Blog
/
OT
/
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
Default blog imageDefault blog imageDefault blog imageDefault blog imageDefault blog imageDefault blog image
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

More in this series

No items found.

Blog

/

Network

/

April 2, 2026

How Chinese-Nexus Cyber Operations Have Evolved – And What It Means For Cyber Risk and Resilience 

Chinese-Nexus Cyber OperationsDefault blog imageDefault blog image

Cybersecurity has traditionally organized risk around incidents, breaches, campaigns, and threat groups. Those elements still matter—but if we fixate on individual incidents, we risk missing the shaping of the entire ecosystem. Nation‑state–aligned operators are increasingly using cyber operations to establish long-term strategic leverage, not just to execute isolated attacks or short‑term objectives.  

Our latest research, Crimson Echo, shifts the lens accordingly. Instead of dissecting campaigns, malware families, or actor labels as discrete events, the threat research team analyzed Chinese‑nexus activity as a continuum of behaviors over time. That broader view reveals how these operators position themselves within environments: quietly, patiently, and persistently—often preparing the ground long before any recognizable “incident” occurs.  

How Chinese-nexus cyber threats have changed over time

Chinese-nexus cyber activity has evolved in four phases over the past two decades. This ranges from early, high-volume operations in the 1990s and early 2000s to more structured, strategically-aligned activity in the 2010s, and now toward highly adaptive, identity-centric intrusions.  

Today’s phase is defined by scale, operational restraint, and persistence. Attackers are establishing access, evaluating its strategic value, and maintaining it over time. This reflects a broader shift: cyber operations are increasingly integrated into long-term economic and geopolitical strategies. Access to digital environments, specifically those tied to critical national infrastructure, supply chains, and advanced technology, has become a form of strategic leverage for the long-term.  

How Darktrace analysts took a behavioral approach to a complex problem

One of the challenges in analyzing nation-state cyber activity is attribution. Traditional approaches often rely on tracking specific threat groups, malware families, or infrastructure. But these change constantly, and in the case of Chinese-nexus operations, they often overlap.

Crimson Echo is the result of a retrospective analysis of three years of anomalous activity observed across the Darktrace fleet between July 2022 and September 2025. Using behavioral detection, threat hunting, open-source intelligence, and a structured attribution framework (the Darktrace Cybersecurity Attribution Framework), the team identified dozens of medium- to high-confidence cases and analyzed them for recurring operational patterns.  

This long-horizon, behavior-centric approach allows Darktrace to identify consistent patterns in how intrusions unfold, reinforcing that behavioral patterns that matter.  

What the data shows

Several clear trends emerged from the analysis:

  • Targeting is concentrated in strategically important sectors. Across the dataset, 88% of intrusions occurred in organizations classified as critical infrastructure, including transportation, critical manufacturing, telecommunications, government, healthcare, and Information Technology (IT) services.  
  • Strategically important Western economies are a primary focus. The US alone accounted for 22.5% of observed cases, and when combined with major European economies including Germany, Italy, Spain and the UK, over half of all intrusions (55%) were concentrated in these regions.  
  • Nearly 63% of intrusions of intrusions began with the exploitation of internet-facing systems, reinforcing the continued risk posed by externally exposed infrastructure.  

Two models of cyber operations

Across the dataset, Chinese-nexus activity followed two operational models.  

The first is best described as “smash and grab.” These are short-horizon intrusions optimized for speed. Attackers move quickly – often exfiltrating data within 48 hours – and prioritize scale over stealth. The median duration of these compromises is around 10 days. It’s clear they are willing to risk detection for short-term gain.  

The second is “low and slow.” These operations were less prevalent in the dataset, but potentially more consequential. Here, attackers prioritize persistence, establishing durable access through identity systems and legitimate administrative tools, so they can maintain access undetected for months or even years. In one notable case, the actor had fully compromised the environment and established persistence, only to resurface in the environment more than 600 days after. The operational pause underscores both the depth of the intrusion and the actor’s long‑term strategic intent. This suggests that cyber access is a strategic asset to preserve and leverage over time, and we observed these attacks most often inin sectors of the high strategic importance.  

It’s important to note that the same operational ecosystem can employ both models concurrently, selecting the appropriate model based on target value, urgency, intended access. The observation of a “smash and grab” model should not be solely interpreted as a failure of tradecraft, but instead an operational choice likely aligned with objectives. Where “low and slow” operations are optimized for patience, smash and grab is optimized for speed; both seemingly are deliberate operational choices, not necessarily indicators of capability.  

Rethinking cyber risk

For many organizations, cyber risk is still framed as a series of discrete events. Something happens, it is detected and contained, and the organization moves on. But persistent access, particularly in deeply interconnected environments that span cloud, identity-based SaaS and agentic systems, and complex supply chain networks, creates a major ongoing exposure risk. Even in the absence of disruption or data theft, that access can provide insight into operations, dependencies, and strategic decision-making. Cyber risk increasingly resembles long-term competitive intelligence.  

This has impact beyond the Security Operations Center. Organizations need to shift how they think about governance, visibility, and resilience, and treat cyber exposure as a structural business risk instead of an incident response challenge.  

What comes next

The goal of this research is to provide a clearer understanding of how these operations work, so defenders can recognize them earlier and respond more effectively. That includes shifting from tracking indicators to understanding behaviors, treating identity providers as critical infrastructure risks, expanding supplier oversight, investing in rapid containment capabilities, and more.  

Learn more about the findings of Darktrace’s latest research, Crimson Echo: Understanding Chinese-nexus Cyber Operations Through Behavioral Analysis, by downloading the full report and summaries for business leaders, CISOs, and SOC analysts here.  

