What the Coast Guard’s Final Rule Means for Maritime Cybersecurity: MAD Security Maritime Town Hall Recap – October 2025

Written by MAD Security Maritime, Cliff Neve | October 30, 2025

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What the Coast Guard’s Final Rule Means for Maritime Cybersecurity

Maritime organizations navigating the complexities of cybersecurity compliance have a new regulatory tide to ride. In October’s Maritime Cybersecurity Town Hall, MAD Security’s VP of Maritime Cybersecurity, Cliff Neve, broke down the Coast Guard’s final rule and its real-world implications for MTSA-regulated facilities.

If you're a port operator, facility security officer (FSO), Cybersecurity Officer (CySO), or third-party contractor supporting maritime infrastructure, this rule affects you. Here’s what you need to know and what you should do next.

The Coast Guard’s Final Rule: Why It Matters

As of July 16, 2025, the U.S. Coast Guard’s final rule establishes minimum cybersecurity standards under 33 CFR 101 Subpart F. This is more than a policy update; it marks a shift in how cyber risk is treated within maritime operations. For the first time, cybersecurity incidents that disrupt port operations are formally recognized as Transportation Security Incidents (TSIs), putting them on par with physical breaches.

That means your networked gate systems, OT (operational technology), and even outdated Windows boxes now fall under the Coast Guard’s scrutiny.

Meet the New Cybersecurity Roles: FSO and CySO Must Collaborate

The regulation clearly defines three major roles in maritime cybersecurity compliance:

Owner/Operator

Ultimately accountable for compliance
Must designate a Cybersecurity Officer (CySO) in writing by July 16, 2027
Responsible for incident response, training programs, and documented cybersecurity planning

Security Officer

Traditionally manages physical security
Now responsible for coordinating cybersecurity efforts with the CySO
Must integrate cyber risk into facility drills, security plans, and incident reporting

Cybersecurity Officer (CyISO) (New Requirement)

Leads implementation of the cybersecurity plan and incident response procedures
Oversees continuous monitoring, incident detection, and regulatory documentation
Can be internal or external (outsourcing to a qualified provider like MAD Security is acceptable and often ideal)

Integration Is the Future: No More Silos Between Physical and Cyber

One of the clearest takeaways from the Town Hall: Physical and cybersecurity are now inseparable.

As Cliff Neve put it: “If a bad actor owns the physical system, they likely own the cyber system and vice versa.”

Ransomware attacks on port gate systems are now just as disruptive as someone cutting through a fence. This requires FSOs and CySOs to conduct joint exercises, share threat models, and unify their security posture.

Compliance Deadlines You Can't Ignore

MAD Security encourages facility owners to get ahead of the deadlines because waiting until July 2027 could leave you exposed.

Here’s what’s expected now and in the near future:

	Cybersecurity Training: Required for all personnel with IT/OT access by January 2026
	Cybersecurity Officer Designation: Must be in writing by July 16, 2027, but recommend identification as soon as possible so that the individual is onboard to establish the strategy and oversee the training, drills, and assessment
	Drills and Exercises: At least 2 cyber drills per year 1 annual cybersecurity exercise, which can be integrated with physical security exercises
	Cybersecurity Assessments and Plans: Conducted under 33 CFR 101.630 Must include IT/OT inventory, risk mapping, and business continuity

MAD Security’s Managed Security Tabletop Exercise (MSTTX) Services simplify this process. Our team conducts realistic simulations, aligns them to your threat landscape, and provides detailed documentation suitable for compliance and audits. Explore more under Managed Security Services.

For Small Ports, a Fractional CISO Could Be the Smart Move

One Town Hall attendee asked: "How can a small facility afford a qualified CySO?"

The answer: You don’t have to hire a full-time executive.

MAD Security offers fractional CySO services, providing expert maritime cybersecurity leadership on a scalable basis. This allows ports to meet compliance requirements without overextending their budgets.

	Align tabletop scenarios to relevant threat
	Generate audit-ready documentation
	Conduct guided sessions with cyber and compliance professionals

What Makes a Good Maritime CySO?

According to Cliff Neve, a capable CISO should:

	Understand both IT and OT systems
	Be familiar with ISA/IEC 62443, NIST 800, Port Environments, and CMMC Level 2 if applicable
	Be able to translate cyber risk into operational impact
	Know how to plan for business continuity after a breach

Importantly, simply assigning your FSO or IT manager as CySO may not satisfy Coast Guard expectations. Maritime cybersecurity is specialized. It demands deep, role-specific experience.

Your Next Steps Toward Compliance

If your facility is still treating cyber as a siloed IT problem, now is the time to course-correct.

MAD Security recommends:

	Designating a highly qualified CySO now, not in 2027
	Updating your Facility Security Plan to include cyber components
	Documenting drills and exercises to show compliance
	Partnering with cybersecurity experts who understand maritime risks and Coast Guard expectations

MAD Security has helped countless government contractors, ports, and maritime vendors build and maintain compliant, resilient cyber programs. We specialize in integrating NIST, DFARS, and CMMC requirements into operational cybersecurity, simplifying complexity and reducing risk.

Get Help Before the Tide Rises

If you’re a maritime facility or vendor supporting port operations, compliance with the Coast Guard’s final rule isn’t optional and delay is a risk.

Let MAD Security help you implement the right cybersecurity foundation before enforcement begins.

Original Publish Date: October 30, 2025

By: Maritime MAD Security

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