BANKING CYBERSECURITY & REGULATORY COMPLIANCE
NBG Cybersecurity Framework Audit & Compliance
Independent Cybersecurity Assessment. Regulatory Alignment. Sustainable Risk Management.
IO Consulting supports financial institutions in assessing and strengthening cybersecurity governance, risk management, and security controls in accordance with applicable National Bank of Georgia requirements.
Our services combine independent cybersecurity framework audits, evidence-based compliance assessments, gap analysis, corrective action planning, and practical implementation support.
We help organizations move beyond formal compliance toward effective cybersecurity governance, stronger operational resilience, and continuous improvement.
Cybersecurity & Compliance
Financial Institution
Critical services and the institution's operating context.
Governance & Controls
Accountable responsibilities and risk-based security safeguards.
Audit Evidence
Documented criteria, appropriate testing and traceable findings.
Operational Resilience
Preparedness, incident response, recovery and ongoing improvement.
REGULATORY CONTEXT
Cybersecurity Governance as a Regulatory and Business Priority
The National Bank of Georgia's cybersecurity requirements establish expectations for managing cyber risks, protecting critical information assets, detecting cybersecurity events, responding to incidents, and supporting recovery.
For institutions within the applicable regulatory scope, cybersecurity management must be aligned with organizational risk management, operational complexity, and the criticality of services.
Effective implementation requires clearly assigned responsibilities, documented processes, functioning controls, reliable evidence, and continuous oversight.
TWO DISTINCT ENGAGEMENTS
Independent Audit. Practical Compliance Support.
Choose the work your institution needs: an independent audit against agreed applicable criteria, or advisory support to implement and improve cybersecurity controls.
Independent Cybersecurity Framework Audit
We perform structured, evidence-based assessments of cybersecurity governance, risk management processes, technical safeguards, incident response capabilities, and operational resilience against the applicable NBG requirements.
- Regulatory criteria mapping and documentation review.
- Stakeholder interviews and technical evidence evaluation.
- Control design and operating effectiveness testing using agreed procedures.
- Risk-based findings with evidence references and corrective recommendations.
- A formal audit report and agreed follow-up within the defined scope.
Compliance Implementation & Remediation
We help organizations establish, improve, and operationalize cybersecurity governance and control mechanisms aligned with applicable NBG requirements.
- Gap analysis, policies, procedures and risk assessment methodologies.
- Asset, third-party, identity and access governance.
- Monitoring, incident response, business continuity and recovery arrangements.
- Corrective action ownership, implementation priorities and evidence preparation.
- Maintainable security practices with documented processes and measurable control effectiveness.
CONTROL ASSESSMENT
Key Areas of Cybersecurity Assessment
Explore the objectives, evidence and improvement considerations that can inform a scoped cybersecurity assessment.
Illustrative assessment areas and examples only. These are not the regulation's official clause names, an exhaustive regulatory checklist or actual client results. Detailed criteria and testing are mapped to the applicable legal act, audit guidance and agreed scope.
Select a control area
Cybersecurity Governance
Responsibilities, strategy, policies and oversight connected to the institution's objectives.
- Control objective
- Establish accountable decision-making and oversight for cybersecurity risks, priorities and control performance.
- Typical evidence reviewed
- Governance charters, assigned roles, approved strategies and policies, committee minutes, management reports and oversight decisions.
- Common control deficiencies
- Unclear ownership, outdated policies, fragmented reporting and decisions without documented risk consideration.
- Potential business impact
- Inconsistent priorities, unresolved risks and delayed decisions affecting critical services or regulatory obligations.
- Example improvement actions
- Clarify authority and responsibilities, refresh policy review cycles, establish meaningful management reporting and track decisions to completion.
Cybersecurity Governance
Responsibilities, strategy, policies and oversight connected to the institution's objectives.
- Control objective
- Establish accountable decision-making and oversight for cybersecurity risks, priorities and control performance.
