What CISA’s Updated CPGs Mean for Financial Institutions

CISA’s recent update to the Cybersecurity Performance Goals (CPGs) marks an important evolution in how organizations should approach cyber resilience. While the CPGs continue to emphasize strong technical controls across Identify, Protect, Detect, Respond, and Recover, the most significant shift is the explicit elevation of Governance as a foundational pillar.

For financial institutions where cybersecurity risk is inseparable from operational, regulatory, and reputational risk, this change reinforces a long-standing reality: effective cybersecurity starts at the top.

Governance as the Foundation of Cybersecurity

By adding Governance as a first-class goal, CISA is signaling that cybersecurity is not merely an IT problem; it is an enterprise risk management issue. The new Govern domain focuses on establishing clear accountability, oversight, and decision-making structures that guide how cybersecurity is funded, prioritized, implemented, and measured.

This includes:

• Clearly defined cybersecurity roles and responsibilities across the C-suite, senior leadership, and operational teams
• Formalized cybersecurity oversight through policies, risk management strategies, and regular reviews
• Executive involvement in incident response planning, exercises, and post-incident improvements
• Explicit expectations for third parties, managed service providers, and vendors

For financial institutions, this aligns closely with regulatory expectations from FFIEC, federal banking agencies, and state regulators, all of which increasingly scrutinize governance and board oversight as indicators of cyber maturity.

From Technical Controls to Accountability

Many of the technical safeguards outlined in the CPGs, such as MFA, vulnerability management, logging, backups, and segmentation, are not new to banks. What is new is the emphasis on ensuring these controls are owned, governed, and enforced consistently across the organization.

Strong governance closes common gaps seen in financial institutions:

• Security tools deployed without clear ownership
• Policies written but not enforced or reviewed
• Incident response plans that exist on paper but aren’t exercised with leadership
• Third-party risks that are assessed once but not actively managed

By formalizing governance, institutions improve their ability to align cybersecurity investments with business priorities, regulatory obligations, and risk appetite.

Governance Strengthens Incident Response and Resilience

CISA’s governance updates also emphasize oversight of incident response planning, supply chain incident reporting, and managed service provider risk. This is particularly critical for financial institutions that rely heavily on third parties for core banking systems, cloud services, payment processing, and IT operations.

When governance is strong:

• Incident response roles are clear before a crisis occurs
• Leadership understands escalation thresholds and reporting obligations
• Communication with regulators, customers, and partners is coordinated
• Recovery decisions balance speed, safety, and regulatory compliance

In short, governance enables faster, more confident decision-making when it matters most.

A Practical, High-Impact Investment

Notably, many governance-related CPG actions are categorized by CISA as low-cost with high impact. Updating policies, clarifying responsibilities, improving oversight cadence, and integrating cybersecurity into enterprise risk management do not require new tools, but they do require leadership attention and discipline.

For financial institutions facing increasing cyber threats, regulatory pressure, and operational complexity, this is a reminder that maturity is not just about adding controls; it’s about ensuring the right people are accountable for them.

The Takeaway for Financial Institutions

CISA’s update reinforces a critical message: cybersecurity effectiveness is driven by governance. Technical controls remain essential, but without executive ownership, oversight, and alignment, even the best tools fall short.

For banks and credit unions, the expanded focus on governance provides both validation and direction. Institutions that invest in strong cybersecurity governance will be better positioned to manage risk, meet regulatory expectations, respond to incidents, and protect the trust that is foundational to the financial system.

In today’s threat environment, governance isn’t overhead; it’s a force multiplier. If your financial institution feels overwhelmed by the level of governance required to be a foundational pillar, we'd love to talk. Our vCISO services offer a Governance module that does the heavy lifting. Fill out our "contact us" form to see if it's a good solution for you!