Continue reading
About the author
Nathaniel Jones
VP, Security & AI Strategy, Field CISO

Blog

/

Proactive Security

/

April 1, 2026

AI-powered security for a rapidly growing grocery enterprise

Default blog imageDefault blog image

Protecting a complex, fast-growing retail organization

For this multi-banner grocery holding organization, cybersecurity is considered an essential business enabler, protecting operations, growth, and customer trust. The organization’s lean IT team manages a highly distributed environment spanning corporate offices, 100+ stores, distribution centers and  thousands of endpoints, users, and third-party connections.

Mergers and acquisitions fueled rapid growth, but they also introduced escalating complexity that constrained visibility into users, endpoints, and security risks inherited across acquired environments.

Closing critical visibility gaps with limited resources

Enterprise-wide visibility is a top priority for the organization, says the  Vice President of Information Technology. “We needed insights beyond the perimeter into how users and devices were behaving across the organization.”

A security breach that occurred before the current IT leadership joined the company reinforced the urgency and elevated cybersecurity to an executive-level priority with a focus on protecting customer trust. The goal was to build a multi-layered security model that could deliver autonomous, enterprise-wide protection without adding headcount.

Managing cyber risk in M&A

Mergers and acquisitions are central to the grocery holding company’s growth strategy. But each transaction introduces new cyber risk, including inherited network architectures, inconsistent tooling, excessive privileges, and remnants of prior security incidents that were never fully remediated.

“Our M&A targets range from small chains with a single IT person and limited cyber tools to large chains with more developed IT teams, toolsets and instrumentation,” explains the VP of IT. “We needed a fast, repeatable, and reliable way to assess cyber risk before transactions closed.”

AI-driven security built for scale, speed, and resilience

Rather than layering additional point tools onto an already complex environment, the retailer adopted the Darktrace ActiveAI Security Platform™ in 2020 as part of a broader modernization effort to improve resilience, close visibility gaps, and establish a security foundation that could scale with growth.

“Darktrace’s AI-driven approach provided the ideal solution to these challenges,” shares the VP of IT. “It has empowered our organization to maintain a robust security strategy, ensuring the protection of our network and the smooth operation of our business.”

Enterprise-wide visibility into traffic  

By monitoring both north-south and east-west traffic and applying Self-Learning AI, Darktrace develops a dynamic understanding of how users and devices normally behave across locations, roles, and systems.

“Modeling normal behavior across the environment enables us to quickly spot behavior that doesn’t fit. Even subtle changes that could signal a threat but appear legitimate at first glance,” explains the VP of IT.

Real-time threat containment, 24/7

Adopting autonomous response has created operational breathing room for the security team, says the company’s Cybersecurity  Engineer.

“Early on, we enabled full Darktrace autonomous mode and we continue to do so today,” shares the IT Security Architect. “Allowing the technology to act first gives us the time we need to investigate incidents during business hours without putting the business at risk.”

Unified, actionable view of security ecosystem

The grocery retailer integrated Darktrace with its existing security ecosystem of firewalls, vulnerability management tools, and endpoint detection and response, and the VP of IT described the adoption process as “exceptionally smooth.”

The team can correlate enterprise-wide security data for a unified and actionable picture of all activity and risk. Using this “single pane of glass” approach, the retailer trains Level 1 and Level 2 operations staff to assist with investigations and user follow-ups, effectively extending the reach of the security function without expanding headcount.

From reactive defense to security at scale

With Darktrace delivering continuous visibility, autonomous containment, and integrated security workflows, the organization has strengthened its cybersecurity posture while improving operational efficiency. The result is a security model that not only reduces risk, but also supports growth, resilience, and informed decision-making at the business level.

Faster detection, faster resolution

With autonomous detection and response, the retailer can immediately contain risk while analysts investigate and validate activity. With this approach, the company can maintain continuous protection even outside business hours and reduce the chance of lateral spread across systems or locations.

Enterprise-grade protection with a lean team

From cloud environments to clients to SaaS collaboration tools, Darktrace provides holistic autonomous AI defense, processing petabytes of the organization’s network traffic and investigating millions of individual events that could be indicative of a wider incident.

Today, Darktrace autonomously conducts the majority of all investigations on behalf of the IT team, escalating only a tiny fraction for analyst review. The impact has been profound, freeing analysts from endless alerts and hours of triage so they can focus on more valuable, proactive, and gratifying work.

“From an operational perspective, Darktrace gives us time back,” says the Cybersecurity Engineer. More importantly, says the VP of IT, “it gives us peace of mind that we’re protected even if we’re not actively monitoring every alert.”

A strategic input for M&A decision-making

One of the most strategic outcomes has been the role of cybersecurity on M&A. 90 days prior to closing a transaction, the security team uses Darktrace alongside other tools to perform a cyber risk assessment of the potential acquisition. “Our approach with Darktrace has consistently identified gaps and exposed risks,” says the VP of IT, including:

  • Remnants of previous incidents that were never fully remediated
  • Network configurations with direct internet exposure
  • Excessive administrative privileges in Active Directory or on critical hosts

While security findings may not alter deal timelines, the VP of IT says they can have enormous business implications. “With early visibility into these risks, we can reduce exposure to inherited cyber threats, strengthen our position during negotiations, and establish clear remediation requirements.”

A security strategy built to evolve with the business

As the holding group expands its cloud footprint, it will extend Darktrace protections into Azure, applying the same AI-driven visibility and autonomous response to cloud workloads. The VP of IT says Darktrace's evolving capabilities will be instrumental in addressing the organization’s future cybersecurity needs and ability to adapt to the dynamic nature of cloud security.

“With Darktrace’s AI-driven approach, we have moved beyond reactive defense, establishing a resilient security foundation for confident expansion and modernization.”

Continue reading
About the author
Your data. Our AI.
Elevate your network security with Darktrace AI