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October 31, 2024

Understanding NERC CIP-015 Requirements

Learn about NERC CIP-015 and its internal network security monitoring requirements. Discover how to ensure compliance and enhance your security posture.
Inside the SOC
Darktrace cyber analysts are world-class experts in threat intelligence, threat hunting and incident response, and provide 24/7 SOC support to thousands of Darktrace customers around the globe. Inside the SOC is exclusively authored by these experts, providing analysis of cyber incidents and threat trends, based on real-world experience in the field.
Written by
Daniel Simonds
Director of Operational Technology
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31
Oct 2024

Background: NERC CIP-015

In January of 2023 the Federal Energy Regulatory Commission (FERC) released FERC Order 887 which addresses a critical security gap in Critical Infrastructure Protection (CIP) standards, the lack of internal network security monitoring (INSM).

The current NERC CIP standards only require solutions that use traditional detection systems that identify malicious code based on known rules and signatures. The new legislation will now require electric cooperatives to implement INSMs to detect malicious activity in east-west network traffic. INSMs establish a baseline of network activity and detect anomalies that would bypass traditional detection systems, improving an organization’s ability to detect novel threats. Without INSM, organizations have limited visibility into malicious activities inside their networks, leaving them vulnerable if attackers breach initial defenses like firewalls and anti-virus software.

Implementation of NERC CIP-015

Once approved, Bulk Electronic Systems (BESs) will have 36 months to implement INSM, and medium-impact BESs with external routable connectivity (ERC) will have 60 months to do so.

While the approval of the NERC CIP-015 requirements have not been finalized, preparation on the part of electric cooperatives should start as soon as possible. Darktrace is committed to helping electric cooperatives meet the requirements for INSM and help reach compliance standards.

Why is internal network security monitoring important?

NERC CIP-015 aims to enhance the detection of anomalies or unauthorized network activity within CIP environments, underscoring the importance of monitoring East-West traffic within trust zones. This approach enables faster response and recovery times.

INSMs are essential to detecting threats that bypass traditional defenses. For example, insider threats, sophisticated new attack techniques, and threats that exploit compromised credentials—such as those obtained through phishing or other malicious activities—can easily bypass traditional firewalls and antivirus software. These threats either introduce novel methods or leverage legitimate access, making them difficult to detect.

INSMs don’t rely on rules and signatures to detect anomalous activity, they spot abnormalities in network traffic and create alerts based on this activity making them vital to detecting sophisticated threats. Additionally, INSM sits behind the firewall and provides detections utilizing the passive monitoring of east west and north south traffic within the enforcement boundary.

Buyers should be aware of the discrepancies between different INSMs. Some systems require constant tuning and updating, external connectivity forcing holes in segmentation or have intrusive deployments that put sensitive OT assets at risk.

What are the NERC CIP-015 requirements?

The goal of this directive is to ensure that cyber threats are identified early in the attack lifecycle by mandating implementation of security systems that detect and speed up mitigation of malicious activity.

The requirements are divided into three sections:

  • Network security monitoring
  • Data retention for anomalous activity
  • Data protection

NERC CIP-015 emphasizes the importance of having documented processes and evidence of implementation, with a focus on risk-based monitoring, anomaly detection, evaluation, retention of data, and protection against unauthorized access. Below is a breakdown of each requirement.

R1: Network Security Monitoring

The NERC CIP-015 requires the implementation of and a documented process for monitoring networks within Electronic Security Perimeters (ESPs) that contain high and medium impact BES Cyber Systems.

Key parts:

Part 1.1: Use a risk-based rationale to implement network data feeds that monitor connections, devices, and communications.

Part 1.2: Detect anomalous network activity using the data feeds.

Part 1.3: Evaluate the anomalous activity to determine necessary actions.

M1: Evidence for R1 Implementation: Documentation of processes, including risk-based rationale for data collection, detection events, configuration settings, and network baselines.

