New York DFS (23 NYCRR 500) Compliance
TThe NYDFS Cybersecurity Regulation requires covered financial entities to run annual penetration testing and vulnerability assessments.
Learn how ImmuniWeb supports Section 500.5.
New York DFS Cybersecurity Regulation Compliance
What Is the NYDFS Cybersecurity Regulation?
Part 500 requires each Covered Entity to maintain a risk-based cybersecurity program with prescriptive controls: a risk assessment, a CISO, multi-factor authentication, encryption, access controls, monitoring and logging, an asset inventory, incident notification within 72 hours, and an annual certification signed by the CEO and CISO.
The Second Amendment added board-level oversight, expanded notification, automated vulnerability scanning with manual review, and additional requirements for larger 'Class A' companies. The annual certification creates personal accountability for senior officers.
See how ImmuniWeb supports NYDFS Section 500.5 penetration testing and vulnerability assessments- for the financial applications you run. Request a demo· or run a free Community Edition test.
Who Must Comply with NYDFS Part 500?
Part 500 applies to Covered Entities:
- Banks and lenders licensed or authorized by NYDFS.
- Insurance companies operating under NYDFS authorization.
- Other financial services entities (including mortgage providers); larger 'Class A' companies face additional requirements.
The web, mobile and API applications these entities run are within the scope of Part 500's testing requirements.
Key NYDFS Requirements for Application Security
Application security is driven by Section 500.5:
- 500.5(a) - Penetration testing: annual penetration testing of information systems based on the risk assessment.
- 500.5(b) - Vulnerability assessments: bi-annual vulnerability assessments, including automated scans and manual review of systems.
- Monitoring and remediation: monitor for, and remediate in a timely way, vulnerabilities found.
NYDFS Part 500 Requirements in Depth
Section 500.5 - Penetration Testing and Vulnerability Assessments
Section 500.5 requires annual penetration testing of information systems based on the risk assessment, plus bi-annual vulnerability assessments including automated scans and manual review of systems not otherwise covered. Penetration testing and scanning of web and mobile applications and APIs satisfy these requirements directly.
Application Security in the Program
Beyond 500.5, the program's monitoring, access-control and risk-assessment requirements all touch application security. Continuous scanning and periodic penetration testing, with tracked remediation, keep the program effective and evidence-ready.
Common Web & Mobile Application Risks to Address
The vulnerabilities Section 500.5 expects you to find map closely to the OWASP Top 10:
- Broken Access Control — users reaching data or actions they should not.
- Cryptographic Failures — weak or missing encryption exposing sensitive data.
- Injection — SQL, command or other injection via unvalidated input.
- Insecure Design — missing security controls by design, not just by bug.
- Security Misconfiguration — default, incomplete or unsafe configuration.
- Vulnerable & Outdated Components — unpatched libraries and frameworks.
- Identification & Authentication Failures — weak login, session or credential handling.
- Software & Data Integrity Failures — untrusted updates, insecure CI/CD pipelines.
- Security Logging & Monitoring Failures — attacks going undetected.
- Server-Side Request Forgery (SSRF) — the server tricked into making malicious requests.
For mobile apps, the OWASP Mobile Top 10 is the equivalent reference (insecure data storage, insecure communication, weak cryptography, and so on). Reliably finding these issues requires testing the running application, not just a documentation review.
How to Support NYDFS Part 500 with ImmuniWeb
- 1. Map your systems. Inventory internet-facing financial apps and APIs with ImmuniWeb Discovery.
- 2. Penetration test annually (500.5(a)) with On-Demand and MobileSuite.
- 3. Run vulnerability assessments (500.5(b)) with Neuron, bi-annually.
- 4. Remediate and retest with actionable, zero-false-positive reports.
- 5. Test continuously with Continuous in CI/CD.
- 6. Prepare evidence for the annual certification and NYDFS reviews.
How ImmuniWeb Helps You Achieve NYDFS Part 500 Compliance
ImmuniWeb supports Section 500.5 with the penetration testing and vulnerability assessments NYDFS requires, with audit-ready evidence.
| Requirement | What it requires | ImmuniWeb products |
|---|---|---|
| 500.5(a) | Annual penetration testing. | On-Demand, MobileSuite |
| 500.5(b) | Bi-annual vulnerability assessments (scans + review). | Neuron, Discovery |
| Program & remediation | Monitor and remediate; secure development. | Continuous, On-Demand |
ImmuniWeb On-Demand and MobileSuite deliver web and mobile penetration testing; Neuron and Neuron Mobile provide automated scanning; Continuous embeds testing into CI/CD; and Discovery maps the attack surface - producing evidence for the annual NYDFS certification.
NYDFS Part 500 vs International Frameworks
If you already work to international standards, the same ImmuniWeb testing supports all of them:
| Framework | Application-security angle | How ImmuniWeb maps |
|---|---|---|
| NYDFS Part 500 | 500.5 pentest + vulnerability assessments | Web/mobile pentest + scanning + ASM |
| FTC Safeguards Rule | 314.4(d) testing | Same testing supports both |
| EU DORA | Resilience testing | Same testing supports both |
| NIST CSF 2.0 | Protect / Detect functions | Application testing & monitoring |
Penetration Testing vs Security Scanning
Both are needed. Automated scanning (DAST) gives broad, frequent coverage and is ideal for continuous testing in CI/CD; manual penetration testing finds business-logic and complex vulnerabilities that scanners miss and produces the depth auditors and regulators expect. Combine continuous scanning with periodic manual penetration testing, and re-test after significant changes.
Compliance Checklist (Application Security)
- Inventory of internet-facing financial apps and APIs
- Annual penetration testing performed (500.5(a))
- Bi-annual vulnerability assessments performed (500.5(b))
- Automated scans plus manual review in place
- Findings remediated and re-tested; evidence retained
- Incident notification process ready (72 hours)
- Evidence prepared for the annual CEO/CISO certification
Why NYDFS Part 500 Compliance Matters
NYDFS enforces Part 500 aggressively, with consent orders and fines up to USD 30 million, and the annual certification signed by the CEO and CISO creates personal accountability. Penetration testing and vulnerability assessments are explicit, recurring obligations under Section 500.5.
Because web, mobile and API applications are a primary attack surface for financial institutions, demonstrable testing is one of the most direct ways to meet Part 500 and avoid enforcement.