A coalition of cyber firms and critical infrastructure operators on Tuesday spelled out its views on the tasks that the Cybersecurity and Infrastructure Security Agency should assign federal agencies to protect operational technology systems after this summer’s attacks on water utilities.

The Operational Technology Cybersecurity Coalition said a CISA binding operational directive (BOD) for OT should specify who is responsible for protecting these systems at each agency,, draw on existing federal guidelines and set minimum cybersecurity practices.

The coalition said the BOD would address a need to act based on CISA’s lack of visibility into the spectrum of OT devices in federal agencies, a lack of consistent across-the-board OT security policies and the severity of the consequences that an attack on federal OT could produce.

Just last month, the Government Accountability Office published a report which concluded that most federal civilian executive branch agencies (FCEBs) haven’t enacted Office of Management and Budget requirements released in 2023 for networked Internet of Things and OT devices.

Putting forward recommendations for a CISA directive has two goals, said Michael Garcia, policy director of the coalition.

“One, it does make sure that the government is taking its own medicine,” said Garcia, who until recently worked at the agency. “You should practice what you preach. … Second, it sends a very strong signal to the private sector that, ‘This is what we think is important: As an OT partner, owner or operator or critical infrastructure owner or operator, [this is what] you should ask other providers to do.’”

There are 8,000 General Services Administration-owned and -leased properties, many of which would have OT involved in everything from power supply to heating, ventilation and air conditioning systems. Some of those OT systems might be “trivial,” Garcia acknowledged, but the coalition paper notes that CISA “does not currently have a holistic view of the assets managed by the FCEB and the potential risks, such as connected programmable logic controllers, to which the government may be exposed.”

With OT falling into a “government gray zone” between chief information officers and facilities managers, CISA should tell agencies to formally designate an officer in charge of cybersecurity for OT, the coalition recommends.

The directive should examine past OT guidelines the National Security Agency issued to see if they should apply to federal civilian agencies, and align any requirements in the hypothetical BOD with cybersecurity performance goals that CISA first issued in 2022, according to the coalition.

The coalition doesn’t assert that such a BOD would have headed off the attacks this summer on the water sector, and is focused on federal OT, something where CISA has done some work.

“To be fair, CISA has incorporated OT security requirements into prior directives (such as BODs 23-01, 23-02, and 26-04) alongside a host of technical guidance,” the paper reads. “But as AI reduces the technical barriers to sophisticated cyber operations, enabling adversaries to identify weaknesses, accelerate reconnaissance, and move laterally through poorly segmented operational environments with greater speed and scale, it is time for an encompassing BOD solely focused on OT security.”

CISA didn’t respond to a request for comment Monday in advance of the coalition publishing its paper.

But Garcia said that in discussions with CISA, “increasingly, I think they understand that there might be a need” for an OT BOD.

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The summer’s cyberattacks by Iranian hackers on water systems in 12 states underscored how vulnerable U.S. water systems are to foreign adversaries. A broad attack on water infrastructure could have consequences comparable to a public health crisis that impacts the country’s entire population.

The threat to water has long been clear. As the 2026 Annual Threat Assessment from the U.S. intelligence community states “Cyber actors from China, Russia, Iran, North Korea, and ransomware groups . . .  pose critical threats to U.S. networks and critical infrastructure.”

Advances in artificial intelligence have heightened those vulnerabilities. Advanced AI models, such as Anthropic’s Claude Mythos, have demonstrated the ability to identify thousands of zero-day vulnerabilities in critical software systems, including major operating systems and browsers. Other systems, including some developed in China, are demonstrating similar capabilities. AI systems can now “plan, test, and execute attacks in rapid cycles,” ranging from minutes down to seconds.

U.S. water systems are vulnerable to cyberattacks for technical, legal and practical reasons.

Technical: About 80% of U.S. water systems lack even basic cyber hygiene, a weakness exploited in the summer attacks. Even systems that serve most of the population (approximately 450 large and 4500 medium-sized water systems) have not adopted advanced cybersecurity capabilities used in other sectors where failure can have catastrophic consequences, including aviation, rail, mass transit, medical devices, finance, and nuclear power.