Incorporating automated solutions for network baselining is essential for effective internal monitoring, especially in diverse environments like substations and control centers. Each environment requires unique baselines—what’s typical for a substation may differ significantly from a control center, making manual monitoring impractical.

A continuous internal monitoring solution powered by artificial intelligence (AI) simplifies this challenge by instantly detecting all connected assets, dynamically learning the environment’s baseline behavior, and identifying anomalies in real-time. Unlike traditional methods, Darktrace’s AI-driven approach requires no external connectivity or repeated tuning, offering a seamless, adaptive solution for maintaining secure operations across all environments.

R2: Data Retention for Anomalous Activity

Documented processes must be in place to retain network security data related to detected anomalies until the required actions are completed.

Note: Data that does not relate to detected anomalies (Part 1.2) is not required to be retained.

M2: Evidence for Data Retention (R2): Documentation of data retention processes, system configurations, or reports showing compliance with R2.

R3: Data Protection: Implement documented processes to protect the collected security monitoring data from unauthorized deletion or modification.

M3: Evidence for Data Protection (R3): Documentation demonstrating how network security monitoring data is protected from unauthorized access or changes.

How to choose the right INSM for your organization?

Several vendors will offer INSM, but how do you choose the right solution for your organization?

Here are seven questions to help you get started evaluating potential INSM vendors:

  1. How does the solution help with ongoing compliance and reporting including CIP-015? Or any other regulations we comply with?
  2. Does the solution provide real-time monitoring of east-west traffic across critical systems? And what kind of threats has it proven capable of finding?
  3. How deep is the traffic visibility—does it offer Layer 7 (application) insights, or is it limited to Layers 3-4?
  4. Is the solution compatible with our existing infrastructure (firewalls, IDS/IPS, SIEM, OT networks)?
  5. Is this solution inline, passive, or hybrid? What impact will it have on network latency?
  6. Does the vendor have experience with electric utilities or critical infrastructure environments?
  7. Where and how are logs and monitoring data stored?

How Darktrace helps electric utilities with INSM requirements

Darktrace's ActiveAI Security Platform is uniquely designed to continuously monitor network activity and detect anomalous activity across both IT and OT environments successfully detecting insider threats and novel ransomware, while accelerating time to detection and incident reporting.

Most INSM solutions require repeated baselining, which creates more work and increases the likelihood of false positives, as even minor deviations trigger alerts. Since networks are constantly changing, baselines need to adjust in real time. Unlike these solutions, Darktrace does not depend on external connectivity or cloud access over the public internet. Our passive network analysis requires no agents or intrusive scanning, minimizing disruptions and reducing risks to OT systems.

Darktrace's AI-driven threat detection, asset management, and incident response capabilities can help organizations comply with the requirements of NERC CIP-015 for internal network security monitoring and data protection. Built specifically to deploy in OT environments, Darktrace / OT comprehensively manages, detects, evaluates, and protects network activity and anomalous events across IT and OT environments, facilitating adherence to regulatory requirements like data retention and anomaly management.

See how INSM with Darktrace can enhance your security operations, schedule a personalized demo today.

Disclaimer

The information provided in this blog is intended for informational purposes only and reflects Darktrace’s understanding of the NERC CIP-015 INSM requirements as of the publication date. While every effort has been made to ensure the accuracy and reliability of the content, Darktrace makes no warranties or representations regarding its accuracy, completeness, or applicability to specific situations. This blog does not constitute legal or compliance advice and readers are encouraged to consult with qualified professionals for guidance specific to their circumstances. Darktrace disclaims any liability for actions taken or not taken based on the information contained herein.

