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Monitoring for PCI DSS 4.0 Compliance

Any company that processes payments knows the pain of an audit under the Payment Card Industry Data Security Standard (PCI DSS). Although the original PCI DSS had gone through various updates, the Payment Card Industry Security Standards Council (PCI SSC) took feedback from the global payments industry to address evolving security needs. The March 2022 release of PCI DSS 4.0 incorporated changes that intend to promote security as an iterative process while ensuring continued flexibility so that organizations could achieve security objectives based on their needs.

 

To give companies time to address new requirements, audits will begin incorporating the majority of the new changes beginning March 31, 2025. However, some issues will be included in audits beginning immediately.

 

Why did the Payment Card Industry Security Standards Council (PCI SSC) update the standard?

At a high level, PCI DSS 4.0 responds to changes in IT infrastructures arising from digital transformation and Software-as-a-Service (SaaS) applications. According to PCI SSC’s press release, changes will enhance validation methods and procedures.

 

When considering PCI DSS 4.0 scope, organizations need to implement controls around the following types of account data:

  • Cardholder Data: Primary Account Number (PAN), Cardholder Name, Expiration Date, Service Code
  • Sensitive Authentication Data (SAD): Full track data (magnetic stripe or chip equivalent), card verification code, Personal Identification Numbers (PINs)/PIN blocks.

 

To get a sense of how the PCI SSC shifted focus when drafting PCI DSS 4.0, you can take a look at how the organization renamed some of the Requirements:

 

 

PCI CategoriesPCI 3.2.1PCI 4.0
Build and Maintain a Secure Network and Systems
  1. Install and maintain a firewall configuration to protect cardholder data
  2. Do not use vendor-supplied defaults for system passwords and other security parameters.
  1. Install and maintain network security controls
  2. Apply secure configurations to all system components

Protect Cardholder Data

(Updated to Protect Account Data in 4.0)

  1. Protect stored cardholder data
  2. Encrypt transmission of cardholder data across open, public networks

3. Protect stored account data

 

4. Protect cardholder data with strong cryptography during transmission over open, public networks

 

Maintain a Vulnerability Management Program
  1. Protect all systems against malware and regularly update anti-virus software or programs
  2. Develop and maintain secure systems and applications

5. Protect all systems and networks from malicious software

6. Develop and maintain secure systems and software

Implement Strong Access Control Measures
  1. Restrict access to cardholder data by business need to know
  2. Identify and authenticate access to system components
  3. Restrict physical access to cardholder data

7. Restrict access to system components and cardholder data by business need to know

8. Identify users and authenticate access to system components

9. Restrict physical access to cardholder data

Regularly Monitor and Test Networks
  1. Track and monitor all access to network resources and cardholder data
  2. Regularly test security systems and processes

10. Log and monitor all access to system components and cardholder data

11. Test security of systems and networks regularly

Maintain an Information Security Policy
  1. Maintain a policy that addresses information security for all personnel
12. Support information security with organizational policies and programs

 

While PCI SSC expanded the requirements to address larger security and privacy issues, many of them remain fundamentally the same as before. According to the Summary of Changes, most updates fall into one of the following categories:

  • Evolving requirement: changes that align with emerging threats and technologies or changes in the industry
  • Clarification or guidance: updated wording, explanation, definition, additional guidance, and/or instruction to improve people’s understanding
  • Structure or format: content reorganization, like combining, separating, or renumbering requirements

 

For organizations that have previously met PCI DSS compliance objectives, those changes place little additional burden.

 

However, PCI DSS 4.0 does include changes to Requirements that organizations should consider.

 

What new Requirements are immediately in effect for all entities?

While additions are effective beginning March 31, 2025, three primary issues affect current PCI audits.

 

Holistically, PCI DSS now includes the following sub requirement across Requirements 2 through 11:

Roles and responsibilities for performing activities for Requirement are documented, assigned, and understood.

 

Additionally, under Requirement 12, all entities should be:

  • Performing a targeted risk analysis for each PCI DSS requirement according to the documented, customized approach
  • Documenting and confirming PCI DSS scope every 12 months

 

What updates are effective March 31, 2025 for all entities?

As the effective date for all requirements draws closer, organizations should consider the major changes that impact their business, security, and privacy operations.

 

Requirement 3

PCI DSS 4.0 incorporates the following new requirements:

  • Minimizing the SAD stored prior to completion and retaining it according to data retention and disposal policies, procedures and processes
  • Encrypting all SAD stored electronically
  • Implementing technical controls to prevent copying/relocating PAN when using remote-access technologies unless requiring explicit authorization
  • Rendering PAN unreadable with keyed cryptographic hashes unless requiring explicit authorization
  • Implementing disk-level or partition-level encryption to make PAN unreadable

 

Requirement 4

PCI DSS 4.0 incorporates the following new requirements:

  • Confirming that certificates safeguarding PAN during transmission across open, public networks are valid, not expired or revoked
  • Maintaining an inventory of trusted keys and certificates

 

Requirement 5

PCI DSS 4.0 incorporates the following new requirements:

  • Performing a targeted risk analysis to determine how often the organization evaluates whether system components pose a malware risk
  • Performing targeted risk analysis to determine how often to scan for malware
  • Performing anti-malware scans when using removable electronic media
  • Implementing phishing attack detection and protection mechanisms

 

Requirement 6

PCI DSS 4.0 incorporates the following new requirements:

  • Maintaining an inventory of bespoke and custom software for vulnerability and patch management purposes
  • Deploying automated technologies for public-facing web applications to continuously detect and prevent web-based attacks
  • Managing payment page scripts loaded and executed in consumers’ browsers

 

Requirement 7

PCI DSS 4.0 incorporates the following new requirements:

  • Reviewing all user accounts and related access privileges
  • Assigning and managing all application and system accounts and related access privileges
  • Reviewing all application and system accounts and their access privileges

