CIP-015 what you need to know

The electric sector already knows CIP-015 is coming. The better question is whether utilities are using the time before October 1, 2028 to build an Internal Network Security Monitoring program that is defensible, auditable, and operationally useful.

I have spent most of my OT cybersecurity career around the power sector, from early NERC CIP program work as an asset owner, to consulting with utilities ranging from small municipalities and rural cooperatives to some of the largest power companies in the country, to now working with technology that helps organizations improve visibility and detection across IT and OT. One lesson has been consistent across all of those roles: compliance is not just about having a control in place. It is about being able to prove the control works.

That is where CIP-015 becomes important.

The standard is not simply asking utilities to deploy a tool inside the Electronic Security Perimeter and call the job done. CIP-015 is about improving the probability of detecting anomalous or unauthorized network activity so that organizations can improve response and recovery from an attack. That purpose is directly stated in the standard itself. (NERC)

The real work between now and October 2028 is not just buying technology. It is building an INSM capability that can collect the right data, detect meaningful activity, support evaluation, retain the right evidence, and protect that evidence from unauthorized deletion or modification.

Why CIP-015 exists

CIP-015 exists because perimeter security alone does not solve the internal visibility problem.

For years, many CIP controls have focused heavily on access management, segmentation, patching, logging, training, and other security practices that help reduce the likelihood of unauthorized access. Those controls still matter. But they do not fully answer what happens after an attacker, insider, compromised vendor account, misused credential, or malicious activity is already operating inside a trusted environment.

NERC’s technical rationale explains that Internal Network Security Monitoring focuses on the collection and analysis of network communications inside a “trust zone,” such as an ESP. In other words, CIP-015 is not only about defending the edge. It is about understanding what is happening inside the environment once traffic is already within the trusted zone. (NERC)

That is the internal visibility gap utilities need to close.

Why traditional security monitoring does not fully satisfy CIP-015

One mistake utilities should avoid is assuming that existing security event monitoring automatically solves CIP-015.

Many organizations already have logging programs tied to CIP-007, SIEM use cases, host-level security events, authentication logs, malware alerts, and incident response workflows. Those capabilities remain valuable, but they are not the same as Internal Network Security Monitoring.

Security event monitoring often tells you what happened on or to a system. INSM is intended to help show what is happening between systems, across network communications, devices, connections, and internal traffic patterns. That distinction is especially important in OT environments where adversaries may use legitimate pathways, valid credentials, native protocols, remote access, engineering workstations, or trusted systems to move inside the environment.

CIP-015 pushes utilities toward a different level of visibility: not just “did a system log something,” but “can we see and evaluate anomalous or unauthorized activity occurring inside the ESP?”

What CIP-015 requires

At a high level, CIP-015-1 requires three core capabilities.

Requirement R1: Monitoring internal network activity  

First, under Requirement R1, Responsible Entities must implement, using a risk-based rationale, network data feeds to monitor network activity, including connections, devices, and network communications. They must also implement one or more methods to detect anomalous network activity using those feeds, and one or more methods to evaluate detected anomalous activity to determine further actions.

Requirement R2: Retaining INSM data for investigations

Second, under Requirement R2, entities must retain INSM data associated with anomalous network activity at least until the related evaluation and action are complete. The standard also notes that entities are not required to retain INSM data that is not relevant to detected anomalous activity.

Requirement R3: Protecting monitoring data from tampering

Third, under Requirement R3, entities must protect INSM data collected for R1 and retained for R2 from unauthorized deletion or modification.

Those requirements may sound straightforward, but implementation is where the challenge begins.

What should utilities be asking themselves for CIP-015?

• Where are we collecting network data inside the ESP, and why are those feeds defensible?
• What methods are we using to detect anomalous network activity?
• How do we distinguish meaningful anomalous behavior from normal operational change?
• Who evaluates detections, and how are decisions documented?
• What data is retained, and how is it protected from unauthorized deletion or modification?
• Can we produce evidence that proves this process has worked over time?

Those answers matter because auditors will not be looking for marketing claims. They will be looking for evidence.

Why anomaly detection is central to CIP-015 compliance

One of the most important parts of CIP-015 is also one of the easiest to oversimplify: the word anomalous.

NERC’s technical rationale provides useful context. It explains that, as used in CIP-015, “anomalous” refers to unexpected, undesired, unusual, or undetermined network traffic. It also makes clear that the term does not refer to any single proprietary technology commonly marketed as “anomaly detection.”

Understanding static baselines vs true anomaly detection

A static baseline is not the same thing as meaningful anomaly detection. If a platform observes traffic for a limited period of time, assumes that observed behavior is “normal,” and then flags future deviations without deeper context, the result can be noisy, brittle, and operationally frustrating.

In real OT environments, “normal” is not fixed. Maintenance windows, vendor access, failovers, engineering changes, testing activity, backup jobs, and operational shifts can all change behavior. Detection has to keep learning and understand context. Otherwise, the organization may end up with alerts that are technically anomalous but not practically useful.

CIP-015 is not just about producing anomalies. It is about producing meaningful detections that can be evaluated, documented, and acted upon.

What should utilities consider when looking for anomaly detection tools

Some technologies were built around behavioral analysis and anomaly detection long before CIP-015 existed. What practitioners should look for is if the technology behind the phrase can identify meaningful deviations, provide context, reduce noise, and support the evaluation and evidence expectations of the standard.

Utilities should be cautious of vendor positioning that treats “anomaly” as a simple compliance keyword. This is especially important when evaluating tools historically built around signature-based, threat-based, or rule-based detection methods that are now being positioned as anomaly detection because CIP-015 uses the term.

