Ampyx Cyber Blog
The Intersection of Resilience & Regulation
One Incident, Several Reports: What GAO's Panel & CISA's Town Halls Say About Harmonization [Updated]
A single cyber incident at a utility can owe reports to several federal agencies, each with its own clock and definition. The Government Accountability Office's latest panel heard that again, and electric, gas, oil, and water groups told the Cybersecurity and Infrastructure Security Agency the same thing in June. This post looks at where the overlap sits and where the reporting rule stands.
Beyond the Checklist: The Place of Internal Controls in NERC CIP Compliance Programs
NERC CIP compliance is no longer a checklist exercise. Internal controls are now how the ERO Enterprise measures whether an entity can sustain compliance over time. This post breaks down what internal controls are, the preventive, detective, and corrective types, how entities test and evidence them, and how WECC's ICDCT and the December 2025 ERO Guide put controls at the center of audit scoping.
Using the Work of Others in NERC CIP and O&P Compliance
The work of others lets you lean on someone else's assessment as compliance evidence. It does not transfer accountability. This breakdown maps the ERO guidance stack, the two-part test auditors apply, worked examples for CIP-013 vendor assessments and BCSI in the cloud, the FERC FY2025 findings on delegation gone wrong, and the audit prep questions to answer first.
NERC CIP Audit Readiness: A Strategic Compliance Guide 2026
Stop treating NERC CIP audits as fire drills. Learn the proactive timelines, documentation discipline, and live audit approach that separate prepared utilities from panicked ones. Here’s a strategic guide to compliance sanity from a former CIP auditor.
What Multi-Region Entities Need to Know About Coordinated Oversight in 2026 [Updated]
NERC's Coordinated Oversight Program lets multi-region entities consolidate compliance monitoring under one Lead Regional Entity, eliminating duplicate audits across six footprints. New for 2026: Category 2 GO/GOP eligibility opens May 15, annual asset verification becomes formal, periodic group reviews go standard. Breakdown of qualifications, modification paths, and audit prep questions.
Inside the ERPQ: How One Form Shapes Your Audit
NERC's Currently Compliant Episode 9 introduced the consolidated Entity Risk Profile Questionnaire (ERPQ). What the podcast did not draw is the bigger picture: with ICE eliminated and continuous internal controls evaluation now embedded across CMEP, the ERPQ is the entry point into how the ERO Enterprise sees you for every monitoring cycle.
Is Something Weird Happening on Your System?
Learn how critical infrastructure operators can spot the early signs of cyber intrusions directly from the control room. Drawing on the latest NERC and CISA guidance, this updated guide details specific physical hardware, workstation, and SCADA anomalies to watch for. Empower your frontline staff with a proactive "See Something, Say Something" cyber defense strategy tailored for OT environments.
FERC Issues Orders on Virtualization and Low Impact: What Changed and What You Need to Do
FERC unanimously approved Order Nos. 918 and 919 on March 19, 2026, finalizing CIP virtualization standards and new low-impact BES Cyber System controls, plus an updated "Control Center" definition. All CIP-registered entities are affected. Implementation windows are 24 and 36 months respectively. Compliance programs should begin gap assessments now.
The E-ISAC's 2025 Report: Real Progress, Remaining Constraints
The E-ISAC's 2025 End-of-Year Report shows real growth in membership, engagement, and threat intelligence output. But a structural challenge rooted in its funding and governance relationship with NERC continues to limit the incident sharing that collective defense depends on. Comparing E-ISAC's reported numbers against peer ISACs in health and financial services reveals how much ground remains.
How CMEP Version 8 Reshapes NERC’s Compliance Model
The CMEP Version 8 does not rewrite NERC compliance, rather it stabilizes it. Building on years of evolution, the updated Manual reinforces risk-based oversight, professional judgment, technical competence, and enterprise consistency across all Reliability Standards. The result is a more mature, defensible compliance model that shapes how audits, enforcement, and reliability governance now operate.
