On November 1, 2023, the New York State Department of Financial
Services (NYDFS) amended its
cybersecurity regulation, 23 NYCRR 500 (or Part 500). NYDFS has
published guidance on the implementation timeline for key
compliance dates for the various categories of entities impacted
(including Small Businesses, Class A Companies
and Covered Entities).
In addition, NYDFS has published training
materials and FAQs regarding the new requirements.
As of December 1, 2023, Small Businesses, Class
A Companies, and Covered Entities were required to report cyber
incidents, including ransomware attacks, to NYDFS.
The next major deadline is April 15, 2024, for
compliance with section 500.17(b) of amended Part 500. This
requires all companies to submit a Certification of Material
Compliance or Acknowledgment of Noncompliance to
the NYDFS. NYDFS has provided in its FAQs that if a "Covered
Entity cannot certify that it was in material compliance with the
Cybersecurity Regulation