 

Requirement 8

PCI DSS 4.0 incorporates the following new requirements:

  • Implementing a minimum complexity level for passwords used as an authentication factor
  • Implementing multi-factor authentication (MFA) for all CDE access
  • Ensuring MFA implemented appropriately
  • Managing interactive login for system or application accounts
  • Using passwords/passphrases for application and system accounts
  • Protecting passwords/passphrases for application and system accounts against misuse

 

Requirement 9

PCI DSS 4.0 incorporates the following new requirements:

  • Performing targeted risk analysis to determine how often POI devices should be inspected

 

Requirement 10

PCI DSS 4.0 incorporates the following new requirements:

  • Automating the review of audit logs
  • Performing a targeted risk analysis to determine how often to review system and component logs
  • Detecting, receiving alerts for, and addressing critical security control system failures
  • Promptly responding to critical security control system failures

 

Requirement 11

PCI DSS 4.0 incorporates the following new requirements:

  • Managing vulnerabilities not ranked as high-risk or critical
  • Performing internal vulnerability scans using authenticated scanning
  • Deploying a change-and-tamper-detection mechanism for payment pages

 

Requirement 12

PCI DSS 4.0 incorporates the following new requirements:

  • Documenting the targeted risk analysis that identifies how often to perform it so it supports each PCI DSS Requirement
  • Documenting and reviewing cryptographic cypher suites and protocols
  • Reviewing hardware and software
  • Reviewing security awareness program at least once every 12 months and updating as necessary
  • Including in training threats to CD, like phishing and related attacks and social engineering
  • Including acceptable technology use in training
  • Performing targeted risk analysis to determine how often to provide training
  • Including in incident response plan the alerts from change-and-tamper detection mechanism for payment pages
  • Implementing incident response procedures and initiating them upon PAN detection

 

What updates are applicable to service providers only?

In some cases, new Requirements apply only to issuers and companies supporting those issuing services and storing sensitive authentication data. Only one of these immediately went into effect, the update to Requirement 12:

  • TPSPs support customers’ requests for PCI DSS compliance status and information about the requirements for which they are responsible

 

Effective March 31, 2025

Service providers should be aware of the following updates:

 

  • Requirement 3:
    • Encrypting SAD
    • Documenting the cryptographic architecture that prevents people from using cryptographic keys in production and test environments
  • Requirement 8
    • Requiring customers to change passwords at least every 90 days or dynamically assessing security posture when not using additional authentication factors
  • Requirement 11
    • Multi-tenant service providers supporting customers for external penetration testing
    • Detecting, receiving alerts for, preventing, and addressing covert malware communication channels using intrusion detection and/or intrusion prevention techniques
  • Requirement 12
    • Documenting and confirming PCI DSS scope every 6 months or upon significant changes
    • Documenting, reviewing, and communicating to executive management the impact that significant organizational changes have on PCI DSS scope

 

Graylog Security and API Security: Monitoring, Detection, and Incident Response for PCI DSS 4.0

 

Graylog Security provides the SIEM capabilities organizations need to implement Threat Detection and Incident Response (TDIR) activities and compliance reporting. Graylog Security’s security analytics and anomaly detection functionalities enable you to aggregate, normalize, correlate, and analyze activities across a complex environment for visibility into and high-fidelity alerts for critical security monitoring and compliance issues like:

 

By incorporating Graylog API Security into your PCI DSS monitoring and incident response planning, you enhance your security and compliance program by mitigating risks and detecting incidents associated with Application Programming Interfaces (APIs). With Graylog’s end-to-end API threat monitoring, detection, and response solution, you can augment the outside-in monitoring from Web Application Firewalls (WAF) and API gateways with API discovery, request and response capture, automated risk assessment, and actionable remediation activities.

 

 

About Graylog  
At Graylog, our vision is a secure digital world where organizations of all sizes can effectively guard against cyber threats. We’re committed to turning this vision into reality by providing Threat Detection & Response that sets the standard for excellence. Our cloud-native architecture delivers SIEM, API Security, and Enterprise Log Management solutions that are not just efficient and effective—whether hosted by us, on-premises, or in your cloud—but also deliver a fantastic Analyst Experience at the lowest total cost of ownership. We aim to equip security analysts with the best tools for the job, empowering every organization to stand resilient in the ever-evolving cybersecurity landscape.

About Version 2 Digital

Version 2 Digital is one of the most dynamic IT companies in Asia. The company distributes a wide range of IT products across various areas including cyber security, cloud, data protection, end points, infrastructures, system monitoring, storage, networking, business productivity and communication products.

Through an extensive network of channels, point of sales, resellers, and partnership companies, Version 2 offers quality products and services which are highly acclaimed in the market. Its customers cover a wide spectrum which include Global 1000 enterprises, regional listed companies, different vertical industries, public utilities, Government, a vast number of successful SMEs, and consumers in various Asian cities.

How I used Graylog to Fix my Internet Connection

In today’s digital age, the internet has become an integral part of our daily lives. From working remotely to streaming movies, we rely on the internet for almost everything. However, slow internet speeds can be frustrating and can significantly affect our productivity and entertainment. Despite advancements in technology, many people continue to face challenges with their internet speeds, hindering their ability to fully utilize the benefits of the internet. In this blog, we will explore how Dan McDowell, Professional Services Engineer decided to take matters into his own hands and get the data over time to present to his ISP.

Speedtest-Overview

 

Over the course of a few months, I noticed slower and slower internet connectivity. Complaints from neighbors (we are all on the same ISP) lead me to take some action. A few phone calls with “mixed” results were not good enough for me so I knew what I needed, metrics!

Why Metrics?

