What is CIS Controls

The Center for Internet Security (CIS) Controls represent a consensus-driven framework that distills decades of incident response data into 18 actionable security controls. For GRC analysts managing third-party risk, CIS Controls serve as both an assessment baseline and a control mapping reference point.

Unlike prescriptive frameworks that mandate specific technologies, CIS Controls focus on security outcomes. This outcome-based approach makes them particularly valuable for vendor due diligence, where you need to assess security posture across diverse technology stacks and organizational structures.

The framework's tiered implementation model addresses a critical challenge in vendor management: how to apply consistent security standards across suppliers with vastly different capabilities. Small vendors can demonstrate security maturity through IG1 implementation, while critical suppliers handling sensitive data should achieve IG2 or IG3 standards.

Evolution and Authority

CIS Controls emerged from the SANS Top 20 Critical Security Controls, incorporating threat intelligence from organizations including the NSA, CERT, and private sector incident response teams. Version 8, released in May 2021, consolidated the framework from 20 to 18 controls while maintaining comprehensive coverage of the MITRE ATT&CK framework.

The controls carry significant regulatory weight. The FTC specifically references CIS Controls in enforcement actions, including the 2016 Wyndham Hotels case where failure to implement basic controls contributed to a $10 million settlement. California's Attorney General endorses CIS Controls as a minimum security standard, creating potential liability for organizations that fail to implement them.

Control Structure and Implementation Groups

The 18 Controls

1. Inventory and Control of Enterprise Assets - You can't protect what you don't know exists
2. Inventory and Control of Software Assets - Track authorized and unauthorized software
3. Data Protection - Identify, classify, and protect data based on sensitivity
4. Secure Configuration of Enterprise Assets - Harden systems against default vulnerabilities
5. Account Management - Control user access lifecycle from creation to termination
6. Access Control Management - Enforce least privilege and need-to-know principles
7. Continuous Vulnerability Management - Identify and remediate vulnerabilities systematically
8. Audit Log Management - Collect, alert, review, and retain security events
9. Email and Web Browser Protections - Defend against phishing and web-based attacks
10. Malware Defenses - Prevent, detect, and remediate malware infections
11. Data Recovery - Maintain tested backups and recovery procedures
12. Network Infrastructure Management - Secure network devices and communication channels
13. Network Monitoring and Defense - Detect and respond to network-based threats
14. Security Awareness and Skills Training - Build human firewalls through education
15. Service Provider Management - Extend security requirements to third parties
16. Application Software Security - Secure the software development lifecycle
17. Incident Response Management - Prepare for, detect, and respond to security incidents
18. Penetration Testing - Validate security controls through simulated attacks

Implementation Groups Explained

IG1 (Essential Cyber Hygiene): 56 safeguards focusing on basic cyber hygiene. Organizations with limited IT staff and simple infrastructure start here. For vendor assessment, IG1 compliance indicates fundamental security awareness.

IG2 (Enhanced Controls): 130 safeguards adding specialized technology and dedicated security staff requirements. Vendors handling moderate volumes of sensitive data should achieve this level.

IG3 (Advanced Security): All 153 safeguards including sophisticated monitoring and response capabilities. Critical vendors, especially those in regulated industries or handling highly sensitive data, require IG3 implementation.

Regulatory Crosswalk and Framework Mapping

CIS Controls map comprehensively to major compliance frameworks:

SOC 2 Trust Service Criteria:

• CC6.1 (Logical Access Controls) maps to CIS Controls 5 and 6
• CC7.2 (System Monitoring) aligns with Controls 8 and 13
• CC9.2 (Vendor Management) directly references Control 15

ISO 27001:2022 Annex A Controls:

• A.8.1 (Asset Management) corresponds to CIS Controls 1 and 2
• A.8.2 (Information Classification) maps to Control 3
• A.5.1 (Information Security Policies) supported by multiple CIS Controls

NIST Cybersecurity Framework:

• Identify function maps to Controls 1, 2, 3, 12
• Protect function covers Controls 4-11, 14, 16
• Detect function aligns with Controls 8, 13
• Respond and Recover map to Controls 11, 17, 18

Third-Party Risk Management Applications

Vendor Assessment Integration

When evaluating vendors, CIS Controls provide quantifiable security metrics. Rather than asking "Do you have security controls?", you can request:

• Percentage of IG1 safeguards implemented
• Evidence of Control 15 (Service Provider Management) implementation
• Audit logs demonstrating Control 8 compliance
• Recovery time objectives per Control 11

Control Verification Methods

Documentation Review: Request CIS Controls self-assessment workbooks showing safeguard implementation status. Look for completion percentages by control and implementation group.

Technical Validation: During security assessments, test specific safeguards:

• Control 1: Request current hardware asset inventory with last update date
• Control 4: Verify secure baseline configurations through sample system reviews
• Control 7: Review vulnerability scan reports and remediation timelines

Continuous Monitoring: Mature third-party risk programs track vendor CIS Control implementation over time:

• Quarterly attestation updates for critical vendors
• Annual reassessment of implementation group achievement
• Incident correlation with control gaps

Industry-Specific Considerations

Financial Services: Regulators expect IG3 implementation for vendors accessing material nonpublic information. The FFIEC Cybersecurity Assessment Tool maps directly to CIS Controls, making adoption mandatory for examination readiness.

Healthcare: While HIPAA doesn't mandate CIS Controls, OCR settlements increasingly reference them as reasonable security measures. Vendors handling PHI should implement IG2 minimum.

Government Contractors: CMMC Level 2 incorporates multiple CIS Controls. Federal contractors must flow down these requirements to subcontractors handling CUI.

Common Implementation Misconceptions

"All controls apply equally": Controls prioritize by actual threat frequency. Control 1 (Asset Inventory) enables all others—you can't secure unknown assets.

"Higher IG means better security": IG3 requirements may introduce unnecessary complexity for small vendors. Right-size expectations based on data sensitivity and vendor criticality.

"Compliance equals implementation": Checkbox compliance without operational implementation provides no security value. Verify controls function in production environments.

"CIS Controls replace other frameworks": They complement, not replace, industry-specific requirements. Use CIS for baseline security, then layer regulatory requirements.

Frequently Asked Questions

How do CIS Controls differ from NIST CSF or ISO 27001?

CIS Controls provide prescriptive technical safeguards prioritized by threat data, while NIST CSF offers a risk management approach and ISO 27001 focuses on management systems. CIS tells you what to implement; NIST and ISO help you manage the program.

Which Implementation Group should we require from vendors?

Base requirements on data sensitivity and vendor criticality. IG1 for low-risk vendors handling non-sensitive data, IG2 for moderate risk or sensitive data access, IG3 for critical vendors in your supply chain.

Do CIS Controls satisfy SOC 2 requirements?

CIS Controls address most SOC 2 Common Criteria, but SOC 2 requires additional elements like management oversight and risk assessment processes. Use CIS as your technical control baseline within a broader SOC 2 program.

How often do CIS Controls update?

Major versions release every 3-4 years with minor updates annually. Version 8 launched in May 2021. Monitor the CIS website for update announcements and transition guidance.

Can small vendors realistically implement CIS Controls?

Yes, through IG1 implementation. The 56 IG1 safeguards focus on essential hygiene achievable with basic IT resources. Many safeguards leverage existing operating system features or free tools.

How do we verify vendor CIS Control implementation without being overly burdensome?

Request annual self-assessments using the CIS Controls Assessment Module (CAM) spreadsheet, supplemented by evidence sampling for critical controls. Focus deeper validation on high-risk vendors only.