References

1.     https://www.nerc.com/pa/Stand/Reliability%20Standards/CIP-015-1.pdf

Inside the SOC
Darktrace cyber analysts are world-class experts in threat intelligence, threat hunting and incident response, and provide 24/7 SOC support to thousands of Darktrace customers around the globe. Inside the SOC is exclusively authored by these experts, providing analysis of cyber incidents and threat trends, based on real-world experience in the field.
Written by
Daniel Simonds
Director of Operational Technology

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Email

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July 24, 2026

Darktrace / EMAIL Expands Behavioral Defense Across Email and Collaboration Workflows

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Email and collaboration tools do more than carry messages. They are where organizations approve payments, share sensitive data, reset credentials, and make thousands of everyday decisions. Increasingly, they are interfaces through which humans direct AI agents in their daily activity. Email, Slack and Teams are high volume, rich with sensitive data, and an easy place to hide malicious activity.

The opportunity isn’t lost on bad actors. Darktrace / EMAIL detected more than 32 million high-confidence phishing emails globally in 2025, and 70% of those messages passed DMARC authentication.  Phishing is increasingly difficult to detect and familiar trust signals alone are not enough. People and security teams need to understand how a message fits the normal behavior of the sender, recipient, and organization. They also need to correlate activity across platforms to spot threats that span multiple channels.

To effectively secure against today’s evolved threats, security teams need to act at two levels: they need to help each employee make a safer decision ‘in the moment’, and they need to understand the wider patterns that may expose the business to risk.

Darktrace is introducing four new capabilities in Darktrace / EMAIL to address both challenges. The new features explain suspicious content more clearly to end users, strengthen the capabilities of Darktrace / Adaptive Human Defense with richer guidance, let organizations define their own patterns for detecting sensitive data in messages, and give security teams a process-level view of risk across email and collaboration workflows.

Darktrace / EMAIL Inbox Analysis highlights risky content within your emails

A warning is more useful when it explains what the user should look at. To help do that, we’ve expanded Darktrace / EMAIL’s Inbox Analysis Add-In to highlight potentially dangerous content within the body of emails that Darktrace / EMAIL flags as potentially suspicious or high risk.  

The add-in can highlight language designed to create urgency, financial references, requests for payment, suspicious links, and content that is unusual for the sender. Each highlighted element includes a pop up that explains why it may be suspicious. Instead of asking an employee to accept a verdict without context, the analysis helps them examine the message and make a more informed decision.

Enhanced Just-In-Time Training Banners in Darktrace / Adaptive Human Defense

Enhanced Just-In-Time Training Banners build on the same principle. The banners now include a contextual header, actionable advice, and specific detection context. This gives employees more useful guidance at the point of risk without adding unnecessary information or cognitive load.

Together, the capabilities help turn a warning into a short learning moment. Employees can see what looks unusual, understand what action to take, and build their judgment.

Custom Sensitive Data Detection in Darktrace / EMAIL - Data Loss Prevention

Sensitive data is different for every business. Standard categories such as payment card details or government identifiers matter, but organizations also have their own customer codes, project names, research formats, account structures, and internal identifiers.

Custom Sensitive Data Detection in Darktrace / EMAIL - Data Loss Prevention allows administrators to write custom expressions for the data their organization needs to protect. Matched content can trigger existing model actions and data loss prevention (DLP) workflows, extending Darktrace's DLP capabilities.

This extends data loss detection beyond a fixed library of common data types. Security teams can apply controls to information that is sensitive in the context of their own organization and adapt those controls as the business changes.

Introducing Email and Collaboration Workflow Risk Posture Dashboards

Some of the most important risks are not isolated events. They are repeated ways of working that create an opening for error, misuse, or attack. For example, a payment request may be one suspicious message, but a recurring approval workflow that relies on weak verification is a business process risk.

The new Email and Collaboration Workflow Risk Posture Dashboard analyzes email and collaboration data across Email, Microsoft Teams, Slack and Zoom to provide a process-level view of risk in the organization. These may include financial authorization workflows, sensitive data sharing patterns, and activity that could expose credentials.

The dashboard brings these patterns into a view and provides actionable recommendations. This helps security teams determine where to investigate or strengthen controls, where ownership needs to be clarified, and where the business may need to change a risky process. It gives CISOs a clearer view of how human and communication risk is embedded in everyday operations, not only where individual alerts occur.