- Typical evidence reviewed
- Governance charters, assigned roles, approved strategies and policies, committee minutes, management reports and oversight decisions.
- Common control deficiencies
- Unclear ownership, outdated policies, fragmented reporting and decisions without documented risk consideration.
- Potential business impact
- Inconsistent priorities, unresolved risks and delayed decisions affecting critical services or regulatory obligations.
- Example improvement actions
- Clarify authority and responsibilities, refresh policy review cycles, establish meaningful management reporting and track decisions to completion.
Cyber Risk Management
A consistent approach to identifying, assessing, treating and monitoring cybersecurity risk.
- Control objective
- Connect cybersecurity risk decisions to business priorities, risk tolerance, relevant threats and operating conditions.
- Typical evidence reviewed
- Risk methodology, assessments, risk registers, treatment plans, acceptance decisions, indicators and review records.
- Common control deficiencies
- Incomplete scope, inconsistent ratings, unowned risks and treatment actions that are not reviewed or verified.
- Potential business impact
- Misallocated resources and unmanaged exposures that can affect information, operations and the institution's obligations.
- Example improvement actions
- Agree assessment criteria, improve risk coverage, assign owners and deadlines, document treatment decisions and review residual risk.
Asset & Information Management
Visibility of critical assets, information, ownership and service dependencies.
- Control objective
- Identify and manage information and supporting assets throughout their lifecycle according to their importance and protection needs.
- Typical evidence reviewed
- Asset and information inventories, ownership records, classification rules, data flows, dependency maps and lifecycle procedures.
- Common control deficiencies
- Incomplete inventories, unknown owners, inconsistent classification and unrecorded dependencies or data locations.
- Potential business impact
- Critical systems or sensitive information may be overlooked when prioritizing protection, incident response and recovery.
- Example improvement actions
- Reconcile inventories, assign owners, classify information, map critical dependencies and maintain records as systems and services change.
Security Controls & Data Protection
Proportionate safeguards for platforms, networks, applications and information.
- Control objective
- Implement and maintain safeguards that address relevant threats and protect information confidentiality, integrity and availability.
- Typical evidence reviewed
- Security baselines, configuration records, patch and vulnerability reports, network rules, encryption settings and approved exceptions.
- Common control deficiencies
- Inconsistent hardening, overdue remediation, excessive network access, weak data handling and unreviewed exceptions.
- Potential business impact
- Unauthorized disclosure, alteration or interruption of information and services, with potential operational and regulatory consequences.
- Example improvement actions
- Prioritize remediation, standardize secure configurations, review segmentation and data safeguards, and verify that agreed controls operate effectively.
Identity & Access Management
Controlled access for users, administrators, systems and third parties.
- Control objective
- Grant and maintain access according to legitimate business need, least privilege and accountable identity lifecycle processes.
- Typical evidence reviewed
- Access requests and approvals, joiner-mover-leaver records, privileged account inventories, authentication settings and periodic access reviews.
- Common control deficiencies
- Orphaned accounts, excessive privileges, weak authentication, inconsistent access removal and incomplete privileged activity oversight.
- Potential business impact
- Unauthorized access, misuse of privileged capabilities and difficulty attributing activity during an incident.
- Example improvement actions
- Strengthen identity lifecycle workflows, risk-based authentication, privileged access controls, recertification and timely access revocation.
Third-Party Security
Cybersecurity responsibilities and dependencies across supplier relationships.
- Control objective
- Assess and manage third-party cybersecurity exposure throughout selection, contracting, service delivery and exit.
- Typical evidence reviewed
- Supplier inventories, due diligence, risk assessments, contractual security terms, assurance reports, access records and exit arrangements.
- Common control deficiencies
- Unassessed critical providers, unclear responsibilities, missing incident notification terms and limited ongoing monitoring.
- Potential business impact
- Supplier incidents or service failures can expose information, disrupt operations and complicate the institution's response obligations.
