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ARTICLE · 21 MAY 2026

NYDFS Issues Two Industry Letters On Responding To A Heightened Cybersecurity Threat Environment, Including “Frontier AI Models”

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The New York State Department of Financial Services has issued two industry letters addressing cybersecurity risks in an evolving threat landscape, with particular focus on emerging frontier AI models that can rapidly identify and exploit system vulnerabilities.

United StatesPrivacy
Justin Herring
Justin Herring
Jeffrey P. Taft
Jeffrey P. Taft
Kathryn Allen
Kathryn Allen
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On May 21, 2026, the New York State Department of Financial Services (“NYDFS” or the “Department”) published two industry letters urging regulated entities to review their cyber programs in response to a heightened cybersecurity threat environment. These issuances are the latest guidance from the Department to the financial services industry related to cybersecurity and the changing threat environment. These letters serve as further confirmation that regulators are focused on the risks posed by new AI models with groundbreaking ability to find and exploit vulnerabilities.

The first industry letter, Guidance on Measures Regulated Entities Should Consider in a Heightened Cybersecurity Threat Environment (the “Heightened Cyber Threat Guidance”), sets forth best practices for regulated companies when there is a “heightened threat environment.” Heightened threat environments can come from “geopolitical events” or “technological developments.” Examples of geopolitical events presumably

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