Legal: The Environmental Protection Agency lacks clear statutory authority to impose broad cybersecurity requirements on water systems. In 2023, EPA issued a memo interpreting existing regulations to strengthen the cybersecurity of water systems. The action met widespread opposition from the water sector as well as formal legal challenges, and the EPA ultimately withdrew the memo. The agency retains limited authority. It can require water systems to complete  risk and resilience assessments, maintain emergency response plans and, in emergencies, address critical cybersecurity flaws.  

Practical: Most U.S. water systems are small.  Some 45,000 serve 3,300 persons or fewer. Because of their size, many fall outside the EPA’s regulatory authority and below the “cyber poverty line,” lacking the funding, staff and expertise necessary for effective cybersecurity.

Not surprisingly, the summer attacks drew attention from the administration and Congress. The EPA ,in partnership with the FBI, and CISA each issued guidance on remedial actions, including disconnecting operational technology, from the internet where feasible and adopting robust password practices.

Sens. Amy Klobuchar, D-Minn., and Adam Schiff (D-Calif., introduced the Water Safety Shield Act, a bill that would require tiered cybersecurity standards for the water sector and dedicate a proposed $600 million annually to water cybersecurity. It would go beyond earlier, less prescriptive efforts to improve resilience in the sector.  

The administration has also established a pilot program with Texas and private-sector cybersecurity companies to identify and address water-system vulnerabilities at no cost to utilities. These efforts are well intentioned, but they do not address the underlying causes of the problem.

Large and midsize U.S. water systems have long been targets of sophisticated adversaries. China’s Volt Typhoon revealed deep Chinese penetration of critical infrastructure, including water systems, that support national security, economic security, and civil society. Those systems remain vulnerable because many have not adopted well-known protections, such as zero-trust architecture. More fundamentally, the software on which they depend remains vulnerable to exploitation.

Policymakers have struggled to respond for two reasons: the cost and complexity of adopting stronger technical defenses, and the highly fragmented nature of the water sector. A relatively small number of large systems serve about half the U.S. population. Roughly 49,000 systems serve the rest, including the 80% of the systems serving 3,300 people or fewer. Those smaller systems serve about 7% of the population.

Despite these challenges, the capabilities needed to significantly strengthen U.S. water-system security are well known and widely used in other sectors where failure can be devastating, including those listed above.

A five-part federal program could provide high-level cybersecurity for U.S. water systems.

Establish stronger technical capabilities. Water systems should adopt zero-trust architecture, which permits only authenticated, minimum-necessary access to resources and segments networks so that a breach in one area does not compromise the entire system. Such architecture could have blocked the unauthorized intrusions used in the summer attacks. Zero-trust systems are already widely used across multiple sectors, and commercial providers can support their adoption. The Department of Defense has certified several companies to provide zero-trust architecture for department components.

Water systems should also use formal methods to reduce or eliminate vulnerabilities in software that cannot safely fail.  Although the summer attackers did not appear to exploit flaws in the water systems’ code, a high-level adversary such as China would be likely to do so.

Formal methods range from “memory-safe” programming languages, which prevent coding errors that leave computer memory open to attack, to rigorous mathematical proofs that verify that software behaves as intended. They also support secure “microkernels,” which strictly separate software functions and make it far more difficult for an attacker to move laterally through a system.

Safe code development draws on the principles of formal methods but is a more practical, semi-formal approach. AI tools developed by companies including Google and CrowdStrike can identify and help repair software vulnerabilities, a process sometimes called “code mending.” Water systems should use such tools to defend against advanced adversaries.

Developing formally verified code for water systems would not be simple. But much of the software that directs the mechanical operations of water utilities comes from a small group of companies, including Siemens, Schneider, and Rockwell Automation. Those companies have the technical expertise to develop more secure code where it is necessary. Secure microkernels are also commercially available.

Support large water systems.  Congress should require large water systems to adopt zero-trust architecture, code-mending tools, and formal methods for critical software. The requirements should be phased in over time.  The legislation should also provide tax credits to help cover the costs of developing, implementing, and maintaining these protections.

Assist midsize water systems. The federal government should establish a program that provides technical expertise and financial support to midsize water systems, including municipal utilities. The program should help them adopt zero-trust architecture, code-mending tools, and formal methods for software development.

