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NY DFS · 23 NYCRR 500

NYDFS
Cybersecurity
Built for
Financial Services.

Full 23 NYCRR 500 readiness for banks, insurers, mortgage servicers, and every other DFS-licensed entity. Compliance consulting, annual penetration testing, and 24/7 SOC-as-a-Service — engineered around the CISO's April 15 certification.

Coverage:
🇺🇸🇪🇺
US · EU SOC · 24/7
23 NYCRR 500 Explained

The first — and strictest — US state cybersecurity rule for financial services.

NYDFS 23 NYCRR 500 applies to every person and entity operating under a license, registration, or similar authorization from the New York Department of Financial Services — banks, insurers, mortgage servicers, virtual currency businesses, and hundreds of other regulated categories.

The Second Amendment, effective November 2023 with staggered deadlines through November 2025, raised the bar dramatically. Multi-factor authentication across the environment. Endpoint detection and response. Annual penetration testing. Continuous vulnerability management. A written, tested incident response plan. A qualified CISO certifying compliance in writing every April 15 — and reporting material issues directly to the board.

Get it wrong, and the DFS can levy fines, suspend your license, or name-and-shame you in an enforcement action the whole industry will read. Q-Sec exists to make sure you don't.

A
Class A Company$1B+ avg revenue · 2,000+ employees
Full + Independent Audit
S
Standard Covered EntityMost DFS-licensed firms
Full 23 NYCRR 500
L
§500.19 Limited Exemption<20 employees · <$7.5M NY revenue · <$15M assets
Reduced controls
E
Fully ExemptNo NPI access · charitable foundations · certain agents
Notice of Exemption
Not sure which category you fall into? We'll scope it in one 30-minute call — including any §500.19 partial-exemption pathway that applies.
Full Coverage

Every section the superintendent cares about.

We map your current state against each section of Part 500, close the gaps, and leave the CISO with defensible evidence for the April 15 certification.

§500.2
Cybersecurity Program
Documented program based on a current risk assessment — reviewed, approved, and maintained.
§500.3
Cybersecurity Policy
Board-approved policy covering 14 specified domains, from access control to business continuity.
§500.4
Qualified CISO
A designated CISO reporting annually to the board — in writing — with material issues escalated timely.
§500.5
Penetration Testing
Annual penetration testing plus continuous vulnerability management, tied to the risk assessment.
§500.6
Audit Trail
Systems that reconstruct material financial transactions and detect cybersecurity events.
§500.7
Access Privileges
Least-privilege access, periodic review, and privileged-account governance across the environment.
§500.9
Risk Assessment
Annual risk assessment informing every other control — with methodology documented.
§500.11
Third-Party Security
Written policy governing vendor access to NPI, with due diligence and contractual protections.
§500.12
MFA Required
Multi-factor authentication for all remote access, privileged accounts, and third-party applications.
§500.14
Monitoring & EDR
Controls to monitor authorized users, detect anomalies, and EDR across endpoints (Amendment II).
§500.16
Incident Response
Written IR plan covering detection, containment, eradication, recovery, and BCDR continuity.
§500.17
72-hour Notice + Cert
Notify the superintendent within 72 hours. CISO files annual certification of compliance by April 15.
Our Services

Three service lines. One accountable team.

Compliance consulting, penetration testing, and 24/7 SOC-as-a-Service — delivered by the same Q-Sec engineers. Flat pricing. Senior consultants. No endless SOW amendments.

23 NYCRR 500 Compliance Consulting

Section-by-section gap assessment, risk assessment, policy authoring, §500.11 third-party program, BCDR alignment, and CISO-ready evidence for the April 15 certification.

Annual Penetration Testing

External, internal, web, API, and cloud pen tests aligned to PTES/OWASP/MITRE ATT&CK — delivered by senior testers, re-test included, evidence pack formatted for your DFS filing.

