The proposed rule shifts expectations away from simple documentation toward operational proof of security controls, focusing on whether they are active, visible, and testable in real environments.
Frequently Asked Questions (FAQ)
Regulators expect organizations to have the capability to restore critical systems within a 72-hour restoration window.
Organizations must be able to isolate a compromised system quickly and consistently to stop lateral movement without being forced to shut down large parts of the network.
Organizations must provide real examples of enforced controls, using logs or reports to walk auditors through how these controls are applied consistently across the environment.
The process should start by validating what is actually happening in the environment today and then focus on strengthening controls that improve visibility and limit incident spread.