Midsize systems will likely need a longer phase-in period than large utilities.  A federally funded cohort of experts drawn from government and the private sector could provide the necessary support. Regional teams, organized by geography or technical specialty, could address the different needs of different water systems.

Create a safe operations posture for small water systems. Few, if any, systems serving 3,300 people or fewer are run by organization with substantial cybersecurity resources. Many cash-strapped systems rely on remote monitoring because on-site service is beyond their budgets. But remote monitoring can create serious risk when industrial devices are exposed directly to the public internet without proper firewalls or virtual private networks. 

The summer attacks primarily exploited such exposed devices. The EPA, FBI, and CISA guidance said the affected systems could be protected by locking them into “run” mode, which prevents remote reprogramming. That step may reduce immediate risk, but it also requires systems to be operated in person.

Small utilities therefore need either the staff and funding for manual operations or secure remote-access systems operated by trained personnel.

A voluntary cybersecurity corps could help address the budget and staffing challenges facing small water systems.  One model would follow the National Guard approach: State governors would oversee the effort, while the federal government would provide funding. A state-led program could begin with water systems and later expand to other vulnerable critical-infrastructure sectors.

The Texas pilot, which brings together the state, the federal government and private-sector companies, could serve as a model. It could also serve as a test for a regional approach, something we suggested in a prior op-ed.  

Build an AI-capable cybersecurity cohort. The proposed cohort should include specialists in artificial intelligence, including experts from leading AI companies. They could use AI tools to develop and deploy cybersecurity programs, including zero-trust architectures and code-mending systems, for utilities of all sizes. AI is advancing rapidly and applying it to protect water systems should be a national priority. The AI specialists should work with major industrial-technology companies, including Siemens, Schneider, and Rockwell, as well as directly with the water systems, both larger and smaller.

U.S. water systems face a significant and growing threat. The Trump administration, Congress, states and private sector should work together urgently to ensure that every American can rely on safe, clean water.

Franklin D. Kramer is a former assistant secretary of defense for international security affairs.

Robert J. Butler is the co-founder and managing director of Cyber Strategies LLC, served as the first deputy assistant secretary of defense for space and cyber policy, and served as the Chief Security Officer for IO Data Centers, a global data center enterprise, among other cybersecurity-related roles in both corporate and government organizations.

Melanie J. Teplinsky is an adjunct professor and senior fellow in the Technology, Law and Security Program at American University (AU), Washington College of Law.  She previously practiced technology law at Steptoe & Jonson LLP and served on the pre-IPO advisory board for CrowdStrike.

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The computers that automate water treatment systems across the country were built for durability, not for an internet-connected world. Many still accomplish their fundamental function, but as cyberattacks on the sector mounted this summer, water industry officials say those aging systems, especially internet-exposed operational technology and programmable logic controllers, remain among the easiest ways for adversaries to break in.

Tom Dobbins, executive director of the Water Information Sharing and Analysis Center or WaterISAC, told CyberScoop the sector’s biggest ongoing weaknesses include exposed OT, vulnerable PLCs, insecure connections through integrators and poor cyber hygiene at smaller utilities, which have pushed the center to make threat sharing faster across the sector.

“We have been under attack, and our enemies, the threat actors, are stepping up their activity as the U.S. is involved in a number of conflicts around the world,” Dobbins said.

That includes not only threats from Iran, the nation the U.S. government reportedly believes is behind this summer’s water facility attacks, but also China and Russia, he said.

WaterISAC is announcing a partnership with Cyware Wednesday to use its threat intelligence platform, selecting the company in part because of its existing relationships with other industry ISACs, Dobbins said. The ISAC already has a partnership with the National Rural Water Association to serve 20,000 of the water sector’s smallest utilities, and Dobbins said Cyware would help its analysts further.

It’s a sector that faces myriad challenges, seen by many as further behind on protecting its systems due to financial and technological constraints.

“OT systems that are exposed to the internet are a major challenge, and many of these systems that are older generation need to be not accessible to the internet,” Dobbins said.

Furthermore, programmable logic controllers (PLCs) are “obviously” a “vulnerability point,” he said. 