SOC-as-a-Service

24/7 SIEM + EDR monitoring, threat hunting, §500.14 anomaly detection, and the 72-hour §500.17 notification runbook — evidence preserved and audit-ready.

Our Process

From gap assessment to certification — no drama.

We've engineered out the delays. Onboarding in ten business days. Certification timelines depend on your starting point — we'll tell you exactly where you stand on day one.

01

Scoping Call

Identify your covered-entity category, §500.19 exemptions, and audit scope. One call, clear output.

02

Gap Assessment

Engineers review your environment against all 23 sections of Part 500 — producing a prioritised plan.

03

Remediation

We implement controls, close gaps, run the pen test, and document everything for the CISO.

04

Certification

Evidence pack, CISO certification of compliance, board report — filed on April 15, not April 14.

05

Ongoing Monitoring

SOC-as-a-Service stays on watch. Next year's assessment starts where this one ends.

Financial services clients represented

Specific engagements vary. Client names available under NDA.

Apr 15
Annual CISO
certification, on time
72h
Event notice runbook
fully automated
95%
Audit readiness
within one quarter
10
Business days
to operational SOC
Framework Alignment

One program. Multiple audits satisfied.

Part 500 doesn't exist in a vacuum. Most DFS-licensed firms also face SOC 2, and multi-jurisdictional groups answer to EU regulators too. Q-Sec builds one control stack that covers all of them.

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NYDFS + SOC 2

Dual-mapped control set · single evidence pack

Financial services firms carrying both a DFS license and a SOC 2 report shouldn't certify the same environment twice. We map NYDFS sections to SOC 2 Trust Service Criteria so one implementation satisfies both.

  • §500.5 pen test satisfies CC7.1 vulnerability management
  • §500.14 monitoring covers CC7.2 / CC7.3 controls
  • §500.16 IR plan aligned to CC7.4 / CC7.5
  • Annual CISO cert supported by SOC 2 Type II evidence
  • Single audit-readiness calendar, not two
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NYDFS + EU Group Regs

DORA · NIS2 · GDPR alignment for US-EU groups

US banks and insurers with EU operations also face DORA and NIS2. Our EU roots mean we understand those frameworks natively — and translate them into a single, compatible control program.

  • NYDFS §500.11 ↔ DORA Article 28 third-party risk
  • §500.17 72-hour notice aligned to NIS2 reporting windows
  • GDPR data handling mapped alongside §500.13 asset mgmt
  • Warsaw-based SOC with EU data residency guarantees
  • Unified policy set across jurisdictions
Why Q-Sec

We work like engineers, not consultants.

Most compliance firms tell you what's wrong. We fix it. Our engineers sit inside your environment — not on the other end of a 90-day engagement letter.

Flat

Transparent, Fixed Pricing

Engagements are priced flat. 50 endpoints or 5,000 — the fee doesn't change mid-quarter. No retainer creep, no per-alert billing.

10d

Fast Onboarding

Setup takes about ten business days. Then we start monitoring. While others spend six months on deployment, you're already protected.

24/7

Real SOC — No Bots

When you call, you reach our SOC in Warsaw — not a chatbot or an outsourced queue. Human analysts, verified escalations, minutes not hours.

CISO

Built for the Cert

Every artefact we produce is formatted for the CISO's April 15 certification. No re-writing, no translation layer between consultant and regulator.

Zero

We Don't Sell Fear

Incidents happen. The problem is not knowing about them. We make sure you do — fast, with context. No FUD. No vendor lock-in language.

One

Single Platform

SOC, MDR, Managed SIEM, and compliance consulting in one place. No stitching together vendors. No compliance tool that doesn't talk to your SOC.

Ready to start?

23 NYCRR 500 doesn't have to be
a six-month ordeal.

Get a scoping call with a Q-Sec engineer. We'll tell you exactly where you stand, which sections are audit-sensitive, and what needs to happen before April 15 — before you commit to anything.

No commitment required
Response within one business day
US & EU coverage
Flat-fee pricing