Showing data without a doubt is one of the most powerful ways to prove a statement. How often do you hear one of the following when you call in for support:

  • Did you unplug it and plug it back in?
  • It’s probably an issue with your router
  • Oh, wireless must be to blame
  • Test it directly connected to your computer!
  • Nothing is wrong on our end, must be yours…

In my scenario I was able to prove without a doubt that this wasn’t a “me” problem. Using data I gathered by running this script every 30 minutes over a few weeks time I was able to prove:

  • This wasn’t an issue with my router
    • The was consistent connectivity slowness at the same times every single day of the week and outside of those times my connectivity was near the offered maximums.
  • Something was wrong on their end
    • Clearly, they were not spec’d to handle the increase in traffic when people stop working and start streaming
    • I used their OWN speed test server for all my testing. It was only one hop away.
    • This was all the proof I needed:
  • End Result?
    • I sent in a few screenshots of my dashboards, highlighting the clear spikes during peak usage periods. I received a phone call not even 10 minutes later from the ISP. They replaced our local OLT and increased the pipe to their co-lo.
      What a massive increase in average performance!

Ookla Speedtest has a CLI tool?!

Yup. This can be configured to use the same speedtest server (my local ISP runs one) each run meaning results are valid and repeatable. Best of all, it can output JSON which I can convert to GELF with ease! In short, I setup a cron job to run my speed test script every 30 minutes on my Graylog server and output the results, converting the JSON message into GELF which NetCat sends to my GELF input.

PORT 8080 must be open outbound!

How can I even?

Prerequisites

1. Install netcat, speedtest and gron.

Debain/Ubuntu

2. curl -s https://packagecloud.io/install/repositories/ookla/speedtest-cli/script.deb.sh | sudo bash
sudo apt install speedtest gron ncat

RHEL/CentOS/Rocky/Apline

wget https://download-ib01.fedoraproject.org/pub/fedora/linux/releases/37/Everything/x86_64/os/Packages/g/gron-0.7.1-4.fc37.x86_64.rpm

sudo dnf install gron-0.7.1-4.fc37.x86_64.rpm curl -s https://packagecloud.io/install/repositories/ookla/speedtest-cli/script.rpm.sh | sudo bash

sudo dnf install speedtest netcat

 

3. You also need a functional Graylog instance with a GELF input running.

4. My speedtest script and Graylog content pack (contains dashboard, route rule and a stream)

  1. Grab the script
    wget https://raw.githubusercontent.com/graylog-labs/graylog-playground/main/Speed%20Test/speedtest.sh
  1. Move the script to a common location and make it executable
    mkdir /scripts
    mv speedtest.sh /scripts/
    chmod +x /scripts/speedtest.sh

Getting Started

  1. Login to your Graylog instance
  2. Navigate to System → Content Packs
  3. Click upload.
  4. Browse to the downloaded location of the Graylog content pack and upload it to your instance
  5. Install the content pack
  6. This will install a Stream, pipeline, pipeline rule (routing to stream) and dashboard
  7. Test out the script!
    1. ssh / console to your linux system hosting Graylog/docker
    2. Manually execute the script:
      /scripts/speedtest.sh localhost 12201
      Script Details: <path to script> <ip/dns/hostname> <port>
  1. Check out the data in your Graylog
    1. Navigate to Streams → Speed Tests
    2. Useful data appears!
    3. Navigate to Dashboards → ISP Speed Test
      1. Check out the data!
  2. Manually execute the script as much as you like. More data will appear the more you run it.

Automate the Script!

This is how I got the data to convince my ISP that something was actually wrong. Setup a CRON job that runs every 30 minutes and within a few day you should see some time related changes.

  1. ssh or console to your linux system hosting the script / Graylog
  2. Create a CRONTAB to run the script every 30 minutes
    1. create crontab (this will be for the currently logged in user OR root if sudo su was used)

crontab -e

    1. Set the script to run every 30 minutes (change as you like)

*/30 * * * * /scripts/speedtest.sh localhost 12201

  1. That’s it! As long as the user the crontab was made for has permissions, the script will run every 30 minutes and the data will go to Graylog . The dashboard will continue to populate for you automatically.

Bonus Concept – Monitor you Sites WAN Connection(s)

This same script could be used to monitor WAN connections at different sites. Without any extra fields, we could use the interface_externalIp or source fields provided by the speedtest cli/sending host to filter by site location, add a pipeline rule to add a field biased on a lookup table or add a single field to the speedtest GELF message (change the script slightly) to provide that in the original message, etc. Use my dashboard to make a new dashboard with tabs for per-site and a summary page! The possibilities are endless.

Most of all, go have fun!

About Graylog  
At Graylog, our vision is a secure digital world where organizations of all sizes can effectively guard against cyber threats. We’re committed to turning this vision into reality by providing Threat Detection & Response that sets the standard for excellence. Our cloud-native architecture delivers SIEM, API Security, and Enterprise Log Management solutions that are not just efficient and effective—whether hosted by us, on-premises, or in your cloud—but also deliver a fantastic Analyst Experience at the lowest total cost of ownership. We aim to equip security analysts with the best tools for the job, empowering every organization to stand resilient in the ever-evolving cybersecurity landscape.

About Version 2 Digital

Version 2 Digital is one of the most dynamic IT companies in Asia. The company distributes a wide range of IT products across various areas including cyber security, cloud, data protection, end points, infrastructures, system monitoring, storage, networking, business productivity and communication products.

Through an extensive network of channels, point of sales, resellers, and partnership companies, Version 2 offers quality products and services which are highly acclaimed in the market. Its customers cover a wide spectrum which include Global 1000 enterprises, regional listed companies, different vertical industries, public utilities, Government, a vast number of successful SMEs, and consumers in various Asian cities.

