NERC has released a new Critical Infrastructure Protection (CIP) Roadmap outlining priorities for how cybersecurity expectations across the Bulk Power System may continue to evolve over the coming years.
Our friends at Ampyx Cyber have already put together a great write-up and analysis of what is included in the Roadmap. Rather than recreate the wheel, we encourage you to take a look at their overview here:
https://ampyxcyber.com/blog/nercs-cip-roadmap-and-the-future-of-grid-cybersecurity
For this post, we want to continue the conversation by focusing specifically on Low Impact assets and what the Roadmap signals about the role these systems are expected to play in future reliability and cybersecurity outcomes. While Low Impact systems have historically been treated as peripheral to core compliance programs, the Roadmap reinforces that foundational cyber hygiene across these assets is increasingly viewed as a necessary part of protecting the Bulk Power System as a whole.
From asset visibility and defensible network architectures to configuration management and monitoring, the same operational fundamentals that support higher-impact CIP requirements are now being emphasized as critical across a much broader portion of the OT environment.
One of the primary drivers behind NERC’s focus is how significantly the grid’s operational footprint has changed.
NERC notes that most operational technology deployed across the Bulk Power System now falls into Low Impact or sub-BES categories. While high- and medium-impact systems remain critical, they represent a smaller share of the total OT environment than in the past. Many of the strongest defense-in-depth protections in CIP remain concentrated around those higher-impact systems, even as operational dependence on distributed and remote assets continues to increase.
Low Impact BES Cyber Systems generally include facilities and control systems that individually would not be expected to cause wide-area reliability impacts if compromised. Sub-BES systems fall outside the formal scope of BES impact categorization altogether, but they still support essential grid functions such as local control, monitoring, and coordination with other systems.
The concern NERC highlights is not that any single Low Impact or sub-BES asset is highly consequential on its own. The concern is aggregation.
NERC points to scenarios where coordinated cyber activity across many smaller or distributed assets could produce system-level impacts, particularly as distributed energy resources, inverter-based generation, large loads, and remotely operated facilities continue to expand.
In its risk scenarios, NERC describes examples such as:
In each case, no single facility may qualify as high impact, yet together they create operational risk that extends well beyond individual sites.
NERC also highlights how widespread remote access has become across generation, substations, and control systems, often involving non-registered third parties such as OEMs and service providers. Many of these access paths remain outside enforceable minimum security baselines today, even as operational dependence on them continues to increase.
In parallel, growing reliance on public telecommunications infrastructure for SCADA and operational communications introduces additional exposure. These networks fall outside current CIP-012 protections and have increasingly become targets themselves, as demonstrated by recent nation-state campaigns against telecommunications providers.
From a risk perspective, this reflects a grid that is more distributed, more interconnected, and more externally dependent than the CIP framework was originally designed to govern.
While much of the discussion around OT cybersecurity focuses on advanced detection and monitoring, the Roadmap places clear emphasis on more basic, but often more difficult, operational realities.
NERC states:
“The strongest mitigations against nearly every major cyber risk facing the BPS stem from consistent implementation of foundational cyber hygiene controls. Effective security operations (SecOps) depend on these fundamentals. Without accurate asset inventories, defensible network topologies, and configuration management, even basic SecOps monitoring and response efforts may become unreliable and potentially operationally intrusive.”
This observation goes directly to how security programs function in real OT environments.
NERC explains that without a clear understanding of what assets exist and how they are expected to communicate, monitoring systems may generate large volumes of ambiguous alerts that are difficult to validate and triage. This increases analyst workload, raises the likelihood of overlooking subtle adversary activity, and can introduce hesitation when response actions carry operational consequences.
Security tooling alone cannot compensate for lack of environmental visibility and control.
For Low Impact and sub-BES environments in particular, NERC notes that foundational controls may be implemented inconsistently where minimum requirements are absent. This creates systemic weaknesses that adversaries can exploit as entry points for broader compromise.
Much of the residual risk in these environments arises not from deliberate risk acceptance, but from limited visibility into where outdated, vulnerable, or misconfigured technologies remain in use.
It is natural to view the Roadmap through a regulatory lens, focusing on future standards, potential requirements, and compliance timelines.
However, NERC’s framing is fundamentally about operational effectiveness.
Foundational cyber hygiene affects:
These are daily operational concerns, not abstract policy considerations.
For many Low Impact operators, especially municipals, cooperatives, and smaller generation or transmission entities, security teams are limited and operational staff often wear multiple hats. In these environments, improvements that reduce manual effort, simplify evidence collection, and provide reliable OT visibility can have an outsized impact on both security posture and audit readiness.
For many organizations, especially those operating Low Impact assets, the challenge is not a lack of intent to improve security. It is the reality that visibility, configuration control, and monitoring across distributed OT environments are difficult to maintain with limited staff and fragmented tools.
In these environments, foundational controls often degrade quietly over time. Asset inventories become outdated, configuration drift goes unnoticed, and vulnerabilities persist because they are not clearly tied to operational risk. By the time monitoring tools detect suspicious activity, teams may lack the environmental context needed to confidently assess impact or take response actions.
This is exactly why NERC emphasizes that foundational cyber hygiene is not a precursor to advanced security operations, but a requirement for them to function at all.
Improving these fundamentals does not depend on waiting for future standards. It directly improves day-to-day operational awareness, supports safer incident response, and reduces the burden of audits and assessments that already exist today.
At Industrial Defender, we have spent more than two decades working in OT environments where visibility, accuracy, and operational safety are critical.
We support organizations of all sizes and impact levels in building and maintaining the foundations NERC describes, including:
Many of the organizations we work with could be described as proactive, not because they are responding to new mandates, but because they recognize that strong foundations make every other security and compliance effort more effective.
For Low Impact operators in particular, our focus is on making these capabilities practical by reducing manual effort, accelerating security program startup, and simplifying ongoing audit preparation, all while respecting the operational constraints of industrial environments.
NERC’s CIP Roadmap reflects a grid that has become more distributed, more interconnected, and more dependent on systems that historically sat outside the strongest security baselines.
In that environment, foundational cyber hygiene determines whether monitoring, response, and future compliance efforts succeed or struggle.
While standards will continue to evolve, organizations that invest in OT foundations now will be better positioned operationally and regulatorily for what comes next.
For those looking to strengthen those foundations, we are here to help.
