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October 31, 2024

Understanding NERC CIP-015 Requirements

Learn about NERC CIP-015 and its internal network security monitoring requirements. Discover how to ensure compliance and enhance your security posture.
Inside the SOC
Darktrace cyber analysts are world-class experts in threat intelligence, threat hunting and incident response, and provide 24/7 SOC support to thousands of Darktrace customers around the globe. Inside the SOC is exclusively authored by these experts, providing analysis of cyber incidents and threat trends, based on real-world experience in the field.
Written by
Daniel Simonds
Director of Operational Technology
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31
Oct 2024

Background: NERC CIP-015

In January of 2023 the Federal Energy Regulatory Commission (FERC) released FERC Order 887 which addresses a critical security gap in Critical Infrastructure Protection (CIP) standards, the lack of internal network security monitoring (INSM).

The current NERC CIP standards only require solutions that use traditional detection systems that identify malicious code based on known rules and signatures. The new legislation will now require electric cooperatives to implement INSMs to detect malicious activity in east-west network traffic. INSMs establish a baseline of network activity and detect anomalies that would bypass traditional detection systems, improving an organization’s ability to detect novel threats. Without INSM, organizations have limited visibility into malicious activities inside their networks, leaving them vulnerable if attackers breach initial defenses like firewalls and anti-virus software.

Implementation of NERC CIP-015

Once approved, Bulk Electronic Systems (BESs) will have 36 months to implement INSM, and medium-impact BESs with external routable connectivity (ERC) will have 60 months to do so.

While the approval of the NERC CIP-015 requirements have not been finalized, preparation on the part of electric cooperatives should start as soon as possible. Darktrace is committed to helping electric cooperatives meet the requirements for INSM and help reach compliance standards.

Why is internal network security monitoring important?

NERC CIP-015 aims to enhance the detection of anomalies or unauthorized network activity within CIP environments, underscoring the importance of monitoring East-West traffic within trust zones. This approach enables faster response and recovery times.

INSMs are essential to detecting threats that bypass traditional defenses. For example, insider threats, sophisticated new attack techniques, and threats that exploit compromised credentials—such as those obtained through phishing or other malicious activities—can easily bypass traditional firewalls and antivirus software. These threats either introduce novel methods or leverage legitimate access, making them difficult to detect.

INSMs don’t rely on rules and signatures to detect anomalous activity, they spot abnormalities in network traffic and create alerts based on this activity making them vital to detecting sophisticated threats. Additionally, INSM sits behind the firewall and provides detections utilizing the passive monitoring of east west and north south traffic within the enforcement boundary.

Buyers should be aware of the discrepancies between different INSMs. Some systems require constant tuning and updating, external connectivity forcing holes in segmentation or have intrusive deployments that put sensitive OT assets at risk.

What are the NERC CIP-015 requirements?

The goal of this directive is to ensure that cyber threats are identified early in the attack lifecycle by mandating implementation of security systems that detect and speed up mitigation of malicious activity.

The requirements are divided into three sections:

  • Network security monitoring
  • Data retention for anomalous activity
  • Data protection

NERC CIP-015 emphasizes the importance of having documented processes and evidence of implementation, with a focus on risk-based monitoring, anomaly detection, evaluation, retention of data, and protection against unauthorized access. Below is a breakdown of each requirement.

R1: Network Security Monitoring

The NERC CIP-015 requires the implementation of and a documented process for monitoring networks within Electronic Security Perimeters (ESPs) that contain high and medium impact BES Cyber Systems.

Key parts:

Part 1.1: Use a risk-based rationale to implement network data feeds that monitor connections, devices, and communications.

Part 1.2: Detect anomalous network activity using the data feeds.

Part 1.3: Evaluate the anomalous activity to determine necessary actions.

M1: Evidence for R1 Implementation: Documentation of processes, including risk-based rationale for data collection, detection events, configuration settings, and network baselines.

Incorporating automated solutions for network baselining is essential for effective internal monitoring, especially in diverse environments like substations and control centers. Each environment requires unique baselines—what’s typical for a substation may differ significantly from a control center, making manual monitoring impractical.

