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ARTICLE · 05 NOVEMBER 2025

Final NYDFS Cybersecurity Rules Take Effect: What Financial Services Companies Must Do Now

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As of November 1, 2025, two critical updates to the New York Department of Financial Services (NYDFS) Cybersecurity Regulation (the Cybersecurity Regulation or "Part 500") took effect for Financial Services Companies.

United StatesTechnology
Christian Auty
Christian Auty
Tarrian Ellis
Tarrian Ellis

As of November 1, 2025, two critical updates to the New York Department of Financial Services (NYDFS) Cybersecurity Regulation (the Cybersecurity Regulation or "Part 500") took effect for Financial Services Companies.1

Covered Entities must now finalize implementation of two critical security components: (1) mandatory Multi-Factor Authentication (MFA) for nearly all Covered Entities in nearly all cases; and (2) development of a comprehensive, documented Asset Inventory Program.

Background of the Cybersecurity Regulation

The NYDFS Cybersecurity Regulation establishes a robust, principles-based framework designed to manage cyber risk in the state's financial sector.

The Cybersecurity Regulation governs "Covered Entities," defined as persons operating under or required to operate under a license, registration, charter, certificate, permit, accreditation or similar authorization under New York's Banking Law, Insurance Law or Financial Services Law.2 The Regulati

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