The average cyberattack costs for a small- or medium-size business is more than $250,000. The salary for a chief information security officer (CISO) is about the same, pulling in between $250,000 and $400,000, according to the annual 2026 CISO Report from Sophos and Cybersecurity Ventures. Small- and medium-size businesses (SMBs) know they cannot afford the salary, so they roll the dice, hoping they will not be attacked. This is a dangerous gamble that these businesses, which make up the backbone of the American economy, should not have to take. A virtual (vCISO) or fractional CISO (fCISO) can provide a practical solution.

As the American economy goes digital, SMBs now rely on the same building blocks as big enterprises — cloud services, payment systems, remote access, customer data, and other third-party vendors.  But without senior cyber leadership, cybersecurity often becomes a patchwork of tools, checklists, insurance paperwork, and whatever guidance a vendor offers. That may get these companies through a questionnaire; it will not build real resilience. Nearly half, all reported cyber incidents, which is projected to cost the global economy $12.2 trillion annually by 2031, involve smaller firms.

The threat is growing in both size and sophistication. Adversaries are deploying AI to automate reconnaissance, develop malware, and run phishing campaigns at scale.  This reduces the cost and skill needed to target smaller firms at volume. Adversaries are also collecting encrypted data with the intent to decrypt it later when they have access to large enough quantum computers. SMBs in defense, healthcare, and financial supply chains often hold sensitive credentials that provide access into larger enterprise environments, but most are not prepared to adopt quantum-resistant encryption.

SMBs generally understand they face cyber risk. The real gap is leadership: someone who can turn technical vulnerabilities into business decisions, set priorities, brief executives, prepare for audits, and hold vendors accountable. For more SMBs, hiring a full-time CISO is financially unrealistic.

A Virtual CISO provides remote, on-demand cybersecurity leadership and advice, typically supporting several organizations at the same time. A fractional CISO is a dedicated, part-time executive who is more deeply integrated into one organization’s governance, security planning, and day-to-day operations. Both models give smaller organizations access to senior-level cybersecurity expertise in a flexible, more affordable way than hiring a full-time CISO.

Washington should make it easier for SMBs to hire fractional cybersecurity leaders, because the private market is not closing this gap on its own. The Cybersecurity and Infrastructure Security Agency (CISA) and the Small Business Administration (SBA) could help by publishing buyer guidance: vetted criteria for evaluating providers, example scopes of work and deliverables, and real-world case studies that show SMB owners what a high-quality vCISO or fCISO engagement should look like.

Clear guidance matters because many smaller firms cannot easily tell the difference between true cybersecurity leadership and a tool reseller, compliance-only consultant, or a generic managed services contract. Any vetted provider criteria should emphasize proven experience building and running security programs, independence from vendor incentives and product quotas, and the ability to tie security investment to real business risk, not just a list of certifications. Model scopes of work should also spell out the basics every engagement should deliver: an initial risk assessment, a prioritized remediation roadmap, and simple metrics that show whether security is improving over time. Without clear buyer criteria, federal efforts could end up funding low-quality services that add cost and paperwork without making companies safer.

The National Institute for Standards and Technology (NIST) should recognize these CISO models in its SMB-focused Cybersecurity Framework guidance. That would help smaller firms turn the framework’s Govern, Identify, Protect, Detect, Respond, and Recover functions into a clear, accountable leadership structure. This would make these roles less abstract: the point is not merely providing advice, but taking executive-level ownership of risk priorities, vendor oversight, incident readiness, and communication with the owner or board.

Congress and the Treasury Department should consider targeted tax incentives or credits for qualified cybersecurity leadership services, tied to measurable risk-reduction outcomes. Eligible activities could include completing a risk assessment, building a incident response plan, conducting vendor security reviews, running employee training, and producing a remediation roadmap. SMBs often defer cybersecurity because every dollar competes with payroll, inventory, and growth. A targeted incentive would make security leadership easier to justify as a business investment rather than an optional add-on.

Federal acquisition officials should require contractors that handle sensitive government data to show it has executive-level cybersecurity oversight, whether it is full-time, virtual, or fractional, and should extend that expectation down to relevant subcontractors and suppliers. This is necessary because SMBs serve as entry points into defense, healthcare, financial, and critical infrastructure supply chains.

Finally, CISA and the SBA should support vCISO- and fractional-CISO-led workforce training. Employees improve security when training comes with leadership, regular reinforcement, and clear accountability, not just annual awareness training. The aim is not to turn every SMB into a Fortune 500 security shop. It should be to give smaller firms access to the leadership they need before the next incident forces the issue.

Georgianna Shea, who is a Doctor of Computer Science, is chief technologist at the Foundation for Defense of Democracies’ Center on Cyber and Technology Innovation and its Transformative Cyber Innovation Lab, where Cason Smith served as a summer 2025 intern. Cason is studying integrated information technology at the University of South Carolina.

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Seth Whitworth, who is both acting Associate Deputy Chief of Space Operations for Cyber and Data and acting chief information security officer, said he believes AI tools are shifting the way defenders review cyber risk, both for individual systems and more holistically throughout an enterprise.  

In particular, Large Language Models can be used to systematically implement fixes for the smaller but critical weaknesses that have allowed state-sponsored hackers and cybercriminals to get inside victim networks and live off the land.