- Example improvement actions
- Classify providers by risk, define security and notification responsibilities, review evidence periodically and plan continuity and exit options.
Security Monitoring & Detection
Visibility and analysis of security-relevant activity across critical environments.
- Control objective
- Detect and analyze potentially adverse events with monitoring coverage and escalation arrangements appropriate to the institution's risks.
- Typical evidence reviewed
- Log source inventories, monitoring rules, alert records, triage procedures, escalation records and detection validation results.
- Common control deficiencies
- Missing critical log sources, poorly tuned alerts, unclear triage ownership and detection scenarios that have not been validated.
- Potential business impact
- Incidents may remain unnoticed or be escalated late, increasing the difficulty of limiting their consequences.
- Example improvement actions
- Expand risk-based monitoring coverage, tune detection rules, clarify alert handling and periodically test detection and escalation paths.
Incident Response
Coordinated decisions, analysis, containment, reporting and communication during incidents.
- Control objective
- Maintain a coordinated ability to manage cybersecurity incidents, limit their effects and meet applicable communication and reporting obligations.
- Typical evidence reviewed
- Response plans, classification criteria, contact lists, incident records, communications, exercise results and lessons learned.
- Common control deficiencies
- Unclear escalation, incomplete playbooks, untested roles and reporting responsibilities that do not reflect applicable requirements.
- Potential business impact
- Delayed containment, inconsistent communications and loss of evidence can increase disruption and hinder incident handling.
- Example improvement actions
- Define classification and escalation, update response procedures, agree communication duties, exercise scenarios and track lessons through corrective actions.
Business Continuity & Recovery
Preparedness to maintain or restore critical services following disruption.
- Control objective
- Align continuity and recovery capabilities with critical service priorities, dependencies and agreed recovery requirements.
- Typical evidence reviewed
- Business impact analysis, continuity and recovery plans, backup records, restoration tests, exercise results and dependency assessments.
- Common control deficiencies
- Unvalidated backups, unclear recovery priorities, outdated plans and exercises that omit critical dependencies.
- Potential business impact
- Extended service interruption, unavailable information and uncertainty about the institution's ability to restore essential operations.
- Example improvement actions
- Confirm recovery requirements, test restoration, coordinate business and IT plans and follow up on exercise findings.
Audit, Evidence & Improvement
Traceable evaluation, clear findings and accountable corrective actions.
- Control objective
- Evaluate controls against defined criteria using sufficient relevant evidence and maintain an accountable improvement process.
- Typical evidence reviewed
- Audit scope and plans, test records, evidence references, findings, management responses and verified corrective action status.
- Common control deficiencies
- Unsupported conclusions, incomplete evidence trails, unclear action ownership and closure based only on unverified statements.
- Potential business impact
- Management may lack a reliable basis for risk decisions, and unresolved control weaknesses can persist without effective oversight.
- Example improvement actions
- Define testing and evidence standards, link findings to criteria and risk, assign corrective action owners and verify closure while preserving audit independence.
AUDIT METHODOLOGY
From Regulatory Requirements to Evidence-Based Assurance
A scoped audit connects applicable criteria to evidence, appropriate testing and risk-based conclusions. The extent of testing and form of reporting are agreed before work begins.
Scope & Criteria
Define applicable regulations, organizational boundaries, systems, processes, and audit criteria.
Evidence Collection
Review policies, risk registers, system configurations, logs, reports, technical controls, and supporting documentation.
Control Testing
Evaluate control design, implementation, and operating effectiveness using appropriate audit procedures.
Findings & Risk Evaluation
Document deficiencies, supporting evidence, business impact, root causes where supported, and risk-based recommendations.
Reporting & Follow-Up
Deliver audit results, discuss remediation priorities, and support agreed follow-up verification without compromising auditor independence.
IMPLEMENTATION & REMEDIATION
Building Sustainable Regulatory Compliance
Implementation support connects regulatory requirements with practical controls, accountable ownership and evidence that teams can maintain.
