This week on Experts on Experts, I sat down with Sabeen Malik, Rapid7’s VP of Global Government Affairs and Public Policy, to discuss a shift security leaders can’t afford to treat as separate threads: frontier AI, vulnerability discovery, cybersecurity compliance, and operational resilience.
AI is changing how quickly vulnerabilities can be found, validated, and potentially exploited. At the same time, regulators, boards, and customers are asking for stronger proof that controls are working and risk is being reduced. Security leaders are being pushed to move at machine speed while proving the business is resilient.
AI vulnerability discovery is moving faster than security standards
Sabeen and I started with the policy question. Many of the systems security teams rely on today were designed for a slower era of human-led discovery. Vulnerability disclosure processes, scoring systems, prioritization frameworks, and regulatory expectations all assume organizations have time to assess, verify, and respond.
Frontier AI challenges that assumption. If models can help find and chain vulnerabilities faster, the industry needs stronger standards around verification, access, disclosure, and accountability. Access to powerful models matters, but access alone does not solve the governance problem. The bigger question is whether the ecosystem can responsibly validate, prioritize, and act on what these systems produce.
AI in cybersecurity must move from discovery to risk reduction
For defenders, faster discovery is only useful if it leads to faster action. Finding more vulnerabilities does not automatically make organizations safer. In many cases, it creates more noise for teams already under pressure.
The real challenge is exploitability. Security teams need to understand which risks are actually reachable, which issues matter most in their environment, and where action will reduce exposure fastest. That is where the shift from reactive security to preemptive security becomes critical. The goal is to use data, context, AI, and expertise to act earlier, not simply respond faster after something happens.
Cybersecurity compliance is becoming continuous
We also discussed how the compliance environment is changing. Organizations are no longer being asked to prove readiness once a year. Increasingly, they need to provide detailed evidence on shorter timelines across a growing set of regulatory and assurance requirements.
That creates a real challenge when evidence is collected manually or disconnected from live security operations. Leaders need to show what changed, what was fixed, who owns the response, and what risk remains. Static snapshots are no longer enough.
Cyber GRC connects security operations, risk, and compliance
One of the clearest themes from the conversation is that the future of security operations will be AI-driven, but human-led. AI can help teams move faster, surface what matters, and respond with greater scale and consistency. But governance, accountability, and judgment still matter.
That same principle applies to compliance. Security and compliance teams need live operational context, not disconnected reports. They need to connect what they detect, what they fix, and what they can prove.
Watch the full episode to hear our conversation on what this moment means for AI in cybersecurity, cybersecurity compliance, and resilient security operations:
The NIS2 directive asks covered organizations to take a more structured approach to risk management, governance, supply chain security, and incident reporting. It expands the scope of who may be covered, raises expectations around management body accountability, introduces clearer and more enforceable requirements, and increases pressure on organizations to show that security is being managed in a consistent, defensible way. Reporting timelines are one of the most visible parts of that shift, with early warning required within 24 hours of awareness for significant incidents, incident notification within 72 hours, and a final report within one month. It also arrived in a landscape that is still uneven, with member states continuing to implement the directive in different ways across the EU.
That combination has created a familiar challenge for CISOs and security teams, as the questions coming from boards and leadership are no longer just about whether the organization understands the regulation, but whether it can meet the requirements in practice. NIS2 reaches into risk management, reporting, governance, and supply chain oversight, which means readiness depends on how well security works across the business, not just on how well a policy is written.
That is why the most useful way to think about NIS2 is as an operational resilience exercise. Compliance still matters, of course, and teams need to know what the directive requires. What tends to make the difference over time is whether security leaders can connect those requirements to the real conditions of the environment: what is exposed, where ownership sits, how incident response works in practice, how supply chain risk is monitored, and how quickly the organization can move when something material happens.
Regulations are easier to absorb than operating model changes. A team may understand that NIS2 raises expectations around governance and incident handling, while still finding it difficult to answer basic questions quickly when pressure rises. Which business services are most critical? Which third parties matter most? Who owns the decision when a serious issue lands? How prepared are we to investigate, communicate, and report inside the timelines the directive expects? Those are the questions that separate a compliance project from a resilience program.