A platform does not solve CIP-015 simply because it can baseline traffic or generate alerts when something changes.

The question is not: Can this tool create alerts?

The question is: Can this tool identify meaningful anomalous activity with enough context, prioritization, and evidence to support evaluation and response?

Why evidence and audit readiness matter for CIP-015

In NERC CIP, the control is only part of the story. Evidence is the part that proves the control existed, worked, and was followed.

That is why CIP-015 readiness should not be treated as a simple deployment project. It should be treated as a compliance operations and evidence program.

What auditors will expect utilities to prove

For R1, examples of evidence include documentation of network data feeds and the risk-based rationale for selecting them, anomalous network detection events, INSM configuration settings, communication baselines or other detection methods, methods used to evaluate anomalous activity, and actions taken in response to detected anomalies.

For R2, evidence may include documentation of the retention process, system configurations, or system-generated reports showing retention timelines sufficient to support evaluation. For R3, evidence may include documentation showing how INSM data is protected from unauthorized deletion or modification.

Common evidence gaps that can create compliance risk

If an entity implements a platform that generates noisy detections, lacks context, does not retain the right data, cannot demonstrate how data is protected, or cannot produce useful audit evidence, the issue may not become obvious until much later. By then, an organization may discover during an audit that it cannot prove what it thought it had implemented.

That is a bad place to be.

CIP evidence gaps can create exposure that goes back over time, not just to the day the audit finding is discovered. This is why utilities need to validate the process early. Do not wait until an audit cycle to find out whether your INSM approach can stand up to scrutiny.

How utilities should prepare for CIP-015 before 2028

October 2028 may sound far away, but in utility planning terms, it is not.

Utilities should already be moving through a structured readiness process.

Assessing internal network visibility across trusted environments

Start with scope. Identify the applicable High and Medium Impact BES Cyber Systems, the relevant ESPs, and the environments where INSM requirements will apply. Then map current visibility. Where do you already have useful network monitoring? Where are you relying mostly on logs, perimeter controls, or assumptions? Where do you have limited east-west visibility inside trusted environments?

Building a defensible network data feed strategy

Next, define the network data feed strategy. CIP-015 requires a risk-based rationale, so the organization should be able to explain why specific feeds were selected and how they support detection of anomalous activity across relevant connections, devices, and communications.

Validating anomaly detection workflows

Then validate the detection method. This is where utilities need to go deeper than vendor claims. Ask how the platform identifies anomalous activity. Ask how it reduces noise. Ask what context is provided for evaluation. Ask how it handles changes in normal operations. Ask what evidence is retained and how that evidence can be produced.

Testing evidence retention and protection processes

After that, build the evaluation workflow. Who reviews detections? How are anomalies classified as benign, abnormal but not suspicious, suspicious, or potentially malicious? When does an event move into CIP-008 incident response? What documentation is created during that process?

Finally, test evidence production. Utilities should be able to show detection records, configuration settings, evaluation notes, response actions, retention records, and data protection controls before an auditor asks for them.

Where Darktrace Fits into CIP-015

This is where technology matters, but only as part of the broader program.

Darktrace was built on self-learning anomaly detection long before CIP-015 created a new compliance driver around anomalous network activity. Its value is rooted in continuous behavioral understanding, multiple analytical techniques, and the ability to identify meaningful deviations across complex IT and OT environments. That matters because CIP-015 requires more than basic alerting. It requires detection that supports evaluation, evidence, and action.

This IT and OT visibility is especially important in power utility environments. High and Medium Impact environments are not made up only of industrial protocols and field devices. Control centers, operational workstations, engineering workstations, servers, remote access systems, domain services, printers, and other enterprise-class assets often sit inside or adjacent to critical operational environments. A useful INSM capability should understand a wide range of communications across both IT and OT, not only traditional industrial protocols like Modbus, DNP3, or IEC 61850.

That distinction matters because “protocol support” can mean very different things. Identifying that a protocol is present is not the same as performing deeper packet analysis that can provide behavioral context, richer protocol understanding, and meaningful detection across the communications actually used inside the environment. For CIP-015, utilities should be asking whether a platform can help evaluate activity across both enterprise and industrial communications, because real power utility environments are rarely “OT-only.”

This is also why utilities should look carefully at how vendors use the word “anomaly.” Some platforms were designed around behavioral understanding and anomaly detection long before CIP-015 created a new compliance driver. Others may now be adopting the language because the standard uses the term. The difference matters. Utilities should ask whether the platform’s detection approach is foundational to the technology, or simply a new label applied to existing signature-based, threat-based, or rule-based methods.

In OT environments, detection quality matters. Utilities do not need more noise. They need visibility into internal communications, confidence in what is normal, context when something changes, and prioritization that helps security and operations teams focus on what matters.

A strong INSM program should help utilities move from raw monitoring to operational confidence. It should support east-west visibility, better anomaly evaluation, defensible evidence retention, protection of monitoring data, and alignment between compliance and security outcomes.

That is the right way to think about CIP-015.

Not as “deploy a tool and move on.”But as “build a capability that can be trusted, operated, and proven.”

CIP-015 is about proving your INSM capability works

The CIP-015 countdown is real, but the countdown itself is not the whole story.

The real story is what utilities do with the time that remains.

Organizations that treat CIP-015 as a checkbox may be able to say they deployed something. But organizations that treat it as an opportunity to close the internal visibility gap will gain something much more valuable: better detection, better response, better evidence, and stronger operational resilience.

The question utilities should be asking now is not whether they can produce more alerts before October 2028.

The question is whether they can prove their INSM capability actually works.