Why API Discovery Is Critical to Security

For Star Trek fans, space may be the final frontier, but in security, discovering Application Programming Interfaces (APIs) could be the technology equivalent. In the iconic episode “The Trouble with Tribbles,” the legendary starship Enterprise discovers a space station that becomes overwhelmed by little fluffy, purring, rapidly reproducing creatures called “tribbles.” In a modern IT department, APIs can be viewed as the digital tribble overwhelming security teams.

 

As organizations build out their application ecosystems, the number of APIs integrated into their IT environments continues to expand. Organizations and security teams can become overwhelmed by the sheer number of these software “tribbles,” as undiscovered and unmanaged APIs create security blindspots.

 

API discovery is a critical component for any security program because it expands the organization’s attack surface.

 

What is API discovery?

API discovery is a manual or automated process that identifies, documents, and catalogs an organization’s APIs so that security teams can monitor the application-to-application data transfers. To manage all APIs that the organization integrated into its ecosystem, organizations need a comprehensive inventory that includes:

  • Internal APIs: interfaces between a company’s backend information and application functionality
  • External APIs: interfaces exposed over the internet to non-organizational stakeholders, like external developers, third-party vendors, and customers

 

API discovery enables organizations to identify and manage the following:

  • Shadow (“Rogue”) APIs: unchecked or unsupervised APIs
  • Deprecated (“Zombie”) APIs: unused yet operational APIs without the necessary security updates

 

What risks do undocumented and unmanaged APIs pose?

Threat actors can exploit vulnerabilities in these shadow and deprecated APIs, especially when the development and security teams have no way to monitor and secure them.

 

Unmanaged APIs can expose sensitive data, including information about:

  • Software interface: the two endpoints sharing data
  • Technical specifications: the way the endpoints share data
  • Function calls: verbs (GET, DELETE) and nouns (Data, Access) that indicate business logic

 

Why is API discovery important?

Discovering all your organization’s APIs enhances security by incorporating them into:

  • Risk assessments: enabling API vulnerability identification, prioritization, and remediation
  • Compliance: mitigate risks arising from accidental sensitive data exposures that lead to compliance violations, fines, and penalties
  • Vendor risk management: visibility into third-party security practices by understanding the services, applications, and environments that they can impact
  • Incident response: faster detection, investigation, and response times by understanding potential entry points, impacted services, and data leak paths
  • Policy enforcement: ensuring all internal and external APIs follow the company’s security policies and best practices
  • Training and awareness: providing appropriate educational resources for developers and IT staff

 

Beyond the security use case, API discovery provides these additional benefits:

  • Faster integrations by understanding available endpoints, methods, and data formats
  • Microservice architecture management by tracking services, health status, and interdependencies
  • Enhanced product innovation and value by understanding API capabilities and limitations
  • Increased revenue by understanding API usage

 

Using automation for API discovery

While developers can manually discover APIs, the process is expensive, inefficient, and risky. Manual API discovery processes are limited because they are:

  • Time-consuming: With the average organization integrating over 9,000 known APIs, manual processes for identifying unknown or unmanaged APIs can be overwhelming, even in a smaller environment.
  • Error-prone: Discovering all APIs, including undocumented ones and those embedded in code, can lead to incomplete discovery, outdated information, or incorrect documentation.
  • Resource-intensive: Manual discovery processes require manual inventory maintenance.

 

Automated tools make API discovery more comprehensive while reducing overall costs. Automated API discovery tools provide the following benefits:

  • Efficiency: Scanners can quickly identify APIs, enabling developers to focus on more important work.
  • Accurate, comprehensive inventory: API discovery tools can identify embedded and undocumented APIs, enhancing security and documentation.
  • Cost savings: Automation takes less time to scan for updated information, reducing maintenance costs.

 

 

What to look for in an API discovery tool

While different automated tools can help you discover the APIs across your environment, you should know the capabilities that you need and what to look for.

Continuous API Discovery

Developers can deliver new builds multiple times a day, continuously changing the API landscape and risk profile. For an accurate inventory and comprehensive visibility, you should look for a solution that scans:

  • All API traffic at runtime
  • Categorizes API calls
  • Sorts incoming traffic into domain buckets

For example, when discovering APIs by domain, the solution includes cases where:

  • Domains are missing
  • Public or Private IP addresses are used

With the ability to identify shadow and deprecated APIs, the solution should give you a way to add domains to the:

  • Monitoring list so you can start tracking them in the system
  • Prohibited list so that the domain should never be used

 

 

Vulnerability Identification

An API discovery solution that analyzes all traffic can also identify potential security vulnerabilities. When choosing a solution, you should consider whether it contains the following capabilities:

  • Captures unfiltered API request and response detail
  • Enhances details with runtime analysis
  • Creates an accessible datastore for attack detection
  • Identified common threats and API failures aligned to OWASP and MITRE guidance
  • Automatic remediation tops with actionable solutions that enable the teams to optimize critical metrics like Mean Time to Response (MTTR)

Risk Assessment and Scoring

Every identified API and vulnerability increases the organization’s risk. To appropriately mitigate risk arising from previously unidentified and unmanaged APIs, the solution should provide automated risk assessment and scoring. With visibility into the type of API and the high-risk areas that should be prioritized, Security and DevOps teams can focus on the most risky APIs first.

 

Graylog API Security: Continuous, Real-Time API Discovery

Graylog API Security is continuous API security, scanning all API traffic at runtime for active

attacks and threats. Mapped to security and quality rules, Graylog API Security captures

complete request and response details, creating a readily accessible datastore for attack

detection, fast triage, and threat intelligence. With visibility inside the perimeter,

organizations can detect attack traffic from valid users before it reaches their applications.

 

Graylog API Security captures details to immediately identify valid traffic from malicious

actions, adding active API intelligence to your security stack. Think of it as a “security

analyst in-a-box,” automating API security by detecting and alerting on zero-day attacks

and threats. Our pre-configured signatures identify common threats and API failures and

integrate with communication tools like Slack, Teams, Gchat, JIRA or via webhooks.