A continuous internal monitoring solution powered by artificial intelligence (AI) simplifies this challenge by instantly detecting all connected assets, dynamically learning the environment’s baseline behavior, and identifying anomalies in real-time. Unlike traditional methods, Darktrace’s AI-driven approach requires no external connectivity or repeated tuning, offering a seamless, adaptive solution for maintaining secure operations across all environments.

R2: Data Retention for Anomalous Activity

Documented processes must be in place to retain network security data related to detected anomalies until the required actions are completed.

Note: Data that does not relate to detected anomalies (Part 1.2) is not required to be retained.

M2: Evidence for Data Retention (R2): Documentation of data retention processes, system configurations, or reports showing compliance with R2.

R3: Data Protection: Implement documented processes to protect the collected security monitoring data from unauthorized deletion or modification.

M3: Evidence for Data Protection (R3): Documentation demonstrating how network security monitoring data is protected from unauthorized access or changes.

How to choose the right INSM for your organization?

Several vendors will offer INSM, but how do you choose the right solution for your organization?

Here are seven questions to help you get started evaluating potential INSM vendors:

  1. How does the solution help with ongoing compliance and reporting including CIP-015? Or any other regulations we comply with?
  2. Does the solution provide real-time monitoring of east-west traffic across critical systems? And what kind of threats has it proven capable of finding?
  3. How deep is the traffic visibility—does it offer Layer 7 (application) insights, or is it limited to Layers 3-4?
  4. Is the solution compatible with our existing infrastructure (firewalls, IDS/IPS, SIEM, OT networks)?
  5. Is this solution inline, passive, or hybrid? What impact will it have on network latency?
  6. Does the vendor have experience with electric utilities or critical infrastructure environments?
  7. Where and how are logs and monitoring data stored?

How Darktrace helps electric utilities with INSM requirements

Darktrace's ActiveAI Security Platform is uniquely designed to continuously monitor network activity and detect anomalous activity across both IT and OT environments successfully detecting insider threats and novel ransomware, while accelerating time to detection and incident reporting.

Most INSM solutions require repeated baselining, which creates more work and increases the likelihood of false positives, as even minor deviations trigger alerts. Since networks are constantly changing, baselines need to adjust in real time. Unlike these solutions, Darktrace does not depend on external connectivity or cloud access over the public internet. Our passive network analysis requires no agents or intrusive scanning, minimizing disruptions and reducing risks to OT systems.

Darktrace's AI-driven threat detection, asset management, and incident response capabilities can help organizations comply with the requirements of NERC CIP-015 for internal network security monitoring and data protection. Built specifically to deploy in OT environments, Darktrace / OT comprehensively manages, detects, evaluates, and protects network activity and anomalous events across IT and OT environments, facilitating adherence to regulatory requirements like data retention and anomaly management.

See how INSM with Darktrace can enhance your security operations, schedule a personalized demo today.

Disclaimer

The information provided in this blog is intended for informational purposes only and reflects Darktrace’s understanding of the NERC CIP-015 INSM requirements as of the publication date. While every effort has been made to ensure the accuracy and reliability of the content, Darktrace makes no warranties or representations regarding its accuracy, completeness, or applicability to specific situations. This blog does not constitute legal or compliance advice and readers are encouraged to consult with qualified professionals for guidance specific to their circumstances. Darktrace disclaims any liability for actions taken or not taken based on the information contained herein.

References

1.     https://www.nerc.com/pa/Stand/Reliability%20Standards/CIP-015-1.pdf

Inside the SOC
Darktrace cyber analysts are world-class experts in threat intelligence, threat hunting and incident response, and provide 24/7 SOC support to thousands of Darktrace customers around the globe. Inside the SOC is exclusively authored by these experts, providing analysis of cyber incidents and threat trends, based on real-world experience in the field.
Written by
Daniel Simonds
Director of Operational Technology

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Email

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July 24, 2026

Darktrace / EMAIL Expands Behavioral Defense Across Email and Collaboration Workflows

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Email and collaboration tools do more than carry messages. They are where organizations approve payments, share sensitive data, reset credentials, and make thousands of everyday decisions. Increasingly, they are interfaces through which humans direct AI agents in their daily activity. Email, Slack and Teams are high volume, rich with sensitive data, and an easy place to hide malicious activity.

