On May 21, 2026, the New York Department of Financial Services (NYDFS) issued industry guidance to licensees regarding security measures they should consider taking “in a heightened cybersecurity threat environment.” Even organizations not subject to NYDFS regulation may want to 
NYDFS Cybersecurity Enforcement: US$2.25m Fine Against Delta Dental

On April 30, 2026, the New York Department of Financial Services (NYDFS) announced a consent order with Delta Dental Insurance Company and Delta Dental of New York, Inc. for alleged violations of the NYDFS Cybersecurity Regulation relating to the 2023…
NY DFS’s new MFA guidance: closing common gaps before the next exam

Multi‑factor authentication (MFA) is now a well-established baseline cybersecurity control. The amended New York Department of Financial Services (NY DFS) solidified that understanding and expanded MFA requirements under 23 NYCRR Part 500 (the NY DFS…
NYDFS releases guidance on third-party service provider risks

On October 21, 2025, the New York Department of Financial Services (NYDFS) issued guidance to help licensees comply with its cybersecurity regulation. The non-exclusive checklists may be of interest to companies not licensed by NYDFS and even those not…
NYDFS fines licensee $2 million for lack of email retention policy and MFA
On August 14, 2025, the New York Department of Financial Services (“NYDFS”) entered into a consent order with Healthplex, Inc, (“Healthplex”), which is licensed by NYDFS as an independent claims adjuster and as a life and/or accident health insurance agent. …
New York changes data breach law—in December and February
New York just finished a series of adjustments to its data breach notification requirements. Effective immediately, organizations must notify impacted individuals of a data breach within 30 days of its discovery instead of “in the most expedient time possible and…
NYDFS settles with insurance companies over failures in their cybersecurity programs

On November 25, 2024, the New York State Department of Financial Services (“NYDFS”) announced it settled with two large insurance companies over allegations of inadequate data security practices in violation of New York’s cybersecurity regulation (23 NYCRR Part 500) (the…
New York hospitals have new cybersecurity requirements
On October 2, 2024, the New York State Department of Health (DOH) published a new cybersecurity regulation (10 NYCRR 405.46) for all general hospitals licensed pursuant to article 28 of the Public Health Law. Although most of the regulation will…
New York Department of Financial Services addresses cybersecurity risks from artificial intelligence



On October 16, 2024, the New York Department of Financial Services (“NYDFS” or “DFS”) issued guidance raising awareness about combatting cybersecurity risks arising from artificial intelligence (“AI”) used by DFS licensees, such as insurers and virtual currency businesses. Risks revolve…
NYDFS issues significant guidance on insurers using AI or external data

On January 17, 2024 the New York Department of Financial Services (“NYDFS”) published a Proposed Insurance Circular Letter (“Proposed Circular”) regarding the use of artificial intelligence systems (“AIS”) and external consumer data and information sources (“ECDIS”) in insurance underwriting and…