“Our adversaries are not looking for the massive cybersecurity vulnerabilities – we’re actually pretty good at [defending] that,” said Whitworth Tuesday at AI Talks, presented by Scoop News Group. “They’re looking for a misconfiguration, a failed update, a tiny little thing that allows them an entry point into a very connected network.”

Many of these basic cyber hygiene problems tend to fall under existing compliance programs, but it can take more than legal mandates to fix them. Many enterprise IT networks – particularly older ones – build up technical debt over time, leading to forgotten systems, hidden routers and other forms of shadow IT that get more insecure over time.

Cybersecurity experts say agents and the Large Language Models that power them – which operate in perpetuity 24/7, – are particularly well-suited to finding these smaller flaws and quickly exploiting them.

But Whitworth argued that the same technology can be used to reshape how organizations measure and track cyber compliance, from a sluggish box-checking exercise to something more nimble and substantive. He claimed that Space Force’s internal process for obtaining Authorities to Operate and other formal security certifications used to take 3-18 months. Now, it “can now be done in weeks and days.”

That in turn can empower program managers to “pull in all of that massive amount of data, allow the AI – who doesn’t get tired, who doesn’t miss patterns, who doesn’t miss these components – to churn on those items and them deliver something” that can inform real-time changes to cybersecurity, he said.

Whitworth also acknowledged the “fear” that many organizations still have around the use of AI, as well as lingering concerns about some of the technology’s enduring limitations like hallucinations and data poisoning. He said he still gives AI-generated outputs “extra scrutiny, because I haven’t seen the trusted validation” yet.

But he also said he gets more valuable insight on the Space Force’s holistic cyber risk from using Large Language Models than he does from other security control assessments, which tend to narrowly focus on the risk of single systems or assets in isolation.

“We are operating in a highly connected, highly orchestrated world, and so moderate risk that’s accepted in one program immediately becomes moderate risk that is accepted in another program,” said Whitworth. “AI can take that whole picture and understand that when this system change impacts this system, it also impacts this [other] system.”

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Washington has rediscovered consequences. Just not consistently.

The March 6 executive order rests on a simple, correct idea: cyber-enabled fraud persists because it is profitable, scalable, and too often tolerated. So the government’s answer is to raise the cost. More coordination. More disruption. More prosecutions. More diplomatic pressure on the states that shelter these operations.

Good.

But weeks ago, an OMB Memo rescinded earlier federal software supply chain memos issued during the Biden administration. In practice, that pulled back from the prior attestation-centered model and made tools like the Secure Software Development Attestation Form and SBOM requests optional rather than durable expectations.

Put plainly, we are getting tougher on the people exploiting digital systems while getting softer on the conditions that make those systems so easy to exploit.

The executive order gets something important right. Cyber-enabled fraud is not a collection of random online annoyances. It is an industrialized form of predation: ransomware, phishing, impersonation, sextortion, and financial fraud that’s run as repeatable business models, often transnational and sometimes protected by permissive states. The order responds with a more centralized federal posture built around disruption, coordination, intelligence sharing, prosecution, resilience, and international pressure.

That is directionally correct. Criminal ecosystems do not retreat because we publish better guidance. They retreat when the cost of doing business rises.

But then we arrive at software.

The critique of the old federal assurance regime is not entirely wrong. Compliance can become theater. Bureaucracies are very good at turning legitimate security goals into rituals of form collection and checkbox management. Some skepticism was warranted. OMB says as much explicitly, arguing the prior model became burdensome and prioritized compliance over genuine security investment.

Still, the failure of bad compliance is not proof that accountability itself was the problem.

That is where the logic breaks. The administration is clearly willing to believe that criminal actors respond to deterrence. It is willing to use prosecutions, sanctions, visa restrictions, and coordinated pressure downstream. But upstream, where insecure technology shapes the terrain those criminals exploit, the theory suddenly changes. There, we are told to trust discretion. Local judgment. Flexible, risk-based decisions.

Sometimes that is wisdom. Often it is just a more elegant way of saying no one wants a hard requirement.

This is also why my own position has not changed. In a post I wrote in 2024, I argued that the industry did not need softer expectations or another round of polite encouragement. It needed more concrete action and consequences strong enough to change incentives. The problem was never that we were demanding too much accountability. The problem was that insecure software remained too cheap to ship.

That is the deeper issue. Cybercrime at scale does not thrive only because criminals exist. It thrives because the environment rewards them. Weak identity systems, brittle software, sprawling dependency chains, poor visibility, and diffuse accountability all make predation cheaper. The people who ship avoidable risk rarely absorb the full cost of it. Everyone else does.

So these two policy moves, taken together, reveal something uncomfortable. The government seems to believe in consequences for cybercriminals, but not quite in consequences for insecure production. It wants deterrence for the scammer, but discretion for the supplier.

A coherent cyber strategy would do both. It would aggressively disrupt criminal networks and also create meaningful pressure for secure-by-design production and procurement. It would recognize that punishing attackers matters, but so does changing the terrain that keeps making attack profitable.

The administration is right about one thing: cybercrime will not shrink until the costs of predation rise.

The unanswered question is why that logic should stop at the edge of the scam center.

Brian Fox is the co-founder and CTO of Sonatype.

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