Navigating Compliance: A Practical Guide to the New Maritime Cybersecurity Regulations

Introduction

The U.S. Coast Guard's final rule on "Cybersecurity in the Marine Transportation System," published January 17, 2025, presents significant compliance challenges for maritime industry stakeholders. This practical guide focuses on the compliance aspects of the new regulations, offering actionable insights for maritime executives, compliance officers, and security professionals tasked with implementation before the July 16, 2025 effective date.

Technical Brief: Cybersecurity in the Maritime Sector

Overview The maritime sector is a critical component of global trade, facilitating the movement of goods and resources across the world. However, increased digitization, reliance on operational technology (OT), and interconnected systems have made it a prime target for cyberattacks. This brief explores the key challenges, vulnerabilities, incidents, and strategies

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Understanding Your Compliance Obligations

Who Must Comply

The cybersecurity requirements apply to:

• U.S.-flagged vessels subject to 33 CFR Part 104
• Facilities subject to 33 CFR Part 105
• Outer Continental Shelf (OCS) facilities subject to 33 CFR Part 106

Compliance Timeline

The Coast Guard has established a phased compliance schedule:

Note: The Coast Guard is considering a 2-to-5-year delay in implementation specifically for U.S.-flagged vessels. Submit comments on this potential delay by March 17, 2025.

Key Compliance Requirements

1. Cybersecurity Plan Development

Your organization must develop and maintain a comprehensive Cybersecurity Plan that:

• Identifies critical systems and potential vulnerabilities
• Defines cybersecurity roles and responsibilities
• Outlines strategies for risk management
• Establishes incident response procedures
• Addresses network segmentation requirements
• Documents access control mechanisms
• Details training and drill protocols

All plans must be submitted to the Coast Guard for review and approval within 24 months of the rule's effective date.

Safeguarding the Maritime Frontier: New Cybersecurity Rules for the Marine Transportation System

Introduction The maritime industry is experiencing an unprecedented digital transformation as vessels, ports, and offshore facilities increasingly adopt interconnected systems to improve operational efficiency. However, this growing reliance on digital technologies has exposed the Marine Transportation System (MTS) to an escalating wave of cybersecurity threats. Recognizing this critical vulnerability, the

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2. Cybersecurity Officer (CySO) Designation

You must formally designate a qualified Cybersecurity Officer responsible for:

• Implementing the Cybersecurity Plan
• Ensuring compliance with regulations
• Overseeing training and exercises
• Managing cyber incident response
• Serving as the primary cybersecurity contact

The CySO should possess the appropriate knowledge and authority to fulfill these responsibilities effectively.

3. Incident Reporting Procedures

From July 16, 2025, you must report "reportable cyber incidents" to the National Response Center without delay. A reportable cyber incident includes any breach that:

• Affects safety or security systems
• Has potential for causing a Transportation Security Incident (TSI)
• Impacts critical operational technology
• Results in unauthorized access to sensitive systems

The rule also revises the definition of "hazardous condition" to expressly include cyber incidents.

4. Network Segmentation Implementation

You must:

• Segment IT and OT networks
• Log and monitor connections between networks
• Document network architecture
• Implement appropriate firewalls and access controls
• Conduct regular testing of segmentation effectiveness

This requirement poses significant challenges, particularly for organizations with legacy infrastructure.

5. Training and Exercise Program

Your organization must establish:

• Initial cybersecurity training (within 6 months)
• Regular refresher training
• Role-specific training for personnel with system access
• Documented training records
• Annual drills and exercises
• Exercise evaluation protocols

Compliance Roadmap: 10 Steps to Implementation

1. Conduct a Gap Analysis: Compare your current cybersecurity posture against the new requirements to identify deficiencies.
2. Inventory Critical Systems: Document all IT and OT systems, identifying those critical to safety and security.
3. Perform a Risk Assessment: Evaluate vulnerabilities, threats, and potential impacts specific to your operations.
4. Develop Your Cybersecurity Plan: Create a comprehensive plan addressing all regulatory requirements.
5. Appoint Leadership: Designate a qualified CySO and define supporting roles and responsibilities.
6. Establish Incident Response Procedures: Develop protocols for detecting, responding to, and recovering from cyber incidents.
7. Implement Technical Controls: Deploy necessary segmentation, monitoring, and access control measures.
8. Develop and Deliver Training: Create and implement a training program for all relevant personnel.
9. Conduct Drills and Exercises: Test your plan's effectiveness through realistic scenarios.
10. Document Everything: Maintain comprehensive records of all compliance activities.