About Graylog  
At Graylog, our vision is a secure digital world where organizations of all sizes can effectively guard against cyber threats. We’re committed to turning this vision into reality by providing Threat Detection & Response that sets the standard for excellence. Our cloud-native architecture delivers SIEM, API Security, and Enterprise Log Management solutions that are not just efficient and effective—whether hosted by us, on-premises, or in your cloud—but also deliver a fantastic Analyst Experience at the lowest total cost of ownership. We aim to equip security analysts with the best tools for the job, empowering every organization to stand resilient in the ever-evolving cybersecurity landscape.

About Version 2 Digital

Version 2 Digital is one of the most dynamic IT companies in Asia. The company distributes a wide range of IT products across various areas including cyber security, cloud, data protection, end points, infrastructures, system monitoring, storage, networking, business productivity and communication products.

Through an extensive network of channels, point of sales, resellers, and partnership companies, Version 2 offers quality products and services which are highly acclaimed in the market. Its customers cover a wide spectrum which include Global 1000 enterprises, regional listed companies, different vertical industries, public utilities, Government, a vast number of successful SMEs, and consumers in various Asian cities.

FERC and NERC: Cyber Security Monitoring for The Energy Sector

As cyber threats targeting critical infrastructure continue to evolve, the energy sector remains a prime target for malicious actors. Protecting the electric grid requires a strong regulatory framework and robust cybersecurity monitoring practices. In the United States, the Federal Energy Regulatory Commission (FERC) and the North American Electric Reliability Corporation (NERC) play key roles in safeguarding the power system against cyber risks.

 

Compliance with the NERC Critical Infrastructure Protection (NERC CIP) standards provides a baseline for mitigating security risk, but organizations should implement security technologies that help them streamline these processes.

Who are FERC and NERC?

The Federal Energy Regulatory Commission (FERC) is the governmental agency that oversees the power grid’s reliability. Since the Energy Policy Act of 2005 that granted FERC these powers, the rise of smart technologies across the energy industry expanded. This led to the Energy Independence and Security Act of 2007 (EISA) which led to FERC and the National Institute of Standards and Technology (NIST) to coordinate cybersecurity reliability standards that protect the industry.

 

However, to develop these reliability standards, FERC certified the North American Electric Reliability Corporation (NERC). Currently, NERC has thirteen published and enforceable Critical Infrastructure Protection (CIP) standards plus one more awaiting approval.

What are the NERC CIP requirements?

The cybersecurity Reliability Standards are broken out across nine documents, each detailing the different requirements and controls for compliance.

 

CIP-002: BES Cyber System Categorization

This CIP creates “bright-line” criteria for how to categorize BES Cyber Systems based on impact that an outage would cause. The publication separates BES Cyber Systems into three general categories:

  • High Impact
  • Medium Impact
  • Low Impact

 

CIP-003-8: Security Management Controls

This publication, with its most recent iteration being enforceable in April 2026, requires Responsible Entities to create policies, procedures, and processes for high or medium impact BES Cyber Systems, including:

  • Cyber security awareness: training delivered every 15 calendar months
  • Physical security controls: protections for assets, locations within an asset containing low impact BES systems, and Cyber Assets
  • Electronic access controls: controls that limit inbound and outbound electronic access for assets containing low impact BES Cyber Systems
  • Cyber security incident response: identification, classification, and response to Cyber Security incidents, including establishing role and responsibilities for testing (every 36 months) and handling incidents, including updating Cyber Security Incident response plan within 180 days of a reportable incident
  • Transient cyber asset and removable media malicious code risk mitigation: Plans for implementing, maintaining, and monitoring anti-virus, application allowlists, and other methods to detect malicious code
  • Vendor electronic remote access security controls: processes for remote access to mitigate risks, including ways to determine and disable remote access and detect known or suspected malicious communications from vendor remote access

 

CIP-004-7: Personnel & Training

Every Responsible Entity needs to have one or more documented processes and provide evidence to demonstrate implementation of:

  • Security awareness training
  • Personnel risk assessments prior to granting authorized electronic or unescorted physical access
  • Access management programs
  • Access revocation programs
  • Access management, including provisioning, authorizing, and terminating access

CIP-005-7: Electronic Security Perimeter(s)

To mitigate risks, Responsible Entities need to have controls for permitting known and controlled communications need documented processes and evidence of:

  • Connection to network using a routable protocol protected by an Electronic Security Perimeter (ESP)
  • Permitting and documenting the reasoning for necessary communications while denying all other communications
  • Limiting network accessibility to management Interfaces
  • Performing authentication when allowing remove access through dial-up connectivity
  • Monitoring to detect known or suspected malicious communications
  • Implementation of controls, like encryption or physical access restrictions, to protect data confidentiality and integrity
  • Remote access management capabilities, multi-factor authentication and multiple methods for determining active vendor remote access
  • Multiple methods for disabling active vendor remote access
  • One or more methods to determine authenticated vendor-initiated remote access, terminating these remote connections, and controlling ability to reconnect

 

Most of these requirements fall under the umbrella of network security monitoring. For example, many organizations will implement tools like:

 

Once organizations can define baselines for normal network traffic, they can implement detections that alert their security teams to potential incidents.

CIP-006-6: Physical Security of BES Cyber Systems

To prove management of physical access to these systems, Responsible Entities need documented processes and evidence that include:

  • Physical security plan with defined operation or procedural controls for restricting physical access
  • Controls for managing authorized unescorted access
  • Monitoring for unauthorized physical access
  • Alarms or alerts for responding to detected unauthorized access
  • Logs that must be retained for 90 days for managing entry of individuals authorized for unescorted physical access
  • Visitor control program that includes continuous escort for visitors, logging visitors, and retaining visitor logs
  • Maintenance and testing programs for the physical access control system

 

Many organizations use technologies to help manage physical security, like badges or smart alarms. By incorporating these technologies into the overarching cybersecurity monitoring, Responsible Entities can correlate activities across the physical and digital domains.