That is also why we have been building practical content to help teams move from interpretation to action.
Our ebook is the best place to start if you want the wider context. It is designed to help security leaders understand what NIS2 means in practical terms, how to think about the directive beyond a narrow checklist, and how to connect compliance obligations to a broader resilience strategy. If your team needs a stronger narrative for internal stakeholders, or a clearer way to explain why NIS2 should influence operational priorities, the ebook is the most useful first read.
Next, our infographic, seen below, is the quickest asset to use when you need to communicate one of the most tangible parts of NIS2: the 24-hour reporting requirement. Some stakeholders need the long-form explanation. Others need a practical view of what has to happen between incident awareness and early notification. The infographic helps teams bring that operational pressure into planning conversations, leadership updates, and internal alignment without requiring everyone to start with a longer asset first.
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Taken together, these assets are useful because they serve different parts of the same problem. The ebook gives you a strategic view and the infographic helps communicate the big picture quickly and clearly.
Enforcement expectations, reporting maturity, and national interpretation continue to evolve, and security teams are working through those changes at the same time as the wider threat landscape becomes more complex. A stronger response starts with clarity, but it needs to move quickly into coordination, ownership, and repeatable process if it is going to hold up under pressure.
If your organization is still treating NIS2 as a point-in-time compliance exercise, now is a good moment to widen the lens. The directive is pushing security leaders beyond a comply-once approach and toward a model of being continuously secure. Teams that build better visibility, stronger governance, and clearer response processes for NIS2 will be better prepared not only for regulatory scrutiny, but for the wider operational demands that are already shaping the market.
If your organization operates in the EU, or works with organizations that do, NIS2 is no longer something on the horizon. It is here and it applies to a far wider range of sectors than its predecessor, the original NIS Directive (Directive (EU) 2016/1148), and it comes with real consequences for organizations that cannot demonstrate they are meeting its requirements. The good news? You do not have to figure out how to approach it alone.
Rapid7 has developed a dedicated NIS2 resource page that shows how the Command Platform can support key technical and operational aspects of NIS2 readiness, highlights common security program gaps, and explains where our solutions can help strengthen visibility, prioritization, detection, and reporting readiness. It is not a substitute for the broader organizational, legal, and governance measures the directive also requires, but it can be a useful starting point if you are evaluating your security capabilities and want a clearer picture of where tooling can support your approach. If you are in the early stages of assessing readiness, or further along and looking for a clearer view of the technical side, it is worth 10 minutes of your time.
What are the NIS2 requirements organizations need to meet?
NIS2, formally Directive (EU) 2022/2555, expands the scope of EU cybersecurity regulation significantly. More sectors are covered,the requirements are more demanding, and, crucially, the expectations have shifted from "do you have policies in place?" to "can you demonstrate that your controls actually work, continuously?".
Article 21 mandates specific risk-management measures, including risk analysis, incident handling, business continuity, supply chain security, vulnerability handling, access control, and policies regarding the use of cryptography and encryption.. Article 23 introduces strict incident reporting timelines: an early warning within 24 hours, a full notification within 72 hours, and a detailed report within one month of a significant incident.
For many security teams, these timelines necessitate a shift in operational readiness. Timely and accurate incident reporting requires pre-established detection workflows, investigation processes, and contemporaneous documentation practices to be in place prior to an incident..
NIS2 also raises the stakes at a leadership level. Executive accountability for cybersecurity is now formalised. This is not just a technical team problem. It is a governance issue that touches CISOs, boards, and senior leadership across every in-scope organization.
Why traditional compliance approaches fall short of NIS2
Many security programs were designed around a different set of expectations. Periodic vulnerability scans.,annual audits, and compliance reports that reflected a moment in time rather than ongoing operational health.
NIS2 necessitates a move toward continuous, defensible risk management. This involves maintaining comprehensive asset visibility, identifying threat-aware exposures with high likelihood of exploitability, and validating the effectiveness of detection capabilities to support regulatory reporting requirements..
It is a meaningful operational shift, and it is exactly the kind of shift where having the right platform and the right partner matters.
How does Rapid7 support NIS2 compliance?
