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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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Proactive Security

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January 7, 2026

How a leading bank is prioritizing risk management to power a resilient future

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As one of the region’s most established financial institutions, this bank sits at the heart of its community’s economic life – powering everything from daily transactions to business growth and long-term wealth planning. Its blend of physical branches and advanced digital services gives customers the convenience they expect and the personal trust they rely on. But as the financial world becomes more interconnected and adversaries more sophisticated, safeguarding that trust requires more than traditional cybersecurity. It demands a resilient, forward-leaning approach that keeps pace with rising threats and tightening regulatory standards.

A complex risk landscape demands a new approach

The bank faced a challenge familiar across the financial sector: too many tools, not enough clarity. Vulnerability scans, pen tests, and risk reports all produced data, yet none worked together to show how exposures connected across systems or what they meant for day-to-day operations. Without a central platform to link and contextualize this data, teams struggled to see how individual findings translated into real exposure across the business.

  • Fragmented risk assessments: Cyber and operational risks were evaluated in silos, often duplicated across teams, and lacked the context needed to prioritize what truly mattered.
  • Limited executive visibility: Leadership struggled to gain a complete, real-time view of trends or progress, making risk ownership difficult to enforce.
  • Emerging compliance pressure: This gap also posed compliance challenges under the EU’s Digital Operational Resilience Act (DORA), which requires financial institutions to demonstrate continuous oversight, effective reporting, and the ability to withstand and recover from cyber and IT disruptions.
“The issue wasn’t the lack of data,” recalls the bank’s Chief Technology Officer. “The challenge was transforming that data into a unified, contextualized picture we could act on quickly and decisively.”

As the bank advanced its digital capabilities and embraced cloud services, its risk environment became more intricate. New pathways for exploitation emerged, human factors grew harder to quantify, and manual processes hindered timely decision-making. To maintain resilience, the security team sought a proactive, AI-powered platform that could consolidate exposures, deliver continuous insight, and ensure high-value risks were addressed before they escalated.

Choosing Darktrace to unlock proactive cyber resilience

To reclaim control over its fragmented risk landscape, the bank selected Darktrace / Proactive Exposure Management™ for cyber risk insight. The solution’s ability to consolidate scanner outputs, pen test results, CVE data, and operational context into one AI-powered view made it the clear choice. Darktrace delivered comprehensive visibility the team had long been missing.

By shifting from a reactive model to proactive security, the bank aimed to:

  • Improve resilience and compliance with DORA
  • Prioritize remediation efforts with greater accuracy
  • Eliminate duplicated work across teams
  • Provide leadership with a complete view of risk, updated continuously
  • Reduce the overall likelihood of attack or disruption

The CTO explains: “We needed a solution that didn’t just list vulnerabilities but showed us what mattered most for our business – how risks connected, how they could be exploited, and what actions would create the biggest reduction in exposure. Darktrace gave us that clarity.”

Targeting the risks that matter most

Darktrace / Proactive Exposure Management offered the bank a new level of visibility and control by continuously analyzing misconfigurations, critical attack paths, human communication patterns, and high-value assets. Its AI-driven risk scoring allowed the team to understand which vulnerabilities had meaningful business impact, not just which were technically severe.

Unifying exposure across architectures

Darktrace aggregates and contextualizes data from across the bank’s security stack, eliminating the need to manually compile or correlate findings. What once required hours of cross-team coordination now appears in a single, continuously updated dashboard.

Revealing an adversarial view of risk

The solution maps multi-stage, complex attack paths across network, cloud, identity systems, email environments, and endpoints – highlighting risks that traditional CVE lists overlook.

Identifying misconfigurations and controlling gaps

Using Self-Learning AI, Darktrace / Proactive Exposure Management spots misconfigurations and prioritizes them based on MITRE adversary techniques, business context, and the bank’s unique digital environment.

Enhancing red-team and pen test effectiveness

By directing testers to the highest-value targets, Darktrace removes guesswork and validates whether defenses hold up against realistic adversarial behavior.

Supporting DORA compliance

From continuous monitoring to executive-ready reporting, the solution provides the transparency and accountability the bank needs to demonstrate operational resilience frameworks.

Proactive security delivers tangible outcomes

Since deploying Darktrace / Proactive Exposure Management, the bank has significantly strengthened its cybersecurity posture while improving operational efficiency.

Greater insight, smarter prioritization, stronger defensee

Security teams are now saving more than four hours per week previously spent aggregating and analyzing risk data. With a unified view of their exposure, they can focus directly on remediation instead of manually correlating multiple reports.

Because risks are now prioritized based on business impact and real-time operational context, they no longer waste time on low-value tasks. Instead, critical issues are identified and resolved sooner, reducing potential windows for exploitation and strengthening the bank’s ongoing resilience against both known and emerging threats.

