In mid-2017, federal agencies released important guidance under the Cybersecurity Act of 2015 designed to help critical infrastructure operators enhance supply chain transparency and resilience. This guidance reflected mounting concerns over the potential for cyber vulnerabilities to cascade through the complex networks of vendors and service providers that support the nation’s most essential systems. For utilities, transport operators, water systems, and other critical sectors, the challenge of securing supply chains had become increasingly intertwined with broader risk management obligations. The new directives offered both a framework and practical tools for addressing these concerns in a coordinated and evidence-based manner.
A central feature of the 2017 guidance was the recommendation that utilities and other critical infrastructure entities leverage open data resources provided by the Department of Homeland Security (DHS), particularly through the Cybersecurity and Infrastructure Security Agency (CISA). The CISA dashboard, made available as part of DHS’s open government initiatives, allowed operators to track vendor-level risk indicators drawn from aggregated threat intelligence, vulnerability reports, and historical incident data. The dashboard’s utility lay in its ability to surface patterns that might otherwise go unnoticed when examining individual suppliers or contractors in isolation. By integrating this data into procurement and oversight processes, critical infrastructure operators could make more informed decisions about vendor selection, contractual safeguards, and ongoing monitoring.
The use of the CISA dashboard required utilities to rethink traditional supply chain risk management practices. Historically, vendor assessments focused primarily on financial stability, technical capability, and compliance with sector-specific operational standards. Cybersecurity considerations, where they existed, tended to be addressed through generic contractual clauses or point-in-time audits. The 2017 guidance urged a more dynamic and data-driven approach. Utilities were encouraged to establish workflows that would continuously pull in CISA dashboard data, cross-reference it against their vendor rosters, and flag suppliers associated with elevated or emerging risks. This continuous monitoring model aligned with the broader shift in cybersecurity thinking from static defenses to adaptive resilience.
Implementing such workflows demanded significant organizational adjustments. Many utilities found that their existing vendor management systems lacked the capacity to interface directly with external data feeds like the CISA dashboard. In response, some turned to third-party risk platforms capable of ingesting and analyzing these data streams alongside internal records. Others developed custom tools or collaborated through industry groups to build shared solutions. Regardless of the specific technical path chosen, the underlying requirement was the same: the ability to link external risk signals to internal procurement, operational, and compliance processes in a timely and actionable manner.
One of the most tangible outcomes of the 2017 guidance was the growing adoption of formal supply chain hazard disclosures, submitted annually to state public utility commissions (PUCs) or similar oversight bodies. These disclosures provided regulators with greater visibility into how utilities were managing cybersecurity risks within their supply chains, complementing existing reporting obligations on physical security, environmental compliance, and financial performance. Typically, the disclosures outlined key supply chain risks identified over the prior year, mitigation steps taken, and any material incidents or near-misses involving vendor-related cyber vulnerabilities. They also often included forward-looking plans for addressing identified gaps or evolving threats.
Developing these disclosures was not a trivial exercise. Utilities needed to assemble data from across multiple departments, including procurement, IT security, legal, and operations. Ensuring consistency and accuracy required robust internal coordination, supported by clear governance structures and documented procedures. Many organizations adopted templated reporting formats to streamline the process and reduce the risk of omission or inconsistency. These templates generally followed a structure that mirrored the categories set out in the DHS guidance, covering topics such as vendor risk tiering, use of open-source risk data, incident response coordination, and supply chain continuity planning.
For utilities just beginning to formalize their supply chain hazard reporting, the 2017 guidance provided a valuable starting point. By aligning internal practices with DHS recommendations and making systematic use of CISA’s open data resources, these entities could demonstrate to regulators and stakeholders that they were taking concrete steps to safeguard critical services. In doing so, they also positioned themselves to better withstand the growing array of cyber threats facing the sector. The move towards greater transparency, driven by both regulatory expectations and practical risk considerations, reflected a broader cultural shift in the utility industry—one in which cybersecurity was no longer treated as a technical issue alone, but as a core element of responsible corporate governance.
As supply chains grew increasingly global and interconnected, the relevance of these efforts only became clearer. Components and services sourced from around the world brought with them not just economic efficiencies, but also new potential entry points for malicious actors. The ability to map, monitor, and manage these complex webs of interdependence became a defining feature of modern critical infrastructure stewardship. The 2017 directives under the Cybersecurity Act represented an important step in helping utilities rise to that challenge.