Those two vulnerabilities were the ones most commonly linked to this summer’s attacks.

Across the sector, PLCs have been the “main point of entry” for hackers, in part because they date back to a “simpler, gentler time,” Dobbins said.

“A lot of the equipment was developed pre-cyber threats and activities,” he said. “The equipment, it’s still valuable, it still is operational, so there’s not a huge reason for or incentive for utilities to upgrade it.”

President Donald Trump has disputed the notion that Iran was behind this summer’s attacks, despite alerts from the Cybersecurity and Infrastructure Security Agency.

“Let’s put it this way: I saw a recent CISA release that pointed to Iran as threat actors, and I know that the president kind of implied that it was not Iran, but I’ll say that CISA maybe is more expert in this area than maybe the president,” Dobbins said. “The president may not have been fully briefed when he made that comment.”

But CISA has also warned of potential threats from Russia and China, he said.

Two other sources of vulnerability for the sector are external — integrators — and internal — employees.

“If those integrators are working and they have a connection into an OT system that’s not managed discretely, then a threat actor can come in through an integrator and get into a system,” he said. 

Then there’s someone “who’s actually a good employee who’s tried to do the right thing and opens an email that has a malicious link in it, so they become subject to a phishing attack,” Dobbins said.

At smaller utilities, it can be difficult to keep up with basic cyber hygiene as well, he said: changing passwords, implementing multifactor authentication.

One way that Cyware might be able to help is by leveraging its relationships with other ISACs, said Tom Stockmeyer, managing director of government and critical infrastructure at Cyware.

“We’re thrilled to add water to the portfolio and start enabling cross-sector sharing,” he said.

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Hackers are targeting water, food, energy, chemical, manufacturing and commercial facilities by taking aim at Siemens S7 Series programmable logic controllers (PLCs) and making use of artificial intelligence in the attacks, U.S. government agencies warned Wednesday.

It’s the latest government warning about attacks on critical infrastructure as the United States wages war against Iran, which the government blamed for a recent campaign against water and wastewater systems— but doesn’t mention in Wednesday’s alert. 

The National Security Agency didn’t immediately respond to a request for comment about who was behind the attacks on the PLCs, which are used to control manufacturing processes.

The agencies said the attacks were an “active threat,” rather than a theoretical one. The attacks could disrupt critical industrial processes, cause safety incidents or lead to the compromise of sensitive data.

Wednesday’s alert from the NSA, Cybersecurity and Infrastructure Security Agency, FBI, Energy Department and Environmental Protection Agency makes special note of the hackers using AI-generated exploitation scripts in the attacks.

“Using AI to generate exploitation scripts represents an evolution in threat actor capabilities, dramatically reducing the technical expertise and time required to develop working ICS exploitation scripts and malicious tools,” the alert states. “In addition, AI enables adversaries to rapidly leverage additional attack vectors and adapt to defensive measures. Threat actors can easily collect public information about vulnerabilities and weaknesses, find exposed and exploitable PLCs, and use AI-generated scripts to act on that information.”

A former top CISA official, Michael Garcia, thought that it was a first for the agency in one of its cybersecurity advisories (CSAs) about operational technology (OT).

“It is the first alert I have seen where CISA is saying in a CSA that a malicious actor is using AI scripts to target OT systems,” Garcia, now vice president of the cybersecurity practice at Monument Policy Advocacy, said on LinkedIn. But the advisory doesn’t recommend using AI in response, instead focusing on well-known, traditional defensive measures, he added.

Frenos, an OT penetration testing company, found another element of the alert troubling: The method by which the attackers could use the approach beyond Siemens-made PLCs.

“Siemens S7 is the subject here, but the exposure pattern is not brand specific,” Brian Proctor, CEO of the company, said in an email. “An adversary who has mapped your data blocks understands your process. They know what normal looks like, which means they know what an operator would fail to notice.”

The AI-generated scripts are disguised as legitimate monitoring tools, the advisory said of the hackers behind them.

“The actors leverage Internet scanning services to find Internet-exposed PLCs running outdated software or that are otherwise poorly protected,” the advisory reads.

Siemens said it was “aware” of the alert and “is coordinating closely with CISA.”