Behavior connects the individual decision to the wider risk

These capabilities build on Darktrace’s unique behavioral approach to security. We use Adaptive AI to learn how people and AI normally behave within an organization, creating the context needed to recognize when activity changes.

Within the Darktrace Behavioral Defense Platform, Darktrace / EMAIL helps protect people against phishing, account takeover, data exfiltration, and human risk across email and collaboration tools. The new capabilities extend that protection in both directions. They give employees clearer context for the decision in front of them, while giving security leaders a broader view of the workflows and behavior that create risk across the organization.

The result is not simply more alerts. It is a better understanding of why something is risky, what action to take, and where the organization can reduce risk before a familiar process becomes an easy route for an attacker.

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About the author
Carlos Gray
Senior Product Marketing Manager, Email

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AI

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July 24, 2026

When Guardrails Break: Why Securing AI Requires Behavioral Detection and Autonomous Containment

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Bottom line up front: Governance, guardrails, identity controls, and secure development are necessary to secure AI, but they are not sufficient. AI systems are probabilistic, adaptive, and non-deterministic. Therefore, organizations need two additional layers of security:

  1. Behavioral-based detection that can identify when AI begins to act outside its intended purpose; and  
  2. Surgical, explainable autonomous containment that can stop risky activity before it causes material damage.  

That capability depends on multiple specialized AI models working together, not one LLM making every decision.

Organizations are embedding AI into development, business operations, and security workflows faster than most security programs can adapt. The risk is no longer limited to the model. It extends across prompts, data, identities, agents, memory, APIs, tools, permissions, and the trust relationships connecting them.

In my recent blog, Securing AI: Analysis of the Complete Security Stack with Governance and Controls, I outlined a defense-in-depth strategy spanning governance, identity, data security, secure development, runtime detection, autonomous containment, and recovery. The most urgent requirement across that architecture is the ability to understand how AI behaves in practice and contain it when that behavior becomes risky.  

Why non-deterministic systems require behavioral-based detection

Traditional controls remain foundational. Organizations need least privilege, strong identity controls, secure-by-design architecture, data governance, AI inventories, guardrails, testing, and clear boundaries on autonomy.

But deterministic controls, which assume predictable and repeatable behavior, cannot fully secure non-deterministic systems, where the same input may not always produce the same outcome.

AI agents can interpret the same instruction differently, chain individually authorized actions into an unsafe outcome, or pursue a legitimate goal through a method the organization did not anticipate. One of the most recent examples of this is the incident that OpenAI and Hugging Face jointly disclosed, where an autonomous agent escaped its intended testing boundaries and compromised Hugging Face infrastructure.  

An agent may have permission to access data and invoke a tool, but that does not mean every use of that access is appropriate. It is not enough to know whether an action is allowed. Organizations need to know whether it makes sense.

  • Is this normal for this agent?  
  • Is it acting within its intended purpose?  
  • Is it accessing unusual data, invoking an unexpected tool, or beginning to drift?  
  • Do a series of ordinary-looking actions become risky when viewed together?

Behavioral-based detection specific to an environment or organization with an understanding of context and risk enables provides the needed detection engineering for AI systems. It learns normal activity across people, systems, data, devices, and AI agents, then identifies deviations and evaluates their risk, intent, and context. This enables detection of misuse, abuse, compromise, manipulation, and unintended behavior even when no known attack signature or explicit policy violation exists.

Why accuracy is the foundation for SOC optimization

AI will only improve the SOC if it produces accurate, explainable, and actionable outcomes.

If analysts must manually validate every AI-generated finding because they cannot understand the evidence or confidence behind it, automation has not reduced workload. It has moved the workload. False positives increase fatigue. False negatives cause the most risk and damage to organizations. Inaccurate autonomous actions can disrupt critical operations.

Accuracy is therefore more than a model-performance metric. It is the prerequisite for analyst trust, SOC optimization, and safe autonomous response.

That accuracy is unlikely to come from one model.