Rapid7 views NIS2 as an operational readiness challenge. The objective is to assist organizations in transitioning from periodic compliance assessments to continuous resilience: a sustained, measurable security posture designed to support regulatory alignment and strengthen defense-in-depth against emerging threats. The platform integrates exposure management, vulnerability management, cloud security, SIEM, and managed detection and response to provide broad support for the core requirements of Article 21 within a unified, connected view of risk..
That means organizations can move from scattered, point-in-time security activity to continuous visibility, threat-informed prioritization, faster incident workflows, and the kind of evidence and reporting that NIS2 and regulators actually demand.
A few areas where this makes a real difference:
Knowing what you are actually exposed to
Rapid7 is positioned as a Leader in the 2025 Gartner® Magic Quadrant™ for Exposure Assessment Platforms, a technology category fundamental to the Continuous Threat Exposure Management (CTEM) framework, which supports the proactive risk-management objectives of NIS2. Surface Command provides centralized visibility across internal and external environments, supporting the identification of unmanaged assets, shadow IT, and security control gaps that may otherwise remain undetected. Exposure Command utilizes active risk scoring and attack path analysis to identify and prioritize exposures based on reachability and threat context, helping teams focus remediation efforts on high-impact risks.
Responding and reporting faster
Rapid7's SIEM and MDR capabilities are designed to support the detection, investigation, and reporting speed necessitated by NIS2. 24/7 monitoring and managed response facilitate the capture of essential telemetry and investigation trails within the SIEM, streamlining the evidence collection process for regulatory reporting.
Demonstrating that controls work
NIS2 is not satisfied by a list of tools you have purchased. It wants evidence that your controls are effective. Rapid7 provides continuous risk scoring, detection metrics, and audit-ready reporting that translates security activity into governance-ready language for leadership and regulators.
Where to go next for NIS2 readiness
This post covers the highlights, but Rapid7's NIS2 resource page goes much deeper.
It walks through each of Article 21's requirements in plain language, maps them to specific Rapid7 capabilities, and shows how the platform supports risk analysis... MFA monitoring, and technical assessment of cryptographic configurations. Whether you are a CISO seeking a strategic overview, a security manager evaluating technical controls, or a compliance lead mapping regulatory requirements to platform capabilities, our guidance is designed to support your objectives. NIS2 is operational; your approach to resilience should be as well. NIS2 is operational and your readiness should be too.
This week on Experts on Experts, I’m joined by Sergio Alonso – Rapid7’s Director of Trust, Risk, and Compliance – to talk about how compliance is changing and why many security teams are rethinking the way they approach readiness, reporting, and operational risk.
One of the biggest themes in the conversation is that compliance is no longer something organizations can treat as a point-in-time exercise. Frameworks like NIS2 and DORA are increasing expectations around resilience and accountability, while cloud environments and faster release cycles make it harder to prove that controls are working consistently over time.
We also discuss the growing gap between security operations and compliance reporting. Security teams generate huge amounts of operational data every day, but translating that into evidence regulators, auditors, and leadership teams can actually use remains a challenge. The conversation looks at how organizations are trying to reduce manual effort, where automation can genuinely help, and why visibility and ownership are becoming more important as regulatory pressure grows.
Organizations still treat compliance as separate from day-to-day security operations, and the teams making the most progress are bringing those two worlds closer together, treating compliance less like a reporting layer and more like part of the operational workflow itself.
Watch the full episode below to hear the full conversation and how organizations are approaching compliance, risk, and resilience heading into 2026.
Sabeen Malik is VP, Global Government Affairs and Public Policy at Rapid7. ⠀
Security teams need a better way to connect what they detect, what they fix, and what they can prove.
The pace of modern security operations no longer works in defenders’ favor. IBM’s Cost of a Data Breach Report 2025 found that the mean time to identify and contain a breach is now 241 days, even as AI and automation help defenders move faster. At the same time, Rapid7’s 2026 Global Threat Landscape Report shows how quickly attacker behavior is compressing the response window: exploited high and critical severity vulnerabilities more than doubled year over year, increasing 105% from 71 in 2024 to 146 in 2025, while the median time from publication to CISA KEV inclusion fell from 8.5 days to 5.0 days. This is not a future risk. It is today’s operational reality.
