CxO™ DELIVERABLE
NYDFS 500 Cybersecurity Assessment
A NYDFS 500 cybersecurity assessment is a review of your cybersecurity program against New York's 23 NYCRR Part 500, including the amended requirements now in full effect. DAG Tech's vCCO tests each section, documents the evidence and gives you a plan so your annual filing is backed by proof.
Custom proposal · Last updated October 2026
The Short Answer
What Is a NYDFS 500 Cybersecurity Assessment?
A NYDFS 500 cybersecurity assessment measures a regulated entity's cybersecurity program against the New York Department of Financial Services rule, 23 NYCRR Part 500, and identifies what must change before the annual compliance filing. Part 500 applies to banks, insurers, mortgage companies, money transmitters and other entities licensed or registered with NYDFS. The Second Amendment, adopted in November 2023, phased in through November 1, 2025, and every part of it is now in effect. Requirements include a CISO with board reporting, risk assessments, written policies, vulnerability scanning, access privilege limits and annual reviews, asset inventories, MFA for remote access and for access to any information system, encryption, incident response and business continuity plans, and annual training. Covered entities must also notify NYDFS of cybersecurity events and file an annual compliance certification. Larger Class A companies also need independent audits, privileged access management and centralized logging.
Certifying without evidence is a real risk, because examiners review logs, scan results, board minutes and training records. The assessment tells you whether you can sign, and what to fix first if you cannot. DAG Tech is not a law firm, so questions about licensing status or exemptions go to your counsel. The vCCO can also support the CISO function or work alongside your designated CISO, and recommends who should close each gap: your team, another provider or DAG Tech when it is the best fit.
At a glance
SPEC SHEET- DELIVERABLE TYPE
- Framework gap assessment
- ALSO KNOWN AS
- NYDFS Part 500 assessment, 23 NYCRR 500 gap analysis, NYDFS cybersecurity regulation review
- PRACTICE AREA
- IT Compliance (CxO™)
- BEST FOR
- NYDFS-licensed or registered financial services and insurance organizations
- WHAT WE NEED
- Current cybersecurity program, last certification, risk assessment and board reports
- NEXT STEP
- Request a NYDFS 500 assessment proposal
Scope
What We Evaluate
We test your program against each section of Part 500 and check the evidence behind it.
Governance and CISO
CISO designation, board oversight and the annual written report to the board.
Risk assessment and policies
Whether your risk assessment is current and drives approved written policies.
Asset inventory
Whether your inventory tracks owner, location, classification, support end dates and recovery objectives.
Access privileges and MFA
Least privilege, annual access reviews, prompt removal and MFA for any information system access.
Vulnerability management
Automated scanning, penetration testing and risk-based remediation timelines.
Monitoring and training
Activity logging, email and web filtering, and annual training that covers social engineering.
Encryption and data retention
Encryption of nonpublic information in transit and at rest, and secure disposal.
Incident response and continuity
Plans, testing, backups and incident notification processes.
Third-party service providers
Policies for vetting and overseeing providers that access nonpublic information.
The Deliverable
What You Receive
- Section-by-section Part 500 gap report
- Evidence inventory showing what supports your annual filing
- Certification readiness opinion with open items listed
- Class A applicability notes when relevant
- Remediation plan suitable for an acknowledgment of noncompliance
- Roadmap with owners, dates and scoped hours
How It Works
How It Runs
- STEP 01
Kickoff
We confirm your entity type, any exemptions, Class A status and your filing date.
- STEP 02
Document Review
The vCCO reviews your policies, risk assessment, board reports and last filing.
- STEP 03
Evidence Testing
We sample logs, scans, access reviews and training records to confirm controls operate.
- STEP 04
Readout
You get the gap report, a filing readiness view and a dated remediation plan.
When to Start
Signs You Need a NYDFS 500 Assessment
- Your annual compliance filing is coming and you are not sure you can certify.
- MFA is not yet required for every system, as the amended rule expects.
- Your asset inventory is a spreadsheet nobody owns.
- The board has not received a written cybersecurity report this year.
- You may have crossed the Class A thresholds.
- A NYDFS examination is scheduled.
Compare
NYDFS 500 Assessment vs. Cybersecurity Risk Assessment
| NYDFS 500 Assessment | Cybersecurity Risk Assessment | |
|---|---|---|
| Question it answers | Does our program meet each section of 23 NYCRR Part 500? | What are our biggest security risks? |
| Output | Section-level gap report, evidence inventory and filing readiness view | Risk findings and recommendations across the IT environment |
| When | Before your annual filing or a NYDFS exam | Any time you need a security baseline, and as input to Part 500's risk assessment |
| Led by | DAG Tech virtual compliance officer (CxO™) | DAG Tech IT assessments team |
Related
Often Paired With
FAQ
NYDFS 500 Cybersecurity Assessment Questions
What is a NYDFS 500 cybersecurity assessment?
It is a review of your cybersecurity program against 23 NYCRR Part 500. It checks each section, samples the evidence behind it and tells you whether you can support a certification of material compliance.
Are all the 2023 amendments in effect now?
Yes. The Second Amendment phased in between November 2023 and November 1, 2025. The final phase added the expanded MFA and asset inventory requirements, so the full amended rule now applies.
What if we cannot certify compliance?
You can file an acknowledgment of noncompliance that identifies the gaps and your remediation timeline. The assessment produces the plan you need for that filing.
What is a Class A company?
Class A companies are larger covered entities defined by New York revenue and by employee count or global revenue thresholds. They have added duties, including independent cybersecurity audits, privileged access management and centralized logging. Confirm your status with counsel; we assess the controls.
How much does a NYDFS 500 assessment cost?
Every deliverable is scoped in hours at the CxO rate, based on your size, Class A status and number of systems. Your proposal shows the total before work starts.
Can DAG Tech act as our CISO?
Part 500 lets a covered entity use a CISO from a third-party provider, but the entity stays responsible for compliance. A DAG Tech vCISO can fill that role or support your designated CISO, working with the vCCO on evidence and filings.
Get Started
Request a NYDFS 500 assessment
Tell us what you need. We scope the hours and send a CxO proposal.
Sent with your request: CxO: vCCO: NYDFS 500 Cybersecurity Assessment
- 01A scoping call with a fractional executive
- 02Every task, deliverable, hour and cost in one proposal
- 03A roadmap with start date
The CxO™ Program
Explore Every Practice Area
About DAG Tech NYDFS 500 Cybersecurity Assessment
A NYDFS 500 cybersecurity assessment is a review of your cybersecurity program against New York’s 23 NYCRR Part 500, including the amended requirements now in full effect. DAG Tech’s vCCO tests each section, documents the evidence and gives you a plan so your annual filing is backed by proof.
A NYDFS 500 cybersecurity assessment measures a regulated entity’s cybersecurity program against the New York Department of Financial Services rule, 23 NYCRR Part 500, and identifies what must change before the annual compliance filing. Part 500 applies to banks, insurers, mortgage companies, money transmitters and other entities licensed or registered with NYDFS. The Second Amendment, adopted in November 2023, phased in through November 1, 2025, and every part of it is now in effect. Requirements include a CISO with board reporting, risk assessments, written policies, vulnerability scanning, access privilege limits and annual reviews, asset inventories, MFA for remote access and for access to any information system, encryption, incident response and business continuity plans, and annual training. Covered entities must also notify NYDFS of cybersecurity events and file an annual compliance certification. Larger Class A companies also need independent audits, privileged access management and centralized logging.