Generative AI is valuable for natural-language analysis, summarization, and human interaction. But an LLM should not be the sole analytical engine for behavioral-based detection, investigation, risk assessment, and containment. Interpretability and consistency are required for high-consequence security decisions.

A stronger architecture uses multiple specialized AI systems collaboratively:  

  • Behavioral models can establish normal activity.  
  • Unsupervised learning can identify novel anomalies.  
  • Graph analysis can evaluate relationships among agents, identities, systems, and tools.  
  • Other models can correlate events, investigate competing hypotheses, and assess risk.  
  • Semantic models can analyze language where behavior-based language analysis is needed but this can be used in tandem with vector embeddings, graph neural networks, and a variety of other AI systems.

Each model contributes a different analytical perspective. Their outputs can corroborate one another, improving accuracy and creating a more reliable basis for response. The objective is not one model operating as an oracle. It is layered, adaptive intelligence designed to produce decisions the SOC can understand and trust.

Autonomous containment is required to secure autonomous systems

Many SOCs remain hesitant to trust LLM-based agents with autonomous containment. That concern is reasonable. A poorly selected response can isolate the wrong asset, stop a critical workflow, block a legitimate identity, or create more operational damage than the original incident.

But relying exclusively on human response is also not viable.

AI systems can operate at machine speed. They can expose sensitive data, execute workflows, modify records, call tools, or propagate actions across connected systems before an analyst can investigate and intervene. The behavior may be unintentional, the result of an agent optimizing toward a goal, or caused by misuse, compromise, prompt injection, or offensive AI.

Intent affects the investigation. It does not change the need to stop the damage.

Organizations need autonomous response, but it must be surgical and explainable. The objective is not to shut down an entire agent, user, application, or business process whenever an anomaly occurs. It is to interrupt the specific risky behavior: block an unusual connection, constrain a tool call, stop an abnormal data transfer, or temporarily limit an agent when it is performing anomalous, risky activity.  

That buys humans time. It stops the spread, limits damage, and allows the SOC to investigate without unnecessarily disrupting the business.

Layered, Adaptive AI provides a path forward

Darktrace has spent more than a decade researching and operationalizing layered, behavioral, Adaptive AI that learns a specific organization rather than relying only on historic attacks or predefined signatures.

The approach is designed to understand normal behavior, identify anomalous activity, assess its risk, correlate related events, autonomously investigate, and, when necessary, apply targeted containment while normal operations continue.

That sequence matters. Autonomous response cannot simply be added to the end of an LLM workflow. Trusted containment depends on broad visibility, continuous behavioral understanding, multiple analytical techniques, risk and context evaluation, autonomous investigation, explainability, and precise response actions.

This represents a more responsible model for security autonomy: not automation for its own sake, but controlled autonomy built to improve security outcomes and protect business operations.

Security must enable AI adoption

The answer for security teams is not to block AI. Organizations are adopting it to improve productivity, accelerate development, and create new business value.

But innovation without behavioral detection and autonomous containment is not sustainable.

Organizations should continue investing in governance, identity, least privilege, data security, secure MLOps, guardrails, testing, evaluation, validation, verification, kill switches, rollback, and forensic readiness. At the same time, they cannot wait for every governance program to mature before addressing runtime risk.

Behavioral-based detection and autonomous containment provide an immediate layer of resilience. They allow organizations to detect exploitation and risky AI behavior they did not anticipate, contain it at machine speed, and preserve human control over broader remediation.

The future of AI security will not be defined by a single model making every decision. It will be defined by multiple specialized AI systems working collaboratively, with sufficient accuracy, transparency, and context to support trusted autonomous action.

Surgical, explainable autonomous containment is no longer a future capability. It is a requirement for scaling AI securely today.

Learn how to build a defense-in-depth strategy for securing AI at scale in our talk at Black Hat on August 5 at 3:15 PM.  

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About the author
Nicole Carignan
SVP, Security & AI Strategy, Field CISO
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