The opportunity isn’t lost on bad actors. Darktrace / EMAIL detected more than 32 million high-confidence phishing emails globally in 2025, and 70% of those messages passed DMARC authentication.  Phishing is increasingly difficult to detect and familiar trust signals alone are not enough. People and security teams need to understand how a message fits the normal behavior of the sender, recipient, and organization. They also need to correlate activity across platforms to spot threats that span multiple channels.

To effectively secure against today’s evolved threats, security teams need to act at two levels: they need to help each employee make a safer decision ‘in the moment’, and they need to understand the wider patterns that may expose the business to risk.

Darktrace is introducing four new capabilities in Darktrace / EMAIL to address both challenges. The new features explain suspicious content more clearly to end users, strengthen the capabilities of Darktrace / Adaptive Human Defense with richer guidance, let organizations define their own patterns for detecting sensitive data in messages, and give security teams a process-level view of risk across email and collaboration workflows.

Darktrace / EMAIL Inbox Analysis highlights risky content within your emails

A warning is more useful when it explains what the user should look at. To help do that, we’ve expanded Darktrace / EMAIL’s Inbox Analysis Add-In to highlight potentially dangerous content within the body of emails that Darktrace / EMAIL flags as potentially suspicious or high risk.  

The add-in can highlight language designed to create urgency, financial references, requests for payment, suspicious links, and content that is unusual for the sender. Each highlighted element includes a pop up that explains why it may be suspicious. Instead of asking an employee to accept a verdict without context, the analysis helps them examine the message and make a more informed decision.

Enhanced Just-In-Time Training Banners in Darktrace / Adaptive Human Defense

Enhanced Just-In-Time Training Banners build on the same principle. The banners now include a contextual header, actionable advice, and specific detection context. This gives employees more useful guidance at the point of risk without adding unnecessary information or cognitive load.

Together, the capabilities help turn a warning into a short learning moment. Employees can see what looks unusual, understand what action to take, and build their judgment.

Custom Sensitive Data Detection in Darktrace / EMAIL - Data Loss Prevention

Sensitive data is different for every business. Standard categories such as payment card details or government identifiers matter, but organizations also have their own customer codes, project names, research formats, account structures, and internal identifiers.

Custom Sensitive Data Detection in Darktrace / EMAIL - Data Loss Prevention allows administrators to write custom expressions for the data their organization needs to protect. Matched content can trigger existing model actions and data loss prevention (DLP) workflows, extending Darktrace's DLP capabilities.

This extends data loss detection beyond a fixed library of common data types. Security teams can apply controls to information that is sensitive in the context of their own organization and adapt those controls as the business changes.

Introducing Email and Collaboration Workflow Risk Posture Dashboards

Some of the most important risks are not isolated events. They are repeated ways of working that create an opening for error, misuse, or attack. For example, a payment request may be one suspicious message, but a recurring approval workflow that relies on weak verification is a business process risk.

The new Email and Collaboration Workflow Risk Posture Dashboard analyzes email and collaboration data across Email, Microsoft Teams, Slack and Zoom to provide a process-level view of risk in the organization. These may include financial authorization workflows, sensitive data sharing patterns, and activity that could expose credentials.

The dashboard brings these patterns into a view and provides actionable recommendations. This helps security teams determine where to investigate or strengthen controls, where ownership needs to be clarified, and where the business may need to change a risky process. It gives CISOs a clearer view of how human and communication risk is embedded in everyday operations, not only where individual alerts occur.

Behavior connects the individual decision to the wider risk

These capabilities build on Darktrace’s unique behavioral approach to security. We use Adaptive AI to learn how people and AI normally behave within an organization, creating the context needed to recognize when activity changes.

Within the Darktrace Behavioral Defense Platform, Darktrace / EMAIL helps protect people against phishing, account takeover, data exfiltration, and human risk across email and collaboration tools. The new capabilities extend that protection in both directions. They give employees clearer context for the decision in front of them, while giving security leaders a broader view of the workflows and behavior that create risk across the organization.