It also exposes a governance problem most security programs were not built to solve. Security teams are expected to demonstrate, continuously, that controls are working, that risk is being reduced, and that security investments are delivering measurable outcomes. Point-in-time audit evidence, assembled quarterly, is structurally incompatible with an environment where the threat picture changes in minutes.
The underlying issue is not a lack of effort, but a disconnect. Security data lives in one place, remediation happens in another, and evidence for auditors is assembled somewhere else. When leadership asks what changed, what was fixed, and what risk remains, teams are left stitching the story together manually producing reports that reflect where the organization was, not where it is.
Cyber GRC closes that gap by bringing governance, risk management, and compliance closer to the security data and workflows teams already rely on.
Why security operations and compliance need connected data
For years, security operations and GRC have run in parallel. One team manages threats, exposures, and remediation. Another manages policies, controls, audits, and evidence. Both aim to reduce risk, but typically without shared context or shared data.
That separation is no longer sustainable. Vulnerability exploitation rose 34% year-over-year and now accounts for 20% of all breaches, with a median of zero days between critical vulnerability publication and mass exploitation (Verizon DBIR 2025). Supply chain breaches doubled, now representing 30% of all incidents. Ransomware appeared in 44% of breaches – up 37% from the prior year.
Security leaders operating in this environment face an expectation that compliance teams were not designed to meet alone: continuous proof that controls are effective against adversaries who operate at machine speed. When AI agents can autonomously chain every phase of an attack with minimal human oversight, a quarterly audit cycle is not an assurance, but a historical record.
Why Cyber GRC matters now
Boards are no longer satisfied with compliance status reports. They want dollarized risk scenarios and evidence that remediation is actually reducing exposure -- not just that it was attempted.
Two pressures are converging. First, environmental complexity: modern infrastructure spans cloud, SaaS, remote endpoints, OT systems, and third-party providers. The perimeter is everywhere, and so is the attack surface. Second, regulatory expectation: SEC, NIS2, DORA, and CMMC now require demonstrable control effectiveness, not just documented policies. Both pressures demand a model that brings security activity, compliance readiness, and accountability into the same view.
What Cyber GRC changes for security and compliance teams
Cyber GRC changes how organizations use security data. Instead of disconnected, point-in-time artifacts, it enables teams to build governance and compliance workflows directly on top of real security telemetry – so evidence reflects the current state of the environment, not a snapshot assembled weeks before an audit.
In practice, this means connecting findings, controls, remediation activity, and evidence so teams can see what issues exist, who owns the response, how remediation is progressing, and what that means for overall readiness. This also helps address the compliance-theater problem directly: many programs are designed to pass audits rather than reduce actual exposure, creating false confidence and misallocated resources. Grounding compliance evidence in live security telemetry -- rather than manual documentation -- means teams can tell the difference between controls that are configured and controls that are working.
How connected security data strengthens compliance
Compliance has historically been treated as a separate process that happens alongside security operations. In practice, it depends on the same data. The telemetry that surfaces a critical finding also determines whether a control is operating effectively.
When evidence is generated directly from operational systems, teams spend less time assembling reports and more time improving controls. Continuous monitoring for control drift allows organizations to move from reactive audit preparation toward a consistent assurance model. Third-party risk -- now a source of 30% of all breaches -- benefits particularly, since continuous TPRM monitoring surfaces supply chain exposure in real time rather than at the next assessment cycle.
How Rapid7 Cyber GRC builds on existing security workflows
This shift does not require rebuilding security programs from the ground up. With the launch of Rapid7 Cyber GRC, customers can use the security data and workflows already connected through the Command Platform to support audits, assessments, and ongoing control validation. Capabilities such as HITRUST E1 control coverage provide continuous monitoring and automated evidence collection, while features like audit-ready user access exports and unified policy data reduce manual effort across SOC 2, NIST CSF, PAI, and other common frameworks.
When NIST CSF 2.0, MITRE ATT&CK, and FAIR-based risk quantification inform the evidence model rather than just the policy library, compliance becomes a byproduct of strong security operations -- not a parallel burden.