“This advisory does not describe new vulnerabilities within the S7 Series programmable logic controllers (PLC). Instead, this reflects threat actors employing new techniques to exploit potential misconfigurations,” the company continued, noting a security bulletin it issued last month.

“Siemens will provide updates around this issue to potentially affected customers through our ProductCERT team,” it said. “At this point in time, we have not identified increased attack levels or unknown vulnerabilities in Siemens ICS products.”

Updated 8/20/2026: to include Siemens comment.

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Last week, the FBI and EPA issued a joint alert that should concern anyone who drinks water in America–which is to say, everyone. Since July 27, water and wastewater utilities in at least seven states have reported cyberattacks against internet-facing programmable logic controllers (PLCs), the small industrial computers that run pumps, valves, and treatment equipment. Some of these attacks degraded operations. Utilities reported pressure loss and flooding, several systems reverted to manual control, and one Minnesota community declaring a local state of emergency.

Nothing about these attacks required sophisticated methods. The attackers didn’t use zero-day exploits or novel malware. They found controllers exposed to the public internet, many of them so old that they stopped receiving security patches years ago. They logged in, changed IP addresses and passwords, and locked operators out of their own equipment. In at least one case, they modified the ladder logic controlling industrial equipment. These were not Hollywood-style hacks. The controllers sat exposed and undefended.

If this feels familiar, it should. In late 2023, attackers compromised controllers at water utilities across several states, including the widely reported incident in Aliquippa, Pennsylvania. The federal government issued guidance then, too. One of the crucial differences between then and now is that attackers have grown in ambition. They’ve moved from defacing screens to disrupting operations across dozens of systems at once, exploiting the fact that third-party integrators often deploy the same vulnerable configuration across many small utilities. 

The uncomfortable truth is that this was preventable. The reason it wasn’t stopped is more structural than technical. The United States has roughly 50,000 community water systems. Most are small, publicly funded, and run by operators whose primary job is keeping water safe and flowing. Cybersecurity ranks far below that, if it ranks at all. The devices in question are often a decade or more old and replacing them takes capital these utilities don’t have. Rules governing water cybersecurity remain mostly voluntary. Attackers understand these economics perfectly. We should too, yet these attacks keep happening.

 But inaction is a choice. The defenses that work here cost little and require no exotic technology. The FBI and EPA guidance is sound, and every water and wastewater organization should act on it this week, not later. Here’s how:

• Get controllers off the public internet. No PLC should be reachable from the outside world. Remote access should go through a secure gateway that mediates, monitors, and logs every connection. That includes cellular modems, which are the overlooked entry point in nearly every audit.
• Fix passwords. Default and shared credentials are still the most common way in. Strong, unique passwords are the cheapest security control available.
• Restrict communication between devices. Firewall rules and access control lists should allow only expected communication between known control system devices. Block traffic from hosting providers and other sources that have no business touching a water plant.
• Lock the logic. Keep physical and software key switches in the run position except during authorized updates. This prevents unauthorized changes to configuration and firmware.
• Practice running manually. The utilities that survived these attacks best were the those that switched to manual operations quickly. That skill requires constant practice.
• Verify, don’t assume. Nearly every utility believes its PLCs aren’t internet-exposed, right up until an inventory proves otherwise. You can’t protect what you can’t see. Most operators are surprised by what a complete asset inventory reveals: forgotten modems, integrator-installed remote access, devices nobody knew were still online.

Every attack like this follows the same pattern. Attackers change configurations, reset passwords, and modify project files. Every one of those actions creates a signal on the network before operations degrade. In this most recent case, one victim only noticed ladder logic discrepancies across multiple sites. Catching intrusions shouldn’t depend on a sharp-eyed engineer having a good day. Continuous monitoring of OT environments exists to turn those signals into alerts within minutes instead of days. That difference is the difference between an incident report and a boil-water notice.

Water systems have the least margin for error and, too often, the fewest resources to defend themselves. The FBI and EPA have told us plainly what’s happening and what to do about it. The attackers are betting we won’t follow through. For the third time in three years, they’re testing that bet.

Let’s finally prove them wrong.