Common Compliance Challenges and Solutions

Legacy Infrastructure

Challenge: Many vessels and facilities utilize dated systems not designed with cybersecurity in mind.

Solution:

• Consider compensating controls where direct technical solutions aren't feasible
• Implement additional monitoring and physical controls
• Document risk acceptance for systems that cannot be fully secured
• Explore waiver options for systems that cannot reasonably comply

Resource Constraints

Challenge: Smaller operators may lack the technical expertise and financial resources for full compliance.

Solution:

• Explore industry partnerships and shared resources
• Consider third-party managed security services
• Investigate Port Security Grant Program funding
• Prioritize critical systems and phase implementation

OT/IT Integration

Challenge: Operational technology often requires specialized security approaches different from IT systems.

Solution:

• Develop separate but coordinated strategies for OT and IT
• Engage vendors for OT-specific security guidance
• Implement strict access controls between environments
• Consider air-gapping critical OT systems where appropriate

Compliance Cost Considerations

The Coast Guard estimates that this final rule creates costs for industry and government of approximately $1.2 billion total and $138.7 million annualized. Budget planning should consider:

• Staffing costs (CySO, security personnel)
• Technical implementation expenses
• Training program development and delivery
• Consulting services for specialized expertise
• Documentation and record-keeping systems
• Audit and assessment expenses
• Incident response capabilities
• Ongoing monitoring and maintenance

Waiver and Equivalence Options

The final rule allows for limited waivers or equivalence determinations under specific circumstances:

Waiver Potential: Available if you can demonstrate the cybersecurity requirements are unnecessary given your specific operating conditions.

Equivalence Determination: Possible if you can show compliance with international conventions or standards that provide an equivalent level of security.

Each request will be evaluated case-by-case, requiring thorough documentation of your security posture.

Verification and Inspection Readiness

The Coast Guard will verify compliance through:

• Cybersecurity Plan reviews
• Regular inspections
• Audit activities
• Response to reported incidents

To prepare for these oversight activities:

• Maintain organized compliance documentation
• Conduct regular self-assessments
• Address identified deficiencies promptly
• Establish a dedicated liaison for Coast Guard interactions
• Document all cybersecurity activities and incidents

Non-Compliance Consequences

Failure to meet the Coast Guard's cybersecurity requirements may result in:

• Civil penalties
• Operational restrictions
• Loss of operating licenses
• Reputational damage
• Increased vulnerability to attacks
• Potential liability in the event of incidents

Additional Resources

• Coast Guard Maritime Cyber Resources: www.uscg.mil/MaritimeCyber/
• NIST Cybersecurity Framework: Essential guidance for risk management
• Port Security Grant Program: Potential funding for implementation
• Industry Associations: Many offer compliance assistance and peer networking

Conclusion

While the new maritime cybersecurity regulations present significant compliance challenges, they also provide an opportunity to strengthen your organization's security posture against evolving threats. By taking a methodical approach to implementation—starting with a thorough assessment of your current state and developing a realistic roadmap for compliance—you can navigate these requirements effectively.

Given the critical role maritime transportation plays in the global economy and national security, these measures are essential for protecting against threats that could disrupt operations, compromise safety, or impact commerce. Proactive compliance not only helps you meet regulatory requirements but also strengthens your overall security position in an increasingly hostile cyber environment.

This guide is intended to provide general compliance information and does not constitute legal advice. Organizations should consult with qualified legal counsel regarding their specific compliance obligations.