBOM on critical app | ×1.5 |
| Previous violation <36 months | ×2.2 |
| Personal data sold without consent | ×3.0 |
| Maximum cap | $15 M per “event” |
Real example: mid-tier insurer, 2024 missed ransom notice, no SBOM, prior fine → $8 M ×1.8×1.5×2.2 = $47.5 M (settled at $12 M after remediation commitments).
- Quick-win checklist for 31 Oct certification
✅ NPI inventory signed off by CISO + CDO
✅ Independent auditor engaged (must be different firm from ISO 27001 cert)
✅ SBOM uploaded for every app touching NPI
✅ Post-quantum TLS pilot dashboard live (even if only 5 % traffic)
✅ 24-hour ransom-payment workflow tested with mock wallet
✅ Board minutes show 60-day cyber brief cycle
✅ Evidence package zipped and hash-timestamped ready for DFS portal upload
- Parting shot
NYDFS no longer asks “Do you have a policy?”
It asks “Show me the API call that proves the control fired in real time.”
If your evidence lives in a PowerPoint, start preparing the press release—and the cheque.
