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NERC CIP-003-9 vendor remote access rules create audit and recordkeeping burdens

Industrial Cyberenergy

What happened. Centrii says NERC CIP-003-9 requires owners of low-impact bulk electric system (BES) cyber systems to identify vendor remote access, disable it and detect malicious communications. It flags compliance and recordkeeping challenges. Penalties can reach $1,584,648 per violation, per day.

Who is affected. Owners and operators of renewable energy, storage and other facilities with low-impact BES cyber systems that permit vendor remote access, covering controllers, SCADA and communications.

What to do. Review whether your low-impact BES assets allow vendor remote access. Set up processes to identify it, disable it and detect malicious communications, and keep records.

When to act. For awareness: background reading, nothing to schedule

Editor's reading

Forasset ownerOT security leadleadership

Purdue level
  • L3.5
  • L2
  • L1
Level 3.5, the industrial DMZ; Level 2, supervisory control (HMIs, SCADA, engineering workstations); Level 1, basic control (PLCs, RTUs, safety controllers)

Why: Vendor remote access usually enters through remote-access gateways in the DMZ (L3.5) and reaches SCADA (L2) and controllers (L1), which the report names as in scope.

Are you exposed?

List every low-impact BES asset where a vendor can connect remotely, and check whether each path is documented and can be disabled.

If you cannot fix it yet
  • Disable vendor remote access by default and enable it only for approved, time-limited sessions.
  • Route all vendor access through a single monitored gateway in the industrial DMZ.
  • Keep dated records of each vendor session and the checks made.
Watch for
  • Vendor remote sessions that start outside approved windows or bypass the central gateway.
  • Known or suspected malicious communications tied to vendor access paths.
ATT&CK for ICS
T0886Remote Services

Inferred from the facts above, not stated by the source. Check it against your own site before acting.

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Source: Industrial Cyber (opens industrialcyber.co)

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