From Spot Evaluations to Continuous Oversight: NERC’s New Internal Controls Model
NERC’s December 2025 ERO Enterprise Guide replaces the old ICE model with continuous, risk based internal control oversight embedded across CMEP and Joint Monitoring. This shift makes control design, evidence, and effectiveness a core driver of Compliance Oversight Plans (COPs), audit depth, and how the Regions measure compliance maturity.
INSM Just Got Clearer: Key Takeaways from the NATF Guidance
NATF has released new CIP-015 INSM guidance that confirms a risk-based approach for collection points, clarifies scope around ESP boundaries, contains numerous useful reference models, and reinforces practical retention strategies. It aligns closely with our INSM playbook, especially on passive visibility, multicast deduplication, and EACMS/BCSI determinations for INSM platforms.
CIP-015 Clarified: Mixed-use PACS/EACMS and What’s Actually In Scope
FERC Order 907-A clarifies CIP-015 on shared networks. INSM must monitor only east-west traffic used for access monitoring of EACMS and PACS. Non-CIP assets and data flows are out of scope, even in mixed-use or commingled PACS/EACMS environments. Learn practical patterns to filter collection, segment analytics, and produce audit-ready evidence.
CIP-002-8, Decoded: Who’s In, Who’s Out Under the New 2.12
Upcoming NERC CIP-002 grid rules change which control centers fall under stricter cybersecurity protections. This post explains the new test in plain language, who is likely covered, and when local, load-serving areas can qualify for an exception. We also share a quick checklist to help utilities document what they have today and avoid surprises later.
CIP-015-1 INSM: A Practical Playbook
NERC CIP-015 makes east-west visibility inside the ESP mandatory. This playbook shows how to stand up INSM the right way through risk-based data feeds, ICS-aware anomaly detection, evaluation tied to incident response, and defensible evidence on a timeline to 10/1/2028 and beyond. Avoid common pitfalls and design now for the likely CIP-015-2 expansion.
Strategic Value of Self-Reporting in NERC CIP Compliance
Self-reporting in NERC CIP isn’t a weakness. It’s a sign of maturity. Proactive disclosures build regulatory trust, reinforce internal controls, and empower compliance teams to improve. When done right, self-reporting signals ownership, not failure, and positions your program as resilient, transparent, and credible.
Monitoring Meets Mandate: Will the Next CIP-015 Standard Deliver on FERC’s Vision?
FERC approved CIP-015-1, but also ordered NERC to expand it. The new SAR outlines how INSM requirements will extend beyond the ESP to include EACMS and PACS systems. This post breaks down how the SAR aligns with FERC’s directive, what still needs attention, and why internal visibility is no longer optional.
Help Shape the Future of the NERC CIP Standards
NERC is asking for industry input on the future of CIP Standards. As part of its 2025 Work Plan, NERC has launched a survey to identify and prioritize emerging security risks to the Bulk Power System. The results will directly inform a roadmap for updating the CIP Standards to address today’s evolving threat landscape. What’s happening, why it matters, and how you can participate before the July 22 deadline.
FERC Quietly Closes The Books on RM20-12-000
FERC has officially closed Docket RM20-12-000, ending a five-year inquiry into potential gaps in the CIP Reliability Standards. While the docket is withdrawn, the underlying concerns—data security, anomaly detection, and coordinated cyberattacks—are being addressed through recent standards like CIP-015-1 (INSM) and proposed updates to CIP-003.
FERC Finalizes INSM Standard: CIP-015-1 and the New Visibility Mandate for the Grid
On June 26, the Federal Energy Regulatory Commission issued Order No. 907, approving the new NERC Reliability Standard CIP-015-1: Cyber Security – Internal Network Security Monitoring (INSM). This marks a critical shift in how we approach cybersecurity within the Bulk Electric System. It also raises the bar significantly on what’s expected for visibility inside the network perimeter.