Regulatory Landscape

Energy utilities face a complex web of cybersecurity regulations and compliance requirements. ISO 27019 helps organizations meet these obligations while maintaining operational security.

Global Regulatory Framework

Critical Infrastructure Designation

Most countries classify energy systems as critical infrastructure, triggering special requirements:

• Enhanced cybersecurity obligations
• Mandatory incident reporting
• Government oversight and audits
• Information sharing requirements
• Potential for classified threat briefings

Major Regulatory Regimes

North America

NERC CIP (Reliability Standards)

North American Electric Reliability Corporation Critical Infrastructure Protection

• Mandatory for bulk electric system operators
• 13 standards covering security management
• Violation penalties up to $1 million per day
• Three-year audit cycle
• Key Standards: CIP-002 (critical assets), CIP-005 (perimeters), CIP-007 (systems security)

TSA Security Directives (Pipelines)

For oil and gas pipelines after Colonial Pipeline attack:

• Cybersecurity coordinator designation
• Incident reporting within 12 hours
• Cybersecurity assessment and remediation
• Architecture reviews and segmentation

European Union

NIS2 Directive

Network and Information Security Directive (Updated 2023):

• Applies to essential and important entities
• Risk management and incident handling
• Supply chain security requirements
• Management accountability (personal liability)
• Harmonized enforcement across EU

Electricity Regulation (EU) 2019/943

Security of electricity supply requirements:

• Cybersecurity risk preparedness plans
• Member state coordination
• Cross-border incident management

United Kingdom

Electricity and Gas Regulations

Post-Brexit cybersecurity framework:

• Security and resilience requirements
• National Cyber Security Centre (NCSC) guidance
• Incident reporting to Department for Energy Security
• CAF (Cyber Assessment Framework) compliance

Asia-Pacific

Australia - SOCI Act

Security of Critical Infrastructure Act:

• Enhanced cyber obligations for energy assets
• Risk management programs required
• Government assistance in incidents
• Mandatory reporting of cyber incidents

Singapore - CII Programme

Critical Information Infrastructure protection:

• Cybersecurity code of practice
• Audits every 2 years
• Penetration testing requirements
• Incident response exercises

Industry Standards and Frameworks

IEC 62351

Power system communication security standard:

• Authentication for IEC protocols
• Encryption specifications
• Access control mechanisms
• Complements ISO 27019

IEEE 1686

Intelligent Electronic Device (IED) security:

• Security features for substation devices
• Role-based access control
• Audit logging requirements

NIST Cybersecurity Framework

Widely adopted voluntary framework:

• Identify, Protect, Detect, Respond, Recover
• Used by many utilities globally
• Maps well to ISO 27019 controls

Compliance Challenges

Multiple Overlapping Requirements

Energy companies often face:

• International operations with different regulations per country
• Federal/national plus regional/state requirements
• Sector-specific plus general data protection laws
• Voluntary standards becoming de facto requirements

Documentation Burden

Meeting all requirements demands extensive documentation:

• Policies and procedures for each control
• Evidence of implementation
• Training records
• Audit trails and logs
• Incident reports and lessons learned

Demonstration of Compliance

Proving compliance requires:

• Regular self-assessments
• Third-party audits
• Continuous monitoring
• Documentation of exceptions and compensating controls

ISO 27019 as a Compliance Framework

Benefits for Regulatory Compliance

ISO 27019 helps meet multiple requirements simultaneously:

• Comprehensive coverage: Addresses most regulatory requirements
• Risk-based approach: Demonstrates due diligence
• Internationally recognized: Credible with global regulators
• Flexible implementation: Adapts to specific regulatory context

Mapping to Regulations

ISO 27019 controls map to most requirements:

• Access control → NERC CIP-004, CIP-005
• Incident management → NIS2 incident reporting
• Risk assessment → Required by most frameworks
• Supply chain → NIS2, TSA directives

Data Privacy Regulations

Energy companies also handle personal data:

Smart Meter Data

Highly sensitive consumption patterns:

• GDPR (EU): Strict consent and processing rules
• CCPA (California): Consumer data rights
• PIPEDA (Canada): Consent requirements
• APPs (Australia): Privacy principles

Employee and Customer Data

General data protection applies:

• Customer billing information
• Employee background checks
• Vendor personnel data
• Must comply with local privacy laws

Emerging Regulatory Trends

Supply Chain Requirements

Increasing focus on third-party risks:

• Vendor security assessments
• Software bill of materials (SBOM)
• Hardware provenance verification
• Managed service provider oversight

Operational Technology Specific

Regulations increasingly distinguishing OT:

• Separate OT security requirements
• Recognition of operational constraints
• Adapted compliance timelines for OT

Incident Disclosure

More jurisdictions requiring public disclosure:

• Material cyber incidents to customers
• SEC disclosure requirements (US public companies)
• Shareholder notification obligations

Next Lesson: Understanding the threat actors and attack vectors targeting energy infrastructure.