Rapid7 is launching Cyber GRC to connect security operations, risk, and compliance
Organizations do not need more disconnected processes for managing risk. They need a way to connect what they detect, what they fix, and what they can prove in a way that stands up to regulatory scrutiny, board-level oversight -- and keeps pace with adversaries who operate at AI speed.
That is why Rapid7 is launching Cyber GRC: to help customers bring security operations, governance, and compliance into a single, continuous view so teams can reduce risk, improve readiness, and demonstrate progress with confidence.
For current clients, reach out to your account team to get early access to Rapid7's Cyber GRC solution and help shape what comes next.
Sabeen Malik is VP, Global Government Affairs and Public Policy at Rapid7. ⠀
Security teams need a better way to connect what they detect, what they fix, and what they can prove.
The pace of modern security operations no longer works in defenders’ favor. IBM’s Cost of a Data Breach Report 2025 found that the mean time to identify and contain a breach is now 241 days, even as AI and automation help defenders move faster. At the same time, Rapid7’s 2026 Global Threat Landscape Report shows how quickly attacker behavior is compressing the response window: exploited high and critical severity vulnerabilities more than doubled year over year, increasing 105% from 71 in 2024 to 146 in 2025, while the median time from publication to CISA KEV inclusion fell from 8.5 days to 5.0 days. This is not a future risk. It is today’s operational reality.
It also exposes a governance problem most security programs were not built to solve. Security teams are expected to demonstrate, continuously, that controls are working, that risk is being reduced, and that security investments are delivering measurable outcomes. Point-in-time audit evidence, assembled quarterly, is structurally incompatible with an environment where the threat picture changes in minutes.
The underlying issue is not a lack of effort, but a disconnect. Security data lives in one place, remediation happens in another, and evidence for auditors is assembled somewhere else. When leadership asks what changed, what was fixed, and what risk remains, teams are left stitching the story together manually producing reports that reflect where the organization was, not where it is.
Cyber GRC closes that gap by bringing governance, risk management, and compliance closer to the security data and workflows teams already rely on.
Why security operations and compliance need connected data
For years, security operations and GRC have run in parallel. One team manages threats, exposures, and remediation. Another manages policies, controls, audits, and evidence. Both aim to reduce risk, but typically without shared context or shared data.
That separation is no longer sustainable. Vulnerability exploitation rose 34% year-over-year and now accounts for 20% of all breaches, with a median of zero days between critical vulnerability publication and mass exploitation (Verizon DBIR 2025). Supply chain breaches doubled, now representing 30% of all incidents. Ransomware appeared in 44% of breaches – up 37% from the prior year.
Security leaders operating in this environment face an expectation that compliance teams were not designed to meet alone: continuous proof that controls are effective against adversaries who operate at machine speed. When AI agents can autonomously chain every phase of an attack with minimal human oversight, a quarterly audit cycle is not an assurance, but a historical record.
Why Cyber GRC matters now
Boards are no longer satisfied with compliance status reports. They want dollarized risk scenarios and evidence that remediation is actually reducing exposure -- not just that it was attempted.
Two pressures are converging. First, environmental complexity: modern infrastructure spans cloud, SaaS, remote endpoints, OT systems, and third-party providers. The perimeter is everywhere, and so is the attack surface. Second, regulatory expectation: SEC, NIS2, DORA, and CMMC now require demonstrable control effectiveness, not just documented policies. Both pressures demand a model that brings security activity, compliance readiness, and accountability into the same view.
What Cyber GRC changes for security and compliance teams
Cyber GRC changes how organizations use security data. Instead of disconnected, point-in-time artifacts, it enables teams to build governance and compliance workflows directly on top of real security telemetry – so evidence reflects the current state of the environment, not a snapshot assembled weeks before an audit.
In practice, this means connecting findings, controls, remediation activity, and evidence so teams can see what issues exist, who owns the response, how remediation is progressing, and what that means for overall readiness. This also helps address the compliance-theater problem directly: many programs are designed to pass audits rather than reduce actual exposure, creating false confidence and misallocated resources. Grounding compliance evidence in live security telemetry -- rather than manual documentation -- means teams can tell the difference between controls that are configured and controls that are working.
