How NERC CIP Can Support Maritime Compliance
Understanding Where NERC CIP and 33 CFR Part 101, Subpart F Align
July 14, 2026 | By Ron Frechette | Founder & Managing Director | CyberSurv
In our last Maritime Cyber Insights article, Beyond Compliance: How AI Is Transforming Maritime Operations, we explored how cybersecurity has evolved beyond simply satisfying regulatory requirements. As maritime organizations strengthen their cyber programs, many are also discovering opportunities to improve operational efficiency through secure AI and intelligent automation. That conversation naturally leads to another question, one we’re hearing with increasing frequency from ports, terminals, and energy companies.
“We’ve already invested heavily in NERC CIP. Can we leverage those controls to meet the Coast Guard’s maritime cybersecurity requirements?”
For organizations that already maintain mature cybersecurity programs, it’s a logical question. No one wants to duplicate years of investment if existing controls can support both operational resilience and maritime compliance. In fact, several of the maritime organizations we’re currently working with are exploring exactly that. Many are evaluating how their existing NERC CIP cybersecurity controls align with 33 CFR Part 101, Subpart F, while also asking whether those controls could potentially support a future waiver or equivalency request with the U.S. Coast Guard. While every organization and operational environment is different, these conversations highlight an important shift. Rather than starting from scratch, organizations want to understand how to maximize the cybersecurity investments they’ve already made.
Different Missions. Shared Objectives.
Although NERC Critical Infrastructure Protection (NERC CIP) and 33 CFR Part 101, Subpart F were developed for different industries, they share a common objective: protecting critical infrastructure from cyber threats that could disrupt essential operations. NERC CIP focuses on safeguarding the reliability of the Bulk Electric System. Subpart F focuses on protecting maritime facilities, vessels, and the Marine Transportation System from cyber incidents that could impact safety, security, or operational continuity. Both frameworks emphasize identifying critical assets, managing cyber risk, controlling access, responding to incidents, maintaining resilience, and fostering a culture of cybersecurity. The difference isn’t whether cybersecurity matters. It’s how those controls are applied within each operational environment.
You’re Probably Closer Than You Think
Organizations with mature NERC CIP programs have already established many of the cybersecurity capabilities needed to strengthen their maritime security posture. These often include:
- Asset inventories
- Identity and access management
- Configuration and change management
- Vulnerability management
- Incident response planning
- Security awareness training
- Logging and monitoring
- Vendor and third-party risk management
These aren’t just compliance requirements… they’re cybersecurity best practices. Rather than rebuilding these capabilities, organizations should first evaluate how existing controls support their maritime operations and identify where additional maritime-specific considerations may be required. In many cases, the foundation is already in place.
Maritime Operations Introduce New Considerations
While NERC CIP provides a strong cybersecurity framework, maritime organizations must also evaluate cyber risk through an operational lens. Questions such as:
- Which systems directly support safe vessel or terminal operations?
- How do operational technology and physical security systems interact?
- Could a cyber event disrupt cargo movement or vessel traffic?
- What third-party vendors have access to operational systems?
- How would a cyber incident affect the Facility Security Plan?
These operational dependencies often extend beyond the traditional scope of NERC CIP. That doesn’t mean existing controls aren’t effective. It means they should be evaluated against the Coast Guard’s maritime security objectives.
Can Existing Controls Support a Waiver or Equivalency?
One of the most common questions we’re hearing is whether an organization’s existing NERC CIP cybersecurity program could support a waiver or equivalency request under 33 CFR Part 101, Subpart F. The answer depends on the organization, its operations, and how well existing controls align with the Coast Guard’s requirements. Rather than assuming compliance automatically transfers from one regulatory framework to another, organizations should first perform a comprehensive evaluation of their existing cybersecurity program. That assessment helps determine:
- Which controls already satisfy the intent of Subpart F
- Where maritime-specific gaps exist
- What additional documentation or operational safeguards may be required
- Whether existing controls may support future discussions regarding a waiver or equivalency request
For organizations with mature cybersecurity programs, this approach can reduce unnecessary duplication while creating a practical roadmap toward maritime compliance.
Every waiver or equivalency request is evaluated by the U.S. Coast Guard based on the specific operational environment and supporting documentation. Organizations should not assume existing compliance with another regulatory framework automatically satisfies the requirements of 33 CFR Part 101, Subpart F.
Collaboration Is the Key
One lesson has become increasingly clear throughout our maritime engagements. The strongest cybersecurity programs aren’t developed by a single department. Successful organizations bring together:
- Facility Security Officers (FSOs)
- Cybersecurity Officers (CySOs)
- Operations leaders
- Engineering teams
- Executive leadership
Each group understands a different aspect of operational risk. When those perspectives come together, organizations gain a much clearer understanding of how existing cybersecurity investments support maritime operations and where additional safeguards may be needed. Compliance becomes more than a regulatory exercise. It becomes part of a broader operational resilience strategy.
Beyond Compliance
At CyberSurv, we believe organizations shouldn’t have to choose between protecting operations, satisfying regulatory requirements, and improving business performance. Our role is to help organizations evaluate the cybersecurity capabilities they already have, determine how those controls align with maritime requirements, and identify practical opportunities to strengthen resilience.
Working alongside our strategic partner, Seebald & Associates, we bring Facility Security Officers, Cybersecurity Officers, and operational leadership together to develop practical, risk-based compliance strategies tailored to each organization. As these assessments progress, many clients uncover manual processes and operational bottlenecks that extend well beyond cybersecurity.
Through our sister company, Turbo AI Solutions, we help organizations evaluate where secure AI can automate repetitive workflows, streamline compliance activities, reduce administrative effort, and improve operational efficiency, all while maintaining strong cybersecurity governance. Together, we’re helping maritime organizations bridge physical security, cybersecurity, compliance, and intelligent automation.
Final Thoughts
Organizations that have invested in NERC CIP aren’t starting from zero. They already possess many of the cybersecurity capabilities needed to support a strong maritime cybersecurity program. The opportunity isn’t to replace those investments. It’s to understand how they align with 33 CFR Part 101, Subpart F, identify any remaining maritime-specific gaps, and develop a practical roadmap that strengthens both compliance and operational resilience.
The organizations that will be most successful won’t view NERC CIP and Subpart F as competing frameworks. They’ll recognize them as complementary approaches that support the same mission: Protecting critical infrastructure while enabling safe, secure, and resilient maritime operations.
Continue the Conversation
If your organization is currently operating under NERC CIP and preparing for 33 CFR Part 101, Subpart F, we’d welcome the opportunity to discuss how your existing cybersecurity program can support your maritime compliance strategy. Whether you’re evaluating your readiness, identifying compliance gaps, or exploring whether existing controls may support future discussions regarding a Coast Guard waiver or equivalency, CyberSurv can help you develop a practical, risk-based path forward.
