Future NERC CIP: Regulatory Changes & Trends

Shahzad Masood


With the ongoing transformations and emerging cybersecurity issues impacting the energy sector, the North American Electric Reliability Corporation (NERC) Critical Infrastructure Protection (CIP) standards are poised for significant updates to address emerging risks and align with industry best practices. 

Utility operators, vendors, and service providers must stay ahead of these regulatory changes and trends to ensure the resilience of the bulk power system (BPS) and maintain compliance. This guide will provide you with insights into the key areas of focus and potential implications for entities subject to NERC CIP standards.

Expanding the Scope of Critical Cyber Assets

One of the significant trends in NERC CIP is the increased emphasis on supply chain risk management. As the energy sector becomes more interconnected and reliant on third-party vendors and service providers, the potential for cyber threats to infiltrate the system through compromised supply chains has grown. 

NERC CIP is expected to enhance supply chain risk management requirements by mandating more rigorous vendor assessments, software integrity checks, and oversight mechanisms to mitigate these risks. The rapid advancement of technologies such as cloud computing, virtualization, and the Internet of Things (IoT) has introduced new challenges for critical infrastructure protection. 

NERC is likely to expand the scope of critical cyber assets to include these emerging technologies, ensuring that appropriate security controls and safeguards are in place to protect their integration into the BPS.

Enhancing Cybersecurity Resilience

As cyber threats become more sophisticated and persistent, NERC is expected to place greater emphasis on incident response and recovery planning. Entities may be required to develop and maintain comprehensive incident response plans, conduct regular exercises and drills, and demonstrate their ability to quickly recover from cyber incidents while minimizing the impact on the BPS.

To stay ahead of evolving cyber threats, NERC CIP is likely to mandate the implementation of continuous monitoring and threat intelligence capabilities. Entities may need to establish real-time monitoring systems, use threat intelligence feeds, and collaborate with industry partners and government agencies to share information and coordinate response efforts.

Resilience MeasureDescriptionBenefitsChallenges
Incident Response PlanningDeveloping comprehensive plans, conducting regular exercises, and demonstrating recovery capabilitiesMinimizes impact of cyber incidents, Enhances preparedness, Improves coordinationResource-intensive, Requires ongoing updates and testing
Continuous MonitoringImplementing real-time monitoring systems, leveraging threat intelligence feeds, and collaborating with industry partnersEarly detection of threats, Proactive response, Improved situational awarenessRequires skilled personnel and resources, Integration challenges with existing systems
Threat IntelligenceGathering and analyzing information about potential threats, vulnerabilities, and threat actorsEnables proactive security measures, Provides context for risk assessment, Supports informed decision-makingQuality and reliability of intelligence sources, Effective analysis, and dissemination
Resilience TestingConducting regular simulations, tabletop exercises, and penetration testingIdentifies weaknesses and gaps, Validates incident response plans, Improves overall resilienceRequires dedicated resources and expertise, Potential operational disruptions

Emerging Priorities for NERC CIP

  • Establishing unified cybersecurity standards across sectors, international harmonization
  • Strengthening identity, and credential management systems for critical infrastructure
  • Fostering public-private partnerships for cybersecurity research, knowledge sharing
  • Developing energy sector-specific cybersecurity workforce training curriculums
  • Incorporating cybersecurity resilience into the design of new systems
  • Addressing cyber risks from the convergence of IT/OT systems
  • Leveraging AI/machine learning for cyber threat detection, response
  • Evolving regulations to account for emerging technologies like 5G

Strengthening Workforce Management

The growing complexity of cybersecurity challenges and the shortage of skilled professionals in the energy sector have highlighted the need for robust workforce management strategies. NERC CIP may introduce new requirements for cybersecurity workforce development, including training programs, certifications, and measures to attract and retain skilled cybersecurity personnel.

Insider threats, whether intentional or unintentional, significantly endanger critical infrastructure. NERC is expected to strengthen its insider threat mitigation requirements, mandating more stringent access controls, personnel risk assessments, and ongoing monitoring of employee activities to detect and prevent potential insider threats.

Aligning with Industry Standards

As the cybersecurity landscape evolves, industry standards and best practices continue to emerge. NERC is likely to align its CIP standards with widely adopted cybersecurity frameworks, such as the NIST Cybersecurity Framework, to ensure a more comprehensive and consistent approach to critical infrastructure protection.

Effective information sharing and collaboration among industry stakeholders is crucial for enhancing cybersecurity resilience. NERC CIP may introduce new requirements or incentives to encourage the sharing of threat intelligence, best practices, and lessons learned among entities, strengthening the collective defense against cyber threats.

Enhancing Compliance and Enforcement Mechanisms

Risk-Based Compliance Monitoring: NERC is exploring the adoption of a risk-based approach to compliance monitoring, which would prioritize the assessment of entities based on their risk profile and the potential impact of non-compliance on the BPS. This approach aims to allocate resources more effectively and focus on areas of higher risk. 

According to NERC, in 2022, risk-based compliance monitoring identified and addressed 90% of potential high-risk violations in the Bulk Power System (BPS) more efficiently than traditional methods, significantly improving resource allocation and compliance effectiveness

Streamlining Compliance Processes: As the CIP standards evolve and become more complex, NERC may introduce measures to streamline compliance processes, such as leveraging automation and advanced analytics to reduce administrative burdens and improve the efficiency of compliance monitoring and reporting.

Addressing Emerging Threats and Vulnerabilities

The convergence of operational technology (OT) and information technology (IT) systems has created new attack vectors and vulnerabilities. NERC CIP is likely to address the security of cyber-physical systems, ensuring that appropriate controls and safeguards are in place to protect these integrated environments.

As new technologies such as artificial intelligence, quantum computing, and 5G networks continue to evolve, they may introduce new cybersecurity risks and vulnerabilities. NERC will need to stay vigilant and proactively address the potential implications of these emerging technologies on critical infrastructure protection.


The future direction of NERC CIP is propelled by the necessity to adjust to promptly emerging cybersecurity concerns and new threats. Staying ahead of regulatory changes and industry trends helps entities subject to NERC CIP better prepare for compliance and enhance the overall resilience of the bulk power system.

Collaboration, continuous improvement, and a proactive approach to cybersecurity are key to navigating the complexities of critical infrastructure protection in the energy sector.

Frequently Asked Questions

Why is workforce management a focus area for NERC CIP?

The growing complexity of cybersecurity challenges and the shortage of skilled professionals in the energy sector have highlighted the need for robust workforce development and insider threat mitigation strategies.

What is the importance of aligning with industry standards and best practices?

Incorporating widely adopted cybersecurity frameworks and promoting information sharing can help ensure a more comprehensive and consistent approach to critical infrastructure protection.

How might compliance and enforcement mechanisms evolve?

NERC may adopt a risk-based approach to compliance monitoring, streamline processes through automation, and enhance enforcement mechanisms to address non-compliance more effectively.

Key Takeaways

  1. Addressing supply chain risks and incorporating emerging technologies are key priorities in expanding the scope of critical cyber assets.
  2. Enhancing cybersecurity resilience through incident response planning, continuous monitoring, and threat intelligence is crucial.
  3. Strengthening workforce management, including cybersecurity workforce development and insider threat mitigation, is essential.
  4. Aligning with industry standards, and best practices, and promoting information sharing can improve collective defense against cyber threats.
  5. NERC is exploring various mechanisms to improve the effectiveness of CIP standards.

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