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NYDFS 23 NYCRR 500 · United States

NYDFS compliance, ready for April 15

Part 500 readiness for banks, insurers and other DFS-licensed firms, with evidence your CISO can sign.

23 NYCRR 500§ sections

The sections your CISO certifies

  1. 2Cybersecurity program
  2. 3Policy
  3. 4CISO & governance
  4. 5Penetration testing
  5. 6Audit trail
  6. 7Access privileges
  7. 9Risk assessment
  8. 11Third parties
  9. 12MFA
  10. 14Monitoring & training
  11. 16Incident response
  12. 17Notices & certification
Each section mapped to evidenceCert-ready
01 · Your category

Covered entity, Class A, or exempt?

Your size and New York revenue decide how much of Part 500 applies.

Simplified from sections 500.1 and 500.19. Class A also applies above $1 billion in total revenue, and the $15M total-assets test can qualify you for the limited exemption.

1 · Employees, including affiliates
2 · Yearly revenue from New York
Your category

Pick both answers

You’ll see which part of the regulation likely applies.

02 · The compliance year

A fixed April filing, plus incident deadlines

April 15, every year

Certify compliance for the previous year, or acknowledge non-compliance with a remediation plan. Your highest-ranking executive and your CISO both sign.

72 hIncident notice

Notify DFS after determining a cybersecurity incident occurred.

24 hExtortion payment

Notice of any ransom payment made.

30 daysWritten explanation

Why the payment was necessary and what you considered.

YearlyTesting and reporting

Penetration test, risk assessment review and a CISO report to the board.

03 · Part 500

Part 500, grouped by what it asks

The controls we put in place, so your CISO can sign on April 15.

500.2500.3500.4500.9

Program and governance

Risk assessment, board-approved policies and CISO reporting

500.5500.6500.14

Testing and monitoring

Annual penetration test, audit trail, monitoring and training

500.7500.12

Access and MFA

Least privilege, access reviews and MFA for everyone who logs in

500.11

Third parties

Vendor policy and due diligence for anyone touching your data

500.16

Response and continuity

Tested incident response and business continuity plans

500.17

Notices and certification

The 72-hour runbook and evidence for April 15

Simplified grouping of Part 500. We map evidence section by section during the engagement.

04 · Three service lines

One accountable team, three services

05 · Questions

NYDFS cybersecurity regulation FAQ

Who has to comply with 23 NYCRR 500?
Any person or business operating under a license, registration, charter or similar authorization from the New York Department of Financial Services, such as banks, insurers, mortgage companies and virtual currency businesses.
What is a Class A company?
A covered entity with at least $20 million in gross annual revenue from New York business in each of the last two fiscal years, plus either more than 2,000 employees or more than $1 billion in total gross annual revenue. Class A companies face extra requirements, including an annual independent audit.
What are the NYDFS notification deadlines?
Notify DFS within 72 hours of determining that a cybersecurity incident occurred. If you make an extortion payment, give notice within 24 hours and a written explanation within 30 days.
When is the annual certification due?
By April 15 each year, covering the previous calendar year. You either certify compliance or acknowledge non-compliance with a remediation plan, signed by your highest-ranking executive and your CISO.
Does Part 500 require penetration testing?
Yes. Section 500.5 requires penetration testing at least once a year, plus automated vulnerability scans. See penetration testing.
Does Part 500 require multi-factor authentication?
Yes. Since 1 November 2025, section 500.12 requires MFA for anyone accessing your information systems, with limited exceptions your CISO approves.
Free assessment

Prepare for April 15

Your category, current controls and certification timeline.

Teams we work with
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Pixel icons by Streamline, CC BY 4.0. This page summarises 23 NYCRR 500 and is not legal advice.