Embracing Security: Navigating CIP-003-9 Implementation

By Sean Thompson, NERC Supervisor

The digital age has intensified the need for robust cybersecurity measures across all sectors, particularly within the Bulk Electric System (BES). The North American Electric Reliability Corporation (NERC) has responded to this growing challenge with CIP-003-9, set to take effect on April 1, 2026. This regulation marks a significant shift towards enhanced security protocols, particularly focusing on vendor electronic remote access and its impact on low impact BES Cyber Systems.

Key Provisions of CIP-003-9

At the core of CIP-003-9 is Section 6, which mandates specific security controls for vendor electronic remote access. Applicable entities must implement strategies for identifying, disabling, and monitoring vendor access. This comprehensive approach is designed to mitigate the risk of unauthorized access and ensure a secure cyber environment. NERC also emphasizes the necessity for entities to review their existing security controls and align them with the new requirements, fostering a more resilient infrastructure.

Strategic Recommendations for Compliance

The implementation process requires entities to assess their current systems and procedures. A critical step involves evaluating existing remote access controls and determining their compliance with Section 6. This may require the development of new processes or the enhancement of existing ones, such as firewall connectivity rules or identity and Access Management systems. Additionally, the integration of Multi-Factor Authentication (MFA) for vendor authentication has been highlighted as a key security measure.

NERC has  also advised entities to establish clear communication channels with vendors, outlining the requirements and duration of remote access. This collaborative approach will not only streamline the compliance process but also strengthen the overall security posture.

Implications and Actionable Insights

The impending implementation of CIP-003-9 signals a significant evolution in the landscape of cybersecurity for the BES sector. Entities must embark on a thorough review of their cyber defenses, prioritizing the development of a comprehensive risk management strategy. This includes conducting security assessments, enhancing technological capabilities, and fostering a culture of continuous improvement.

In light of the interconnected nature of modern cyber systems, the emphasis on vendor access control underlines the critical role of third-party risk management. By adopting a proactive and collaborative approach, entities can safeguard their systems against potential cyber threats, thereby contributing to the overall reliability and security of the BES.


The introduction of CIP-003-9 is a proactive step towards fortifying the cyber defenses of the Bulk Electric System. As entities gear up for its implementation, the focus must be on comprehensive preparation, strategic planning, and the adoption of advanced security measures. By embracing these changes, the BES sector can navigate the complexities of the digital landscape and ensure a secure and resilient energy infrastructure for the future.  For assistance with all of your NERC Compliance needs, including CIP-003-9 contact reliability@naes.com.