Transitioning to NIST CSF - What you need to know

J Michael Smith
Jul 3
2 min read

FFIEC'S TRANSITION AWAY FROM CAT - Part 2

In our last update, we shared that the FFIEC has officially moved away from the Cybersecurity Assessment Tool (CAT) and now endorses the utilization of other nationally recognized cybersecurity frameworks like NIST Cybersecurity Framework (CSF) 2.0 as the new standard.

In this newsletter, we will focus on exactly what this means for your institution—and how to make the transition successfully.

Understanding NIST CSF 2.0: Key Enhancements

The updated NIST CSF 2.0 goes beyond just controls—it emphasizes cybersecurity as an integral part of organizational strategy. Here are some major additions:

Governance Function: New to CSF 2.0, this function emphasizes leadership, risk ownership, and strategic alignment of cybersecurity with business objectives.
Supply Chain Risk Management: Enhanced guidance helps institutions evaluate third-party and supply chain exposure more effectively.
Tailored Implementation: NIST now provides sector-specific profiles and tiers, making it easier to adapt based on your institution’s size, risk tolerance, and resources.

How It Compares to the CAT Tool

While CAT provided a checklist-based approach, NIST CSF offers a more strategic, outcome-focused structure. Here’s a quick comparison:

Aspect	CAT Tool	NIST CSF 2.0
Approach	Static checklist	Dynamic, iterative framework
Governance	Minimal	Central to the framework
Flexibility	One-size-fits-all	Scalable for any organization
Updates	Discontinued	Actively maintained by NIST

Your Next Steps Toward Compliance

Map Existing Controls:
Align your current CAT-based controls to the five NIST CSF functions: Identify, Protect, Detect, Respond, and Recover—plus the new Govern function.
Gap Analysis:
Identify areas where your current program doesn’t meet NIST CSF 2.0 standards.
Develop a Transition Plan:
Prioritize updates to governance structure, supply chain risk assessments, and incident response strategies.
Engage Stakeholders:
Ensure leadership and board members understand the implications of the shift and are involved in the oversight process.