“Our goal was to move from reactive to proactive security,” the CTO says. “Darktrace didn’t just help us achieve that, it accelerated our roadmap. We now understand our environment with a level of clarity we simply didn’t have before.”

Leadership clarity and stronger governance

Executives and board stakeholders now receive clear, organization-wide visibility into the bank’s risk posture, supported by consistent reporting that highlights trends, progress, and areas requiring attention. This transparency has strengthened confidence in the bank’s cyber resilience and enabled leadership to take true ownership of risk across the institution.

Beyond improved visibility, the bank has also deepened its overall governance maturity. Continuous monitoring and structured oversight allow leaders to make faster, more informed decisions that strategically align security efforts with business priorities. With a more predictable understanding of exposure and risk movement over time, the organization can maintain operational continuity, demonstrate accountability, and adapt more effectively as regulatory expectations evolve.

Trading stress for control

With Darktrace, leaders now have the clarity and confidence they need to report to executives and regulators with accuracy. The ability to see organization-wide risk in context provides assurance that the right issues are being addressed at the right time. That clarity is also empowering security analysts who no longer shoulder the anxiety of wondering which risks matter most or whether something critical has slipped through the cracks. Instead, they’re working with focus and intention, redirecting hours of manual effort into strategic initiatives that strengthen the bank’s overall resilience.

Prioritizing risk to power a resilient future

For this leading financial institution, Darktrace / Proactive Exposure Management has become the foundation for a more unified, data-driven, and resilient cybersecurity program. With clearer, business-relevant priorities, stronger oversight, and measurable efficiency gains, the bank has strengthened its resilience and met demanding regulatory expectations without adding operational strain.

Most importantly, it shifted the bank’s security posture from a reactive stance to a proactive, continuous program. Giving teams the confidence and intelligence to anticipate threats and safeguard the people and services that depend on them.

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About the author
Kelland Goodin
Product Marketing Specialist

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AI

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January 5, 2026

How to Secure AI in the Enterprise: A Practical Framework for Models, Data, and Agents

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Introduction: Why securing AI is now a security priority

AI adoption is at the forefront of the digital movement in businesses, outpacing the rate at which IT and security professionals can set up governance models and security parameters. Adopting Generative AI chatbots, autonomous agents, and AI-enabled SaaS tools promises efficiency and speed but also introduces new forms of risk that traditional security controls were never designed to manage. For many organizations, the first challenge is not whether AI should be secured, but what “securing AI” actually means in practice. Is it about protecting models? Governing data? Monitoring outputs? Or controlling how AI agents behave once deployed?  

While demand for adoption increases, securing AI use in the enterprise is still an abstract concept to many and operationalizing its use goes far beyond just having visibility. Practitioners need to also consider how AI is sourced, built, deployed, used, and governed across the enterprise.

The goal for security teams: Implement a clear, lifecycle-based AI security framework. This blog will demonstrate the variety of AI use cases that should be considered when developing this framework and how to frame this conversation to non-technical audiences.  

What does “securing AI” actually mean?

Securing AI is often framed as an extension of existing security disciplines. In practice, this assumption can cause confusion.

Traditional security functions are built around relatively stable boundaries. Application security focuses on code and logic. Cloud security governs infrastructure and identity. Data security protects sensitive information at rest and in motion. Identity security controls who can access systems and services. Each function has clear ownership, established tooling, and well-understood failure modes.

AI does not fit neatly into any of these categories. An AI system is simultaneously:

  • An application that executes logic
  • A data processor that ingests and generates sensitive information
  • A decision-making layer that influences or automates actions
  • A dynamic system that changes behavior over time

As a result, the security risks introduced by AI cuts across multiple domains at once. A single AI interaction can involve identity misuse, data exposure, application logic abuse, and supply chain risk all within the same workflow. This is where the traditional lines between security functions begin to blur.

For example, a malicious prompt submitted by an authorized user is not a classic identity breach, yet it can trigger data leakage or unauthorized actions. An AI agent calling an external service may appear as legitimate application behavior, even as it violates data sovereignty or compliance requirements. AI-generated code may pass standard development checks while introducing subtle vulnerabilities or compromised dependencies.

In each case, no single security team “owns” the risk outright.

This is why securing AI cannot be reduced to model safety, governance policies, or perimeter controls alone. It requires a shared security lens that spans development, operations, data handling, and user interaction. Securing AI means understanding not just whether systems are accessed securely, but whether they are being used, trained, and allowed to act in ways that align with business intent and risk tolerance.

At its core, securing AI is about restoring clarity in environments where accountability can quickly blur. It is about knowing where AI exists, how it behaves, what it is allowed to do, and how its decisions affect the wider enterprise. Without this clarity, AI becomes a force multiplier for both productivity and risk.

