However, the strategies and implementations that are also due on July 16, 2027, require CySO-level understanding of cybersecurity principles or you will end up falling short. Therefore, MAD Security recommends immediate identification and engagement of in-house or outsourced cybersecurity expertise.
This isn’t a box-checking exercise. The CySO plays a foundational role in your security posture and regulatory readiness. Selecting the wrong person or treating the role as just another IT duty can lead to compliance gaps and unmanaged risk. The right CySO not only understands technology, but also bridges the gap between operational resilience, risk management, and regulatory obligations.
This blog post outlines what the Final Rule and its FAQs say about the CySO, why this role must go beyond IT, and what qualifications, training, and leadership traits you should look for to make the right choice.
The CySO serves as the primary point of contact for all cybersecurity matters, overseeing risk management, implementing security policies, and coordinating with regulators. They also support the execution of a Cybersecurity Framework (CSF), typically aligned with the Coast Guard Final Rule, CISA Cybersecurity Protection Goals, and the broader NIST Cybersecurity Framework.
The FAQs clarify that the CySO doesn’t need to be an internal employee. Organizations may designate a qualified contractor or third party so long as that individual fulfills the responsibilities and meets the required qualifications.
This isn’t a ceremonial title; it’s a compliance-critical leadership role requiring technical expertise, operational awareness, and strategic oversight.
Designating your current FSO, IT manager, or system administrator as your CySO might seem convenient but it’s usually ineffective. Cybersecurity leadership is not the same as IT operations or Facilities Security. Treating them as interchangeable can result in regulatory missteps and operational vulnerabilities.
Many IT professionals excel at maintaining systems, but the CySO must lead to governance, risk, and compliance efforts. Assigning an unqualified or overburdened IT staff member to this role often leads to:
| Incomplete or outdated policies | |
| Misalignment with cybersecurity frameworks | |
| Poor incident response readiness | |
| Gaps in regulatory documentation and reporting |
There’s also a potential conflict of interest when IT is tasked with overseeing its own security practices. An independent cybersecurity governance function ensures objectivity, accountability, and regulatory alignment.
Your CySO should be someone who understands both cybersecurity and organizational risk and who can lead at the strategic level.
A successful CySO combines hands-on cybersecurity experience with strong risk management and governance capabilities. They must not only understand technical threats but also know how to mitigate them within a regulated operational environment. They also need to be a seasoned leader who can effectively communicate risks to the CEO and understand where cyber risks fit in from a priority perspective with other enterprise risks.
Look for someone with practical security experience, combined with knowledge of risk-based frameworks such as NIST and ISO. Your CySO should understand why controls matter not just how to implement them.
The CySO must communicate effectively with:
| Executive leadership to support informed risk decisions | |
| IT teams to ensure proper control implementation | |
| Compliance officers or Facility Security Officers (FSOs) to ensure alignment with audits and documentation |
This role requires more than technical acumen; it demands business and regulatory fluency.
Your CySO should understand:
| Cybersecurity frameworks (Coast Guard Final Rule, NIST CSF, IEC 62443) | |
| Incident response planning and documentation | |
| Access control, audit logging, and technical safeguards | |
| Assessment and reporting workflows required for compliance |
Your CySO will often be the face of cybersecurity to regulators and internal stakeholders. Strong communication and documentation practices are essential not just for clarity, but for audit readiness.
Ultimately, the CySO must be a cybersecurity leader, not just a technician.
When designating a Cybersecurity Officer (CySO) to meet the Maritime Cybersecurity Final Rule requirements, credentials matter. The right certifications and training ensure your CySO has the technical expertise, governance knowledge, and regulatory awareness to lead your maritime cybersecurity program with confidence.
Certifications matter when assessing CySO qualifications. Look for vendor-neutral credentials that validate both technical capability and governance expertise, including:
| CISSP (Certified Information Systems Security Professional) | |
| CISM (Certified Information Security Manager) | |
| CEH (Certified Ethical Hacker) | |
| CMMC Registered Practitioner (RP) especially relevant for DoD contractors | |
| CompTIA Security+ / CySA+ – foundational but valuable |
Maritime operators deal with Operational Technology (OT) systems daily. Your CySO should be familiar with ISA/IEC 62443, the leading framework for securing OT environments like port control and vessel management systems.
The best CySOs stay ahead of emerging threats through ongoing education. Sector-specific training in maritime cybersecurity, ICS, or supply chain risk management adds extra value.
While product certifications (e.g., Microsoft, Cisco) are helpful for IT roles, the CySO should be grounded in framework-based governance and risk not tool configuration.
For port and vessel operators, designating a qualified CySO isn’t just about meeting a deadline; it’s about building a resilient, compliant cybersecurity program.
The right CySO brings accountability, alignment, and operational readiness to your cybersecurity efforts. They serve as the bridge between your people, your tech, and your regulators.
| Designate a qualified CySO with the right credentials and risk management experience | |
| Document roles and responsibilities in alignment with the Final Rule and supporting FAQs | |
| Align your cybersecurity program with the Coast Guard’s Final Rule, CISA Cyber Protection Goals, and the NIST Cybersecurity Framework and ensure incident response plans are tested and ready |
With the Maritime Cybersecurity Final Rule now in effect, proactive action today will prevent compliance headaches tomorrow. By choosing the right CySO, you're not just meeting a deadline; you're building resilience into your maritime operations.
At MAD Security, we help maritime operators identify, vet, and train CySOs through services like Virtual Compliance Management, GRC assessments, and CMMC readiness consulting. Whether you're building your team or seeking to augment it, we bring the expertise you need to meet federal expectations.
Schedule a consultation today and take the first step toward lasting maritime cybersecurity compliance with confidence.
Original Publish Date: October 21, 2025
By: Maritime MAD Security