Example: Security Card Access in buildings showing entry and exit times.

 

By tracking both physical access and digital access to BES Cyber Systems, Responsible Entities can improve their overarching security posture, especially given the interconnection between physical and digital access to systems.

CIP-007-6: System Security Management

To prove that they have the technical, operational, and procedural system security management capabilities, Responsible Entities need documented processes and evidence that include:

  • System hardening: disabling or preventing unnecessary remote access, protection against physical input/output ports used for network connectivity, risk mitigation to prevent CPU or memory vulnerabilities
  • Patch management process: evaluating security patch applicability at least once every 35 calendar days and tracking, evaluating, and installing security patches
  • Malicious code prevention: methods for deterring, detecting, or preventing malicious code and mitigating the threat of detected malicious code
  • Monitoring for security events: logging security events per system capabilities, generating security event alerts, retaining security event logs, and reviewing summaries or samplings of logged security events
  • System access controls: authentication enforcement methods, identification and inventory of all known default or generic accounts, identification of people with authorized access to shared accounts, changing default passwords, technical or procedural controls for password-only authentication, including forced changes at least once every 15 calendar months, limiting the number of unsuccessful authentication attempts and generating

 

Having a robust threat detection and incident response (TDIR) solution enables Responsible Parties to leverage user and entity behavior analytics (UEBA) with the rest of their log data so they can handle security functions like:

  • Privileged access management (PAM)
  • Password policy compliance
  • Abnormal privilege escalation
  • Time spent accessing a resource
  • Brute force attack detection

 

CIP-008-6: Incident Reporting and Response Planning

To mitigate risk to reliable operation, Responsible Entities need documented incident response plans and evidence that include:

  • Processes for identifying, classifying, and responding to security incidents
  • Roles and responsibility for the incident response groups or individuals
  • Incident handling procedures
  • Testing incident response plan at least once every 15 calendar months
  • Retaining records for reportable and other security incidents
  • Reviewing, updating, and communicating lessons learned, changes to the plan based on lessons learned, notifying people of changes

 

Security analytics enables Responsible Entities to enhance their incident detection and response capabilities. By building detections around MITRE ATT&CK tactics, techniques, and procedures (TTPs), security teams can connect the activities occurring in their environments with real-world activities to investigate an attacker’s path faster. Further, with high-fidelity Sigma rule detections aligned to the ATT&CK framework, Responsible Entities improve their incident response capabilities.

 

In the aftermath of an incident or incident response test, organizations need to develop reports that enable them to identify lessons learned. These include highlighting:

  • Key findings
  • Actions taken
  • Impact on stakeholders
  • Incident ID
  • Incident summary that includes type, time, duration, and affected systems/data

 

To improve processes, Responsible Entities need to organize the different pieces of evidence into an incident response report that showcases the timeline of events.

 

Further, they need to capture crucial information about the incident, including:

  • Nature of threat
  • Business impact
  • Immediate actions taken
  • When/how incident occurred
  • Who/what was affected
  • Overall scope

 

CIP-009-6: Recovery Plans for BES Cyber Systems

To support continued stability, operability, and reliability, Responsible Entities need documented recovery plans with processes and evidence for:

  • Activation of recovery plan
  • Responder roles and responsibilities
  • Backup and storage of information required for recovery and verification of backups
  • Testing recovery plan at least once every 15 calendar months
  • Reviewing, updating, and communicating lessons learned, changes to the plan based on lessons learned, notifying people of changes

 

CIP-010-4: Configuration Change Management and Vulnerability Assessments

To prevent and detect unauthorized changes, Responsible Entities need documentation and evidence of configuration change management and vulnerability assessment that includes:

  • Authorization of changes that can alter behavior of one or more cybersecurity controls
  • Testing changes prior to deploying them in a production environment
  • Verifying identity and integrity of operating systems, firmware, software, or software patches prior to installation
  • Monitoring for unauthorized changes that can alter the behavior of one or more cybersecurity controls at least once every 35 calendar days, including at least one control for configurations affecting network accessibility, CPU and memory, installation, removal, or updates to operating systems, firmware, software, and cybersecurity patches, malicious code protection, security event logging or alerting, authentication methods, enabled or disabled account status
  • Engaging in vulnerability assessment at least once every 15 calendar months
  • Performing an active vulnerability assessment in a test environment and documenting the results at least once every 36 calendar months
  • Performing vulnerability assessments for new systems prior to implementation

 

CIP-011-3: Information Protection

To prevent unauthorized access, Responsible Entities need documented information protection processes and evidence of:

  • Methods for identifying, protecting, and securely handling BES Cyber System Information (BCSI)
  • Methods for preventing the unauthorized retrieval of BCSI prior to system disposal

CIP-012-1: Communications between Control Centers

To protect the confidentiality, integrity, and availability assessment monitoring data transmitted between Control Centers, Responsible Entities need documented processes for and evidence of:

  • Risk mitigation for unauthorized disclosure and modification or loss of availability of data
  • Identification of risk mitigation methods
  • Identification of where methods are implemented
  • Assignment of responsibilities when different Responsible Entities own or operate Control Centers

 

To mitigate data exfiltration risks, Responsible Parties need to aggregate, correlate, and analyze log data across:

  • Network traffic logs
  • Antivirus logs
  • UEBA solutions

 

With visibility into abnormal data downloads, they can more effectively monitor communications between control centers.