The five categories of AI risk in the enterprise

A practical way to approach AI security is to organize risk around how AI is used and where it operates. The framework below defines five categories of AI risk, each aligned to a distinct layer of the enterprise AI ecosystem  

How to Secure AI in the Enterprise:

  • Defending against misuse and emergent behaviors
  • Monitoring and controlling AI in operation
  • Protecting AI development and infrastructure
  • Securing the AI supply chain
  • Strengthening readiness and oversight

Together, these categories provide a structured lens for understanding how AI risk manifests and where security teams should focus their efforts.

1. Defending against misuse and emergent AI behaviors

Generative AI systems and agents can be manipulated in ways that bypass traditional controls. Even when access is authorized, AI can be misused, repurposed, or influenced through carefully crafted prompts and interactions.

Key risks include:

  • Malicious prompt injection designed to coerce unwanted actions
  • Unauthorized or unintended use cases that bypass guardrails
  • Exposure of sensitive data through prompt histories
  • Hallucinated or malicious outputs that influence human behavior

Unlike traditional applications, AI systems can produce harmful outcomes without being explicitly compromised. Securing this layer requires monitoring intent, not just access. Security teams need visibility into how AI systems are being prompted, how outputs are consumed, and whether usage aligns with approved business purposes

2. Monitoring and controlling AI in operation

Once deployed, AI agents operate at machine speed and scale. They can initiate actions, exchange data, and interact with other systems with little human oversight. This makes runtime visibility critical.

Operational AI risks include:

  • Agents using permissions in unintended ways
  • Uncontrolled outbound connections to external services or agents
  • Loss of forensic visibility into ephemeral AI components
  • Non-compliant data transmission across jurisdictions

Securing AI in operation requires real-time monitoring of agent behavior, centralized control points such as AI gateways, and the ability to capture agent state for investigation. Without these capabilities, security teams may be blind to how AI systems behave once live, particularly in cloud-native or regulated environments.

3. Protecting AI development and infrastructure

Many AI risks are introduced long before deployment. Development pipelines, infrastructure configurations, and architectural decisions all influence the security posture of AI systems.

Common risks include:

  • Misconfigured permissions and guardrails
  • Insecure or overly complex agent architectures
  • Infrastructure-as-Code introducing silent misconfigurations
  • Vulnerabilities in AI-generated code and dependencies

AI-generated code adds a new dimension of risk, as hallucinated packages or insecure logic may be harder to detect and debug than human-written code. Securing AI development means applying security controls early, including static analysis, architectural review, and continuous configuration monitoring throughout the build process.

4. Securing the AI supply chain

AI supply chains are often opaque. Models, datasets, dependencies, and services may come from third parties with varying levels of transparency and assurance.

Key supply chain risks include:

  • Shadow AI tools used outside approved controls
  • External AI agents granted internal access
  • Suppliers applying AI to enterprise data without disclosure
  • Compromised models, training data, or dependencies

Securing the AI supply chain requires discovering where AI is used, validating the provenance and licensing of models and data, and assessing how suppliers process and protect enterprise information. Without this visibility, organizations risk data leakage, regulatory exposure, and downstream compromise through trusted integrations.

5. Strengthening readiness and oversight

Even with strong technical controls, AI security fails without governance, testing, and trained teams. AI introduces new incident scenarios that many security teams are not yet prepared to handle.

Oversight risks include:

  • Lack of meaningful AI risk reporting
  • Untested AI systems in production
  • Security teams untrained in AI-specific threats

Organizations need AI-aware reporting, red and purple team exercises that include AI systems, and ongoing training to build operational readiness. These capabilities ensure AI risks are understood, tested, and continuously improved, rather than discovered during a live incident.

Reframing AI security for the boardroom

AI security is not just a technical issue. It is a trust, accountability, and resilience issue. Boards want assurance that AI-driven decisions are reliable, explainable, and protected from tampering.

Effective communication with leadership focuses on:

  • Trust: confidence in data integrity, model behavior, and outputs
  • Accountability: clear ownership across teams and suppliers
  • Resilience: the ability to operate, audit, and adapt under attack or regulation

Mapping AI security efforts to recognized frameworks such as ISO/IEC 42001 and the NIST AI Risk Management Framework helps demonstrate maturity and aligns AI security with broader governance objectives.

Conclusion: Securing AI is a lifecycle challenge

The same characteristics that make AI transformative also make it difficult to secure. AI systems blur traditional boundaries between software, users, and decision-making, expanding the attack surface in subtle but significant ways.

Securing AI requires restoring clarity. Knowing where AI exists, how it behaves, who controls it, and how it is governed. A framework-based approach allows organizations to innovate with AI while maintaining trust, accountability, and control.

The journey to secure AI is ongoing, but it begins with understanding the risks across the full AI lifecycle and building security practices that evolve alongside the technology.

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About the author
Brittany Woodsmall
Product Marketing Manager, AI
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