Cyber Risks · Dragos Blog

NERC CIP-015-2: EACMS, PACS, SCI Monitoring Explained

Summary: FERC proposed in June 2025 to approve NERC CIP-015-1 while directing NERC to extend internal network security monitoring to electronic access control or monitoring systems (EACMS) and physical access control systems (PACS) outside the Electronic Security Perimeter. The NERC Project 2025-02 drafting team's initial ballot for CIP-015-2, which adds Cyber Systems to the requirement language and Shared Cyber Infrastructure (SCI) to the applicability column, passed at 84.33% on January 20, 2026.

What's compelling: EACMS, PACS, and SCI sit outside the ESP with the visibility, authority, and connectivity adversaries need to plan and disguise lateral movement into BES Cyber Systems - and FERC's position is that you cannot secure the ESP while blind to activity in the systems that connect to it.

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Topics
OT / ICS & Critical Infrastructure
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