The result is not simply more alerts. It is a better understanding of why something is risky, what action to take, and where the organization can reduce risk before a familiar process becomes an easy route for an attacker.

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About the author
Carlos Gray
Senior Product Marketing Manager, Email

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AI

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July 23, 2026

When AI Agents Go Off Script: What the OpenAI and Hugging Face Incident Means for Defenders

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The recent security incident disclosed jointly by OpenAI and Hugging Face is quickly becoming one of the most discussed AI security stories of the year; it's one that has generated great discussion amongst our researchers and technical teams here at Darktrace.

During an internal evaluation of advanced OpenAI models, an autonomous agent reportedly escaped its intended testing boundaries, obtained internet access, and compromised Hugging Face infrastructure while attempting to evaluate and benchmark the model's cyber capabilities. OpenAI has described it as an unprecedented cyber incident and is collaborating with Hugging Face to investigate and share its findings publicly to help defenders understand the implications and improve AI safety across the community.

What this means for organizations deploying AI agents

The most important takeaway for security leaders is not that the AI model is capable of complex and effective chained attacks. It's what this tells us about the guardrails and protections that need to be put in place to ensure these increasingly capable models are safely used within our businesses.

According to OpenAI's investigation, the models were not acting with malicious intent. They were attempting to achieve a legitimate assigned objective. In pursuing that objective, they identified a path that involved obtaining information from a third party's environment and followed it to completion. From the model's perspective, that appears to have been an effective solution to the problem it was given.

Many organizations still hold the assumption that giving an AI agent a legitimate goal will naturally result in legitimate behavior. Increasingly, that is not something defenders can safely assume.

A human who encounters a "permission denied" message generally understands the technical restriction as well as the social meaning behind it. An agent may interpret that message only as evidence that one method to achieve its objective has failed. What makes this incident notable is the agent’s ability to keep pursuing the objective, revise its plan, and combine many individually useful actions into an outcome its designers did not intend.

This is not an isolated challenge. Recent research from the UK's AI Security Institute found that frontier models often attempt to "cheat" evaluations by finding unintended shortcuts to success. More interestingly, that behavior is not always reflected in chain-of-thought outputs and is not always admitted when models are questioned about their actions. One lesson for defenders is that understanding what an AI system says it is doing is not always the same as understanding its behavior and what it is actually doing.

Why behavioral security is an essential security foundation

That's the principle behind Darktrace / SECURE AI and our broader approach to behavioral security. Understanding intent or putting in place static guardrails is not enough; security teams need visibility into how agents behave over time, what resources they interact with, how their behavior changes, and whether they begin pursuing objectives in unexpected ways. Research released by NIST earlier this summer reinforced that rules alone are not sufficient to defend against AI threats, with one conclusion being that "there will always be a way to prompt an AI system to disregard its rules - it's just a matter of finding it."

Another interesting lesson is that nothing described in OpenAI's preliminary findings appears fundamentally impossible for a skilled human attacker. But it does highlight the accessibility and scale that could be unlocked for attackers as increasingly capable models become more widely available. Resource constraints that attackers deal with will decrease as frontier models can help execute elements of those attack workflows autonomously, persist through failure, and iterate towards an objective. Capabilities that were once limited to skilled attackers can increasingly be supplemented with these systems, lowering the barrier to entry to conduct complex cyber operations.

It is incredibly positive to see OpenAI and Hugging Face investigating this incident collaboratively and sharing their findings publicly. Transparency and collaboration around incidents like these helps the entire security community better understand how rapidly AI capabilities are evolving and where we need to improve safeguards. It also reinforces why Darktrace is excited to be partnering with OpenAI through the Daybreak Cyber Partner Program: to explore how advanced AI can be used safely and responsibly in support of defenders while developing the visibility, governance, and security controls needed for increasingly autonomous systems.

This incident is an important reminder that capable AI systems will not always behave in the ways we expect. As organizations deploy AI agents across critical workflows, understanding behavior is an even more important foundation for effective security.

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About the author
Dr. Tim Bazalgette
Chief AI Officer, Darktrace
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