Ampyx Cyber Blog
The Intersection of Regulation & Resilience
CIP-003 Low Impact Vendor Remote Access: Expert Audit Questions
A deep dive into NERC’s Currently Compliant Podcast Episode 8, extracting every key question being asked about CIP-003-9 vendor remote access. These questions provide a clear view into audit expectations across the ERO Enterprise and highlight where entities are struggling with visibility, control validation, and monitoring of vendor access.
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.
Cyber on Tap, Part Two: New York's Water Cybersecurity Regulation Is Now in Force
New York's Appendix 5-E cybersecurity regulation for public water systems took effect March 11, 2026, making it the first mandatory, enforceable water cybersecurity framework in the country. This post covers who is in scope, what is required, when it is due, and what resources are available to help. It also examines what New York's action means in the context of a federal policy environment that is actively stepping back from sector-specific cybersecurity regulation.
National Cyber Strategy: What It Means for Critical Infrastructure
The Trump administration released its long-awaited National Cyber Strategy. Six pages, six pillars, and a clear signal that federal cyber policy is shifting toward offensive posture and regulatory streamlining. For critical infrastructure operators, the document raises more questions than it answers. Here is what it says, what it doesn't, and what you should do about it.
Redesigning the Machine: NERC Board Accepts Transformational Standards Modernization Plan
The NERC Board has approved a historic transformation of the standards development process to meet the speed of the modern grid. Aiming for a 12–18 month timeline, the new framework re-engineers how NERC addresses risks from data centers, IBRs, and VPPs. Read our deep dive into the 2027 roadmap, the new SME pool, and the upcoming shift in voting eligibility.
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.
NERC’s CIP Roadmap and the Future of Grid Cybersecurity
NERC’s new CIP Roadmap signals a major shift in how cyber risk will be regulated across the power grid. This Policy Pulse explains what NERC released, why it matters, what standards and guidance are coming next, and how utilities, generators, and grid operators should prepare for expanding CIP scope and enforcement.
Reinforcing the U.S. Grid: The 2025 USCC Report on Chinese Energy Influence
The 2025 USCC Annual Report outlines national security risks from PRC-linked technologies in the U.S. energy sector. It offers clear, field-informed recommendations, including testimony from Ampyx Cyber’s CEO, on supply chain threats, OT device transparency, and cyber response. Read the full analysis and policy roadmap.
Cybersecurity Performance Goals 2.0: Governance First, Outcomes Always
CISA’s Cybersecurity Performance Goals 2.0 reshape baseline expectations for critical infrastructure. The update elevates governance, strengthens OT-specific requirements, and shifts from checklist controls to outcome-driven resilience. This Policy Pulse post breaks down what changed, why it matters, and how operators should prepare.
Cybersecurity Signals in the 2025 National Security Strategy
The 2025 National Security Strategy weaves cybersecurity into every major national priority, from resilient infrastructure and protected supply chains to technology leadership and secure global partnerships. This overview highlights the core cyber related themes and what they signal for critical infrastructure and industry.
ERO CMEP 2026: Oversight in the Age of Transformation
The Electric Reliability Organization’s (ERO) 2026 Compliance Monitoring and Enforcement Program Implementation Plan (CMEP) signals a new era in how risk-based oversight keeps pace with a rapidly transforming grid. Released in October, the plan refines NERC’s compliance priorities for the coming year, retiring Incident Response as a distinct risk element and introducing Grid Transformation as a central theme.
FERC 2025 CIP Audit Findings: DER Impact Ratings, Vendor Oversight Gaps, and Cloud Compliance Risk
FERC’s latest CIP audit lessons for 2025 highlight three rising compliance risks. Entities are undercounting DERs in GOP control center impact ratings, outsourcing compliance work without adequate oversight, and moving EACMS or PACS functions to the cloud without a defensible evidence path. These issues now represent real audit exposure across the US bulk power system.
Closing the Gaps: FERC Order 912 and the Future of Supply Chain Risk Management
FERC Order 912 marks a shift in supply chain cybersecurity for the Bulk-Power System. It directs NERC to strengthen supply chain protections by closing gaps in risk identification, reassessment, and response, and by extending coverage to Protected Cyber Assets. Vendor data validation is encouraged but not mandated, and NERC has 18 months to deliver new or revised standards.
Securing Tomorrow’s Grid: FERC Acts on Low Impact, Virtualization, and Supply Chains
FERC’s September 2025 actions reshaped grid reliability standards by tightening security requirements for low-impact assets, adding authentication, encryption, and monitoring; new requirements and new definitions to support secure adoption of virtualization technologies; and expanding supply chain protections to cover Protected Cyber Assets and other connected systems.
Interconnection Gets Teeth: Virginia Puts Cyber into the Rulebook
Virginia moves cyber into DER interconnection. State Corporation Commission (SCC) Staff proposes adopting IEEE 1547.3-2023 and the NARUC/DOE Baselines, requiring utilities to publish minimum cybersecurity standards, audit & report annually, and align Technical Interconnection (TIIR) settings for secure comms/ports. Bottom line: meeting utility cyber controls becomes a condition of interconnection.
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.
2025 RISC Report: Cybersecurity at the Center of Grid Reliability
The NERC 2025 RISC Report elevates cybersecurity to the core of grid reliability, alongside grid transformation, extreme events, interdependencies, and volatile energy policy. Unlike past reviews, this report is a forward-looking roadmap, urging modernization, cross-sector coordination, and resilience in a digitized, high-risk energy landscape.
Cyber on Tap: NY's Water Utilities Face New Cyber Rulebook
New York has proposed the first mandatory cybersecurity regulation for water and wastewater systems, targeting utilities serving over 3,300 people. With requirements for vulnerability assessments, incident reporting, and executive oversight, this rule signals a shift toward enforceable cyber resilience and other states may soon follow.
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.