Cybersecurity Trends Examiners May Focus on in 2026

As financial institutions move into 2026, cybersecurity examinations continue to evolve. Regulators are shifting away from purely checklist-based reviews and placing greater emphasis on governance, risk management, and operational resilience. Examiners want to see not only that controls exist, but that institutions understand their cybersecurity risk exposure and can demonstrate effective oversight.

The following trends highlight key areas examiners are likely to focus on during cybersecurity and IT examinations in 2026.

1. Governance and Risk-Based Cybersecurity Programs

Strong governance remains a foundational regulatory expectation. Examiners continue to assess whether cybersecurity risk is integrated into the institution’s overall risk management framework.

Key areas of focus include:

• Clearly defined roles and responsibilities for cybersecurity oversight
• Regular reporting to the board or appropriate committees
• Evidence that management is actively monitoring and responding to cybersecurity risk
• Risk assessments that are updated and aligned with the institution’s size, complexity, and activities

Many institutions support this approach using frameworks such as NIST CSF, which emphasizes governance and risk management as core components of an effective cybersecurity program.

2. Oversight of Artificial Intelligence and Emerging Technologies

As financial institutions adopt emerging technologies, including AI-enabled tools, examiners are increasingly focused on governance and risk management rather than the technology itself.

Institutions should be prepared to demonstrate:

• Awareness of where AI or automation is used within the environment
• Risk assessments addressing data integrity, model risk, and vendor dependency
• Oversight of third-party solutions that incorporate AI functionality
• Alignment with existing change management and vendor management processes

This expectation applies whether AI is used in cybersecurity tools, operational systems, or customer-facing solutions.

3. Identity Security and Zero Trust Concepts

Identity and access management continues to be a major examination focus, particularly as institutions rely more heavily on cloud services, remote access, and third-party integrations.

Examiners commonly review:

• Multi-factor authentication for remote and privileged access
• Least-privilege access enforcement
• Periodic user access reviews
• Monitoring and logging of privileged activity

While institutions may not formally label their architecture as “Zero Trust,” examiners increasingly expect Zero Trust principles—such as continuous verification and reduced implicit trust—to be reflected in access control practices.

4. Third-Party and Supply Chain Risk Management

Third-party risk management remains one of the most consistent areas of regulatory scrutiny. As financial institutions continue to rely on fintechs, managed service providers, and cloud vendors, examiners expect vendor risk management programs to be formal, risk-based, and well-documented.

Common examination focus areas include:

• Vendor risk tiering and due diligence processes
• Contract language addressing cybersecurity responsibilities
• Ongoing monitoring of critical vendors
• Understanding of downstream or supply chain dependencies

Institutions should be prepared to show that vendor oversight is an ongoing process—not a one-time onboarding activity.

5. Incident Response and Operational Resilience

Examiners are increasingly focused on how institutions prepare for, respond to, and recover from cybersecurity incidents.

Institutions should expect review of:

1. Incident response plans and procedures
2. Tabletop exercises or testing results
3. Evidence that lessons learned are incorporated into program improvements
4. Coordination with business continuity and disaster recovery planning

Operational resilience—how quickly systems and services can be restored following a disruption—continues to receive heightened attention.

6. Security Awareness and Human Risk

Despite advances in technology, human error remains a leading contributor to cybersecurity incidents. As a result, examiners continue to closely evaluate security awareness programs.

Key areas include:

• Ongoing, role-based training
• Phishing and social engineering testing results
• Metrics used to measure program effectiveness
• Processes for addressing repeat failures or high-risk users

High-risk roles, such as those with privileged access or financial authority, often receive additional scrutiny.

7. Documentation and Evidence

Across all areas, examiners consistently emphasize documentation. Policies, procedures, risk assessments, testing results, and management reports should clearly demonstrate that controls are operating as intended. Well-maintained documentation helps support compliance and demonstrates management’s understanding and ownership of cybersecurity risk.

Cybersecurity examinations in 2026 will continue to focus on how well financial institutions understand and manage risk—not simply whether controls exist. Contact us to discuss your institution’s exam readiness, perform a NIST CSF+ Assessment, or check out our other blog posts for additional insights on cybersecurity and regulatory expectations.