 

CIP-013-2: Supply Chain Risk Management

To mitigate supply chain risks, Responsible Entities need documented security controls and evidence of:

  • Procurement processes for identifying and assessing security risks related to installing vendor equipment and software and switching vendors
  • Receiving notifications about vendor-identified incidents related to products or services
  • Coordinating responses to vendor-identified incidents related to products or services
  • Notifying vendors when no longer granting remote or onsite access
  • Vendor disclosure of known vulnerabilities related to products or services
  • Verifying software and patch integrity and authenticity
  • Coordination controls for vendor-initiated remote access
  • Review and obtain approval for the supply chain risk management plan

 

CIP-015-1: Internal Network Security Monitoring

While this standard is currently awaiting approval by the NERC Board of Trustees, Responsible Entities should consider preparing for publication and enforcement with documented processes and evidence of monitoring internal networks’ security, including the implementation of:

  • Network data feeds using a risk-based rationale for monitoring network activity, including connections, devices, and network communications
  • Detections for anomalous network activity
  • Evaluating anomalous network activity
  • Retaining internal network security monitoring data
  • Protecting internal network security monitoring data

 

Graylog Security: Enabling the Energy Sector to Comply with NERC CIP

Using Graylog Security, you can rapidly mature your TDIR capabilities without the complexity and cost of traditional Security Information and Event Management (SIEM) technology. Graylog Security’s Illuminate bundles include detection rulesets so that you have content, like  Sigma detections, enabling you to uplevel your security alert, incident response, and threat hunting capabilities with correlations to ATT&CK tactic, techniques, and procedures (TTPs).

By leveraging our cloud-native capabilities and out-of-the-box content, you gain immediate value from your logs. Our anomaly detection ML improves over time without manual tuning, adapting rapidly to new data sets, organizational priorities, and custom use cases so that you can automate key user and entity access monitoring.

With our intuitive user interface, you can rapidly investigate alerts. Our lightning-fast search capabilities enable you to search terabytes of data in milliseconds, reducing dwell times and shrinking investigations by hours, days, and weeks.

To learn how Graylog Security can help you implement robust threat detection and response, contact us today.

 

About Graylog  
At Graylog, our vision is a secure digital world where organizations of all sizes can effectively guard against cyber threats. We’re committed to turning this vision into reality by providing Threat Detection & Response that sets the standard for excellence. Our cloud-native architecture delivers SIEM, API Security, and Enterprise Log Management solutions that are not just efficient and effective—whether hosted by us, on-premises, or in your cloud—but also deliver a fantastic Analyst Experience at the lowest total cost of ownership. We aim to equip security analysts with the best tools for the job, empowering every organization to stand resilient in the ever-evolving cybersecurity landscape.

About Version 2 Digital

Version 2 Digital is one of the most dynamic IT companies in Asia. The company distributes a wide range of IT products across various areas including cyber security, cloud, data protection, end points, infrastructures, system monitoring, storage, networking, business productivity and communication products.

Through an extensive network of channels, point of sales, resellers, and partnership companies, Version 2 offers quality products and services which are highly acclaimed in the market. Its customers cover a wide spectrum which include Global 1000 enterprises, regional listed companies, different vertical industries, public utilities, Government, a vast number of successful SMEs, and consumers in various Asian cities.

Security Misconfigurations: A Deep Dive

Managing configurations in a complex environment can be like playing a game of digital Jenga. Turning off one port to protect an application can undermine the service of a connected device. Writing an overly conservative firewall configuration can prevent remote workforce members from accessing an application that’s critical to getting their work done. In the business world that runs on Software-as-a-Service (SaaS) applications and the Application Programming Interfaces (APIs) that allow them to communicate, a lot of your security is based on the settings you use and the code that you write.

 

Security misconfigurations keep creeping up the OWASP Top 10 Lists for applications, APIs, and mobile devices because they are security weaknesses that can be difficult to detect until an attacker uses them against you. With insight into what security misconfigurations are and how to mitigate risk, you can create the programs and processes that help you protect your organization.

What are Security Misconfigurations?

Security misconfigurations are insecure default settings that remain in place during and after system deployment. They can occur anywhere within the organization’s environment because they can arise from:

  • Operating systems
  • Network devices their settings
  • Web servers
  • Databases
  • Applications

 

Organizations typically implement hardening across their environment by changing settings to limit where, how, when, and with whom technologies communicate. Some examples of security misconfigurations may include failing to:

  • Disable or uninstall unnecessary features, like ports, services, accounts, API HTTP verbs, API logging features
  • Change default passwords
  • Limit the information that error messages send to users
  • Update operating systems, software, and APIs with security patches
  • Set secure values for application servers, application frameworks, libraries, and databases
  • Use Transport Layer Security (TLS) for APIs
  • Restrict Cross-Origin resource sharing (CORS)

 

Security Misconfigurations: Why Do They Happen?

Today’s environments consist of complex, interconnected technologies. While all the different applications and devices make business easier, they make security configuration management far more challenging.

 

Typical reasons that security misconfigurations happen include:

  • Complexity: Highly interconnected systems can make identifying and implementing all possible security configurations difficult.
  • Patches: Updating software and systems can have a domino effect across all interconnected technologies that can change a configuration’s security.
  • Hardware upgrades: Adding new servers or moving to cloud can change configurations at hardware and software level.
  • Troubleshooting: Fixing a network, application, or operating system issue to maintain service availability may impact other configurations.
  • Unauthorized changes: Failing to follow change management processes for adding new technologies or fixing issues can impact interconnections, like users connecting corporate email to authorize API access for an unsanctioned web application.
  • Poor documentation: Failure to document baselines and configuration changes can lead to lack of visibility across the environment.

Common Types of Security Misconfiguration Vulnerabilities

To protect your systems against cyber attacks, you should understand what some common security misconfigurations are and what they look like.

