The North American Electric Reliability corporation (NERC) Critical Infrastructure Protection (CIP) Standard CIP-003-9 has a new sub requirement that requires organizations to implement specific controls to manage and secure vendor electronic remote access to low-impact Bulk Electric System (BES) Cyber Systems. (Please see Implementation Plan published by NERC.) With the increased supply chain issues and the number of vendor compromises over the last few years, events dictate the need for enhanced vendor electronic remote access security controls for low impact facilities. .png?width=550&height=550&name=NERC%20blog%20posts%20(2).png)
CIP-003-9 is subject to future enforcement for April 1st, 2026. In order to prepare for compliance, organizations need to review and enhance their CIP-003 programs. Some of the recommended actions and security improvements to prepare for compliance with CIP-003-9 are as follows:
- Implement Secure Authentication: Implement multi-factor
authentication (MFA) or other robust methods to verify the identity of vendors before granting a remote access session. - Enforce Principle of Least Privilege: Authorize vendors to access only the systems and data necessary for their specific tasks, limiting exposure of critical infrastructure. Only the minimal requested access should be granted.
- Deploy Real-Time Monitoring: Organizations should set up systems to actively monitor vendor activities during remote access sessions to identify and respond to any anomalies or suspicious behavior.
- Maintain Detailed Logging: Record all vendor access events, including login times, actions performed, and session durations, to support audits and incident investigations (most remote access software has this capability).
- Define the Revocation Process: Establish a procedure to immediately terminate vendor access when it is no longer needed or if a security risk is detected.
- Conduct Regular Access Reviews: Periodically review all active vendor access permissions to ensure that proper access has been granted and access that is no longer required has been removed.
- Define Security Requirements: Incorporate cybersecurity obligations into vendor contracts or agreements, specifying the controls vendors must follow to gain and maintain access to the organizations BES Cyber Systems.
- Clarify Vendor Responsibilities: Ensure vendors understand their role in maintaining secure access and their duty to report any security incidents promptly.
By implementing these measures, organizations can secure vendor electronic remote access, protect low-impact BES Cyber Systems, and achieve full compliance with CIP-003-9.
For questions or to discuss further, reach out to the GDS Energy Reliability & Security Team and let us know how we can help.