Explore an implementation phase
Assess
Assess the current cybersecurity environment, existing controls, critical dependencies and relevant gaps.
Assess
Assess the current cybersecurity environment, existing controls, critical dependencies and relevant gaps.
Map Requirements
Map applicable regulatory requirements to accountable controls, responsible owners and evidence needs.
Design Controls
Design policies, procedures, responsibilities and technical safeguards appropriate to the institution's risks and operating model.
Implement
Support practical implementation, assigned responsibilities and staff awareness within the agreed scope.
Validate
Validate implementation, review control evidence and identify remaining issues requiring corrective action.
Improve
Track corrective actions, review progress and refine controls as risks, requirements and operational needs change.
An iterative improvement lifecycle, adapted to agreed priorities and scope. Implementation validation supports readiness and does not by itself constitute an independent audit or regulatory approval.
ENGAGEMENT DELIVERABLES
What Your Organization Receives
Clear outputs help management understand the applicable criteria, assessment findings and practical priorities for improvement.
Regulatory Requirements Matrix
Applicable criteria linked to assessment scope, controls, responsibilities and expected evidence.
Evidence-Based Audit Report
Audit conclusions supported by defined procedures, evidence references, scope and limitations.
Compliance Gap Register
Documented differences from applicable criteria, with findings and relevant priorities.
Cybersecurity Risk Assessment
A risk-based view of identified weaknesses, potential consequences and treatment considerations.
Corrective Action Plan
Agreed actions, owners, dependencies, feasible timelines and verification criteria.
Management Summary & Roadmap
A concise management view of findings, key risks, decisions and prioritized next steps.
Actual deliverables depend on the agreed engagement scope. An audit report belongs to a properly scoped audit; implementation or remediation work must not be presented as an independent audit. No deliverable guarantees regulatory acceptance or compliance.
QUESTIONS & ANSWERS
NBG Cybersecurity Audit & Compliance Questions
Which organizations are subject to the NBG Cybersecurity Framework?
The applicable requirements depend on the institution's regulatory category and the relevant legal act. The commercial-bank framework must not be automatically extended to all financial institutions. Microbanks and other regulated entities may be subject to separate requirements.
What is the difference between an NBG cybersecurity audit and a gap assessment?
An independent audit evaluates applicable criteria using defined procedures and supporting evidence. A gap assessment identifies areas requiring improvement and may be performed as part of a compliance implementation engagement. The scope, independence, and form of reporting may differ.
Does preparing cybersecurity policies guarantee compliance?
No. Compliance requires appropriately designed, implemented, and operating controls supported by reliable evidence. Documentation alone is insufficient.
What evidence is typically reviewed during an audit?
Depending on the scope, evidence may include policies, risk assessments, asset inventories, access reviews, security monitoring records, incident documentation, continuity testing, third-party assessments, and technical configurations.
Can IO Consulting help remediate audit findings?
Yes. Implementation and remediation support can be provided under an appropriately scoped engagement. Independence and conflict-of-interest safeguards must be considered if a subsequent independent audit is also requested.
How frequently should the framework be reviewed?
Review and audit frequency should follow the applicable current regulatory requirements, supervisory instructions, and the institution's risk management arrangements. The governing legal text and the institution's category must be checked before setting a review or audit schedule.
NBG CYBERSECURITY FRAMEWORK
Cybersecurity Beyond Compliance.
IO Consulting supports financial institutions in assessing alignment with the National Bank of Georgia’s cybersecurity requirements, conducting independent audits, and strengthening information security management practices.
Our experts help identify control gaps, develop risk-based remediation plans, and implement security measures needed to address applicable regulatory requirements.
Independent Assessment • Practical Recommendations • Risk-Based Approach
Audit and implementation are distinct engagements. If both are requested, independence and conflicts of interest are assessed for the specific scope before work begins.