Co-Founder Taliferro
Introduction
In 2023 I argued that human‑centric security beats tool‑first thinking. That aged well. The difference in 2025: accountability. Regulations and frameworks now force leaders to operationalize culture, governance, and fast response—not just buy platforms.
What Changed Since 2023
NIST CSF 2.0. Published Feb 26, 2024, CSF 2.0 applies to all organizations and adds a dedicated Govern function that elevates leadership, risk ownership, and metrics. Source.
SEC Cyber Disclosures (Item 1.05). Public companies must file an 8‑K within four business days after determining an incident is material, with annual governance disclosures. Press release · Final rule.
PCI DSS 4.0 enforcement. Future‑dated controls became mandatory on March 31, 2025; v4.0.1 clarified timelines without changing that date. Council blog · v4.0.1.
Secure‑by‑Design. CISA’s guidance and vendor pledges are shifting more responsibility onto software makers. Bake security into defaults, development, and updates. Guidance.
Threat reality check. The 2025 DBIR highlights ransomware’s continued weight inside the “System Intrusion” pattern. Don’t chase tools—cut dwell time. DBIR 2025.
Why Human‑Centric Still Wins
Controls work when people can use them. If MFA flows are clunky, users route around them. If patching breaks the business, teams delay. Human‑centric design lowers friction, raises compliance, and shortens response cycles.
Corporate Apathy: Still the Weak Link
Apathy is ignoring known gaps because “we’ve never been hit.” In 2025, apathy is risk exposure. Boards are now on the hook via CSF’s Govern function and SEC reporting. Treat security as a business risk with owners, budgets, and timelines.
9 Practical Actions for 2025
- Map to CSF 2.0 Govern. Define risk ownership, decision rights, and metrics.
- Write the 8‑K playbook. Materiality checklist, counsel sign‑off, comms templates, and a four‑day timer.
- Quarterly tabletops. Include executives, legal, PR, and key vendors.
- Modernize auth. Passkeys or phishing‑resistant MFA; kill password reuse.
- Close PCI 4.0 gaps. Logging, change control, e‑commerce controls, and continuous monitoring.
- Secure‑by‑Design procurement. Require vendors to meet default‑secure criteria—tie this to robust cloud architecture practices.
- Prioritize time‑to‑contain. Measure MTTR, not how many tools you own.
- Invest in internal talent. Upskill your people before shopping for unicorns.
- Board oversight. Standing cyber committee with quarterly KPI review.
Role‑Specific Playbooks (Quick Starts)
For Engineering Leads: adopt threat modeling in sprint planning and require security user stories alongside features. Standardize dependency scanning and SBOM (software bill of materials) publication. If you’re integrating APIs, align with our API gateway guidance to reduce exposure.
For IT & Cloud: enforce least privilege, rotate keys, and apply baseline guardrails in IaC (infrastructure as code). Map cloud controls to CSF 2.0’s Govern/Protect and review quarterly. For platform changes that impact users, follow the change‑control principles we use in operations streamlining.
For Business Owners: define what “material” means for an incident (revenue, reputation, safety) and pre‑approve the 8‑K workflow with counsel. Train spokespeople. Your first four hours matter more than your first four tools.
Metrics That Matter
- MTTD / MTTR: mean time to detect / respond; report to the board each quarter.
- Exploitability window: time from patch release to deployment; aim for days, not weeks.
- MFA bypass rate: track how often users fall back to weaker factors; improve flows with passwordless.
- Tabletop cadence: at least quarterly, with action items closed within 30 days.
Common Pitfalls in 2025
- Tool sprawl without owners. Name a DRI (directly responsible individual) for each critical control.
- Unmapped third‑party risk. Vendors handle sensitive data; apply Secure‑by‑Design reviews before purchase and at renewal.
- “One‑size” MFA. High‑risk roles deserve stronger factors and step‑up auth; see our take on phishing‑resistant sign‑in.
- Change fatigue. Pair new controls with training and simple UX—human‑centric means usable.
90‑Day Action Plan
- Days 1–15: confirm CSF 2.0 scope and owners; draft the 8‑K playbook with counsel; baseline auth and logging.
- Days 16–45: close top five PCI 4.0 gaps; implement passkeys for admins; run a company‑wide phishing‑resistant rollout pilot.
- Days 46–75: run a full incident tabletop; fix findings; tune detections to cut false positives by 20%.
- Days 76–90: board review of metrics; publish a one‑page cyber policy; schedule the next two tabletops.
Conclusion
Cybersecurity in 2025 is trust, not tools. Put people first, govern clearly, practice often, and respond fast. That’s how you reduce real risk.
FAQ
What is CSF 2.0’s Govern function?
It defines leadership responsibilities, risk ownership, policies, and measurements across the program.
When did PCI DSS 4.0 future‑dated controls become mandatory?
March 31, 2025.
When is an 8‑K due for a cyber incident?
Within four business days after determining the incident is material.
Related Reading
- API Gateways: From Pessimism to Value — reduce attack surface with disciplined routing and policy.
- Why Off‑the‑Shelf Solutions Pale — when custom fit reduces security debt.
- Streamlining Business Operations with Technology — governance and change control in practice.
Sources
- NIST CSF 2.0 (Feb 26, 2024): PDF · Overview
- SEC final rule & summary: Press · Rule
- PCI DSS 4.x enforcement (Mar 31, 2025): Council blog · v4.0.1
- CISA Secure‑by‑Design: Guidance
- Verizon DBIR 2025: Report