  • Improperly Configured Databases: overly permissive access rights or lack of authentication
  • Unsecured Cloud Storage: lack of encryption or weak access controls
  • Default or Weak Passwords: failure to change passwords or poor password hygiene leading to credential-based attacks
  • Misconfigured Firewalls or Network Settings: poor network segmentation, permissive firewall settings, open ports left unsecured
  • Outdated Software or Firmware: failing to install software, firmware, or API security updates or patches that fix bugs
  • Inactive Pages: failure to include noopener or noreferrer attributes in a website or web application
  • Unneeded Services/Features: leaving network services available and ports open, like web servers, file share servers, proxy servers FTP servers, Remote Desktop Protocol (RDP), Virtual Network Computing (VNC), and Secure Shell Protocol (SSH)
  • Inadequate Access Controls: failure to implement and enforce access policies that limit user interaction, like the principle of least privilege for user access, deny-by-default for resources, or lack of API authentication and authorization
  • Unprotected Folders and Files: using predictable, guessable file names and locations that identify critical systems or data
  • Improper error messages: API error messages returning data such as stack traces, system information, database structure, or custom signatures

Best Practices for Preventing Security Misconfiguration Vulnerabilities

As you connect more SaaS applications and use more APIs, monitoring for security misconfigurations becomes critical to your security posture.

Implement a hardening process

Hardening is the process of choosing the configurations for your technology stack that limit unauthorized external access and use. For example, many organizations use the CIS Benchmarks that provide configuration recommendations for over twenty-five vendor product families. Organizations in the Defense Industrial Base (DIB) use the Department of Defense (DoD) Security Technical Implementation Guides (STIGs).

 

Your hardening processes should include a change management process that:

  • Sets and documents baselines
  • Identifies changes in the environment
  • Reviews whether changes are authorized
  • Allows, blocks, or rolls back changes as appropriate
  • Updates baselines and documentation to reflect allowed changes

Implement a vulnerability management and remediation program

Vulnerability scanners can identify common vulnerabilities and exposures (CVEs) on network-connected devices. Your vulnerability management and remediation program should:

  • Define critical assets: know the devices, resources, and users that impact the business the most
  • Assign ownership: identify the people responsible for managing and updating critical assets
  • Identify vulnerabilities: use penetration tests, red teaming, and automated tools, like vulnerability scanners
  • Prioritize vulnerabilities: combine a vulnerability’s severity and exploitability to determine the ones that pose the highest risk to the organization’s business operations
  • Identify and monitor key performance indicators (KPIs): set metrics to determine the program’s effectiveness, including number of assets managed, number of assets scanned per month, frequency of scans, percentage of scanned assets containing vulnerabilities, percentage of vulnerabilities fixed within 30, 60, and 90 days

 

Monitor User and Entity Activity

Security misconfigurations often lead to unauthorized access. To mitigate risk, you should implement best authentication, authorization, and access practices that include:

  • Multifactor Authentication: requiring users to provide two or more of the following: something they know (password), something they have (token/smartphone), or something they are (fingerprint or face ID)
  • Role-based access controls (RBAC): granting the least amount of access to resources based on their job functions
  • Activity baselines: understanding normal user and entity behavior to identify anomalous activity
  • Monitoring: identifying activity spikes like file permission changes, modifications, and deletions across email servers, webmail, removable media, and DNS

 

Implement and monitor API Security

APIs are the way that applications talk to one another, often sharing sensitive data. Many companies struggle to manage the explosion of APIs that their digital transformation strategies created, creating security weaknesses that attackers seek to exploit. To mitigate these risks, you should implement a holistic API security monitoring program that includes:

  • Continuously discovering APIs across the environment
  • Scanning all API traffic at runtime
  • Categorizing API calls
  • Sorting API traffic into domain buckets
  • Automatically assessing risk
  • Prioritizing remediation action using context that includes activity and intensity
  • Capturing unfiltered API request and response details

 

 

Graylog Security and Graylog API Security: Helping Detect and Remediate Security Misconfigurations

Built on the Graylog Platform, Graylog Security gives you the features and functionality of a SIEM while eliminating the complexity and reducing costs. With our easy to deploy and use solution, you get the combined power of centralized log management, data enrichment and normalization, correlation, threat detection, incident investigation, anomaly detection, and reporting.

 

Graylog API Security is continuous API security, scanning all API traffic at runtime for active attacks and threats. Mapped to security and quality rules like OWASP Top 10, Graylog API Security captures complete request and response detail, creating a readily accessible datastore for attack detection, fast triage, and threat intelligence. With visibility inside the perimeter, organizations can detect attack traffic from valid users before it reaches their applications.

 

With Graylog’s prebuilt content, you don’t have to worry about choosing the server log data you want because we do it for you. Graylog Illuminate content packs automate the visualization, management, and correlation of your log data, eliminating the manual processes for building dashboards and setting alerts.

 

About Graylog  
At Graylog, our vision is a secure digital world where organizations of all sizes can effectively guard against cyber threats. We’re committed to turning this vision into reality by providing Threat Detection & Response that sets the standard for excellence. Our cloud-native architecture delivers SIEM, API Security, and Enterprise Log Management solutions that are not just efficient and effective—whether hosted by us, on-premises, or in your cloud—but also deliver a fantastic Analyst Experience at the lowest total cost of ownership. We aim to equip security analysts with the best tools for the job, empowering every organization to stand resilient in the ever-evolving cybersecurity landscape.

About Version 2 Digital

Version 2 Digital is one of the most dynamic IT companies in Asia. The company distributes a wide range of IT products across various areas including cyber security, cloud, data protection, end points, infrastructures, system monitoring, storage, networking, business productivity and communication products.

Through an extensive network of channels, point of sales, resellers, and partnership companies, Version 2 offers quality products and services which are highly acclaimed in the market. Its customers cover a wide spectrum which include Global 1000 enterprises, regional listed companies, different vertical industries, public utilities, Government, a vast number of successful SMEs, and consumers in various Asian cities.

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