Cyber Risks · Dragos Blog

NERC CIP-015-1 Is Approved—Here’s What Asset Owners Need to Do

Summary: On June 26, 2025, FERC issued Order No. 907 approving NERC CIP-015-1, which requires Internal Network Security Monitoring of east-west traffic inside Electronic Security Perimeters for High and Medium Impact Bulk Electric System Cyber Systems with External Routable Connectivity, effective October 1, 2028. FERC also directed NERC to develop modifications within one year expanding the scope to Electronic Access Control or Monitoring Systems and Physical Access Control Systems outside the ESP.

Bottom line: The enforceable deadline is October 1, 2028, and the version 2 scope FERC ordered - EACMS and PACS outside the ESP - is where an adversary posing as a trusted user could reach BES Cyber Systems inside the perimeter, a gap Responsible Entities will lack visibility into until it is closed.

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Topics
OT / ICS & Critical Infrastructure
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