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With the World Cup now complete, its biggest cybersecurity story may be what didn’t happen. While no major public cyber disruption has been reported, that shouldn’t be mistaken for a lack of risk. 

In the run-up to the tournament, the FBI’s Internet Crime Complaint Center (IC3) issued a public service announcement warning organizations and fans about fraudulent, spoofed websites impersonating the FIFA event – a reminder that the absence of a headline-grabbing breach doesn’t mean bad actors weren’t trying. In many ways, it’s evidence of the planning, coordination, and resilience required to keep an event of this scale running securely.

A global event like the World Cup depends on far more than what happens inside the stadium. It relies on local governments, venues, transportation systems, telecom providers, payment platforms, hotels, vendors, public safety agencies, and law enforcement, all working together. 

When I worked at the FBI, I saw how fast major events test teamwork across agencies, regions, and businesses. The World Cup offered that test at a scale few events can match.

Successful resilience is built months before kickoff

Successful major-event security depends on what happens long before there is a visible incident: trusted relationships, clear roles, shared intelligence and response plans. Planning becomes even more important when an event is not limited to a single city or venue.

In the past, event security consisted of guards, gates, and stadium perimeters. Those still matter, but they’re only part of the picture. Today, an event this big that brings millions of people together depends on many systems working in concert. No single organization owns the full risk picture, which means resilience depends on how well these groups can share information, coordinate response plans, and keep essential services operating under pressure. This means security can’t be planned around one perimeter. The real perimeter is the full event ecosystem.

Resilience starts much earlier, with planning across organizations that may not normally operate as one team. The real test for major events is whether public- and private-sector partners know their roles before pressure hits. That includes who shares information, who validates threats, who communicates with the public, who has decision-making authority and how quickly partners can act if a system slows down or becomes unavailable.

Major events are only as resilient as the systems behind them

Attackers don’t need to compromise the most visible organization to create disruption. They can look for weaker points across the event ecosystem. A disruption may begin with a vendor, ticketing platform, transportation partner, payment provider, hotel, contractor or communications provider, but the impact can quickly become broader than any one organization.

Sports organizations now operate like large businesses, with ticketing systems, VIP data, sponsors, vendors, media partners, stadium operations, payment systems, and fan engagement platforms. They depend on networks of suppliers and partners, and that creates multiple possible entry points.

Operational technology (OT) deserves more attention than it typically gets in these conversations. A ransomware attack that disrupted stadium operations directly, rather than a ticketing site or a fan-facing app, would be one of the most damaging scenarios organizers could face. OT security has to sit alongside the more visible concerns like payment fraud and spoofed domains, not behind them.

Bad actors don’t let a good crisis go to waste. Fans are often an easy target. Excitement drives a fan to buy a last-minute ticket or check a score on an unknown site. That excitement is exactly what fraudsters count on.

This risk grows over time. As the event gets closer and attracts more eyes, it becomes a richer target. A fake FIFA ticket site is useless to a crook a month after the last game. Groups running these systems must act faster as opening day nears, and share threat intelligence without delay.

Threat intelligence turns planning into proactive defense

The World Cup may be over, but the work isn’t. Cities, governments, and private-sector organizations will continue supporting large-scale public events that depend on complex digital and physical ecosystems. The question isn’t whether another major event will face cyber threats, it’s whether the planning starts early enough.

Organizations involved in future major events should focus on resilience, not just prevention. That means planning for what happens if a critical system slows down, goes offline, or becomes unreliable, and ensuring partners know how to coordinate before an incident occurs.

Every major event forces defenders to prepare for known risks. The harder challenge is anticipating the ones that haven’t emerged yet.

The next major disruption may not come from the attack that organizations spent months preparing for. It could target a new dependency, exploit emerging technology, or capitalize on a moment when public attention is at its highest. That’s why resilience can’t be built around yesterday’s playbook. It has to be informed by continuous threat intelligence, regular coordination across public- and private-sector partners, and the flexibility to adapt as the threat landscape changes.

The World Cup demonstrated what’s possible when that preparation comes together. As cities, governments, and private organizations look ahead to future global events, success won’t be measured solely by the attacks they stop. It will be measured by how effectively they can maintain critical operations, share information, and adapt under pressure when the unexpected happens.

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