How connected security data strengthens compliance
Compliance has historically been treated as a separate process that happens alongside security operations. In practice, it depends on the same data. The telemetry that surfaces a critical finding also determines whether a control is operating effectively.
When evidence is generated directly from operational systems, teams spend less time assembling reports and more time improving controls. Continuous monitoring for control drift allows organizations to move from reactive audit preparation toward a consistent assurance model. Third-party risk -- now a source of 30% of all breaches -- benefits particularly, since continuous TPRM monitoring surfaces supply chain exposure in real time rather than at the next assessment cycle.
How Rapid7 Cyber GRC builds on existing security workflows
This shift does not require rebuilding security programs from the ground up. With the launch of Rapid7 Cyber GRC, customers can use the security data and workflows already connected through the Command Platform to support audits, assessments, and ongoing control validation. Capabilities such as HITRUST E1 control coverage provide continuous monitoring and automated evidence collection, while features like audit-ready user access exports and unified policy data reduce manual effort across SOC 2, NIST CSF, PAI, and other common frameworks.
When NIST CSF 2.0, MITRE ATT&CK, and FAIR-based risk quantification inform the evidence model rather than just the policy library, compliance becomes a byproduct of strong security operations -- not a parallel burden.
Rapid7 is launching Cyber GRC to connect security operations, risk, and compliance
Organizations do not need more disconnected processes for managing risk. They need a way to connect what they detect, what they fix, and what they can prove in a way that stands up to regulatory scrutiny, board-level oversight -- and keeps pace with adversaries who operate at AI speed.
That is why Rapid7 is launching Cyber GRC: to help customers bring security operations, governance, and compliance into a single, continuous view so teams can reduce risk, improve readiness, and demonstrate progress with confidence.
For current clients, reach out to your account team to get early access to Rapid7's Cyber GRC solution and help shape what comes next.
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.
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.”
If you're a security leader operating in Germany, Austria, or Switzerland, you already know that compliance isn't a checkbox. It's a competitive differentiator. Rapid7 has completed BSI C5 Type 2 attestation for the Rapid7 Command Platform, including Threat Command, and it's a milestone worth unpacking.
This isn't just a badge on a webpage. It's proof that our security controls work, not just on paper, but in practice, over time.
What is BSI C5 and why does it matter?
The Cloud Computing Compliance Criteria Catalogue (C5) was developed by Germany's Federal Office for Information Security (BSI). It sets some of the most rigorous cloud security standards in the world, covering everything from data protection to operational transparency.
A Type 2 attestation is the gold standard within that framework. Unlike a point-in-time audit, Type 2 validates that security controls aren't just well-designed, but that they're actively working consistently over a sustained period. It's the difference between a security promise and a security proof.
For organizations in the DACH region, C5 is more than a nice-to-have. It's a procurement requirement for German federal agencies, critical infrastructure operators, healthcare institutions, and financial services firms. If you're operating in any of these sectors, your cloud providers need to meet this bar. Rapid7 now does.
BSI C5 Type 2 and your cloud security strategy
Whether you're evaluating security vendors, managing compliance obligations, or looking to strengthen your organization's risk posture, the question is the same: How do you know your cloud security provider actually does what it says?
BSI C5 Type 2 attestation answers that question. It's independent, rigorous, and sustained over time. While rooted in German regulatory requirements, C5 is increasingly recognized as a benchmark for secure cloud operations across Europe. It's one of the clearest signals that a cloud provider has the operational maturity to handle sensitive environments.
The Rapid7 Command Platform unifies exposure management with detection and response, giving security teams clear visibility across their attack surface. Threat Command extends that protection further, identifying and helping remediate threats across the clear, deep, and dark web. Both are now independently validated against one of the world's toughest cloud security frameworks.
Why independent validation of security controls matters
Trusting a security vendor shouldn't require a leap of faith. Independent validation exists so you have the evidence to make that call with confidence. This attestation reflects our continued investment in meeting the highest security standards for customers across Germany and the wider European market. Rapid7 has achieved a milestone that speaks directly to the conversations had every day with public sector and enterprise organizations who need more than a promise.
They need proof that a security provider's controls have been tested, verified, and proven to hold up over time. That's the kind of assurance that matters when the stakes are high.
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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.
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