For decades, the federal government has relied on sector-specific regulations to safeguard critical infrastructure. As an example, organizations including the North American Electric Reliability Corporation Critical Infrastructure Protection (NERC CIP) set standards for the energy sector, while the Transportation Security Administration issues pipeline directives and the Environmental Protection Agency makes water utility rules.
While these frameworks were designed to protect individual sectors, the digital transformation of operational technology and information technology has made such compartmentalization increasingly risky.
Today, the boundaries between sectors are blurring – and the gaps between their governance frameworks are becoming attackers’ entry points.
The problem is the lack of harmony.
Agencies are enforcing strong but disconnected standards, and compliance often becomes an end in and of itself, rather than a pathway to resilience.
With the rollout of the Cyber Incident Reporting for Critical Infrastructure Act (CIRCIA) and the release of the National Institute of Standards and Technology’s Cybersecurity Framework 2.0, the United States has an opportunity to modernize oversight, making it more adaptive, consistent and outcome based.
Doing so will require a cultural shift within federal governance: from measuring compliance to ensuring capability.
Overlapping mandates, uneven protection
Every critical infrastructure sector has its own set of cybersecurity expectations, but those rules vary widely in scope, maturity and enforcement. The Energy Department may enforce rigorous incident response requirements for electric utilities, while TSA might focus its directives on pipeline resilience. Meanwhile, small water utilities, overseen by the EPA, often lack the resources to fully comply with evolving standards.
This uneven terrain creates what I call “regulatory dissonance.” One facility may be hardened according to its regulator’s rulebook, while another connected through shared vendors or data exchanges operates under entirely different assumptions. The gaps between these systems can create cascading risk.
The 2021 Colonial Pipeline incident illustrated how oversight boundaries can become national vulnerabilities. While the energy sector had long operated under NERC CIP standards, pipelines fell under less mature guidance until TSA introduced emergency directives after the fact. CIRCIA was conceived to close such gaps by requiring consistent incident reporting across sectors. Yet compliance alone won’t suffice if agencies continue to interpret and implement these mandates in isolation.
Governance as the common language
Modernizing oversight requires more than new rules; it requires shared governance principles that transcend sectors. NIST’s Cybersecurity Framework 2.0 introduces a crucial element in this direction: the new “Govern” function, which emphasizes defining roles, responsibilities and decision-making authority within organizations. This framework encourages agencies and their partners to move from reactive enforcement toward continuous, risk-informed governance.
For federal regulators, this presents an opportunity to align oversight frameworks through a “federated accountability” model. In practice, that means developing consistent taxonomies for cyber risk, harmonized maturity scoring systems and interoperable reporting protocols.
Agencies could begin by mapping common controls across frameworks, aligning TSA directives, EPA requirements and DOE mandates to a shared baseline that mirrors NIST Cybersecurity Framework principles. This kind of crosswalk not only streamlines oversight, but also strengthens public-private collaboration by giving industry partners a clear, consistent compliance roadmap.
Equally important is data transparency. If the Cybersecurity and Infrastructure Security Agency , DOE and EPA share a common reporting structure, insights from one sector can rapidly inform others. A pipeline incident revealing supply chain vulnerabilities could immediately prompt water or energy operators to review similar controls. Oversight becomes a feedback loop rather than a series of disconnected audits.
Engineering resilience into policy
One of the most promising lessons from the technology world comes from the “secure-by-design” movement: Resilience cannot be retrofitted. Security must be built into the design of both systems and the policies that govern them.
In recent years, agencies have encouraged vendors to adopt secure development lifecycles and prioritize vulnerability management. But that same thinking can, and should, be applied to regulation itself. “Secure-by-design oversight” means engineering resilience into the way standards are created, applied and measured.
That could include:
- Outcome-based metrics: Shifting from binary compliance checks (“Is this control in place?”) to maturity indicators that measure recovery time, detection speed or incident containment capability.
- Embedded feedback loops: Requiring agencies to test and refine directives through simulated exercises with industry before finalizing rules, mirroring how developers test software before release.
- Adaptive updates: Implementing versioned regulatory frameworks that can be iteratively updated, similar to patch cycles, rather than rewritten every few years through lengthy rulemaking.
Such modernization would not only enhance accountability but also reduce the compliance burden on operators who currently navigate multiple, sometimes conflicting, reporting channels.
Making oversight measurable
As CIRCIA implementation begins in earnest, agencies must ensure that reporting requirements generate actionable insights. That means designing systems that enable real-time analysis and trend detection across sectors, not just retrospective compliance reviews.
The federal government can further strengthen resilience by integrating incident reporting into national situational awareness frameworks, allowing agencies like CISA and DOE to correlate threat intelligence and issue rapid, unified advisories.
Crucially, oversight modernization must also address the human dimension of compliance. Federal contractors, third-party service providers and local operators often sit at the outer edge of regulatory reach but remain central to national resilience. Embedding training, resource-sharing and technical assistance into federal mandates can elevate the entire ecosystem, rather than penalizing those least equipped to comply.
The next step in federal cyber strategy
Effective harmonization hinges on trust and reciprocity between government and industry. The Joint Cyber Defense Collaborative (JCDC) has demonstrated how voluntary partnerships can accelerate threat information sharing, but most collaboration remains one-directional.
To achieve true synchronization, agencies must move toward reciprocal intelligence exchange, aggregating anonymized, cross-sector data into federal analysis centers and pushing synthesized insights back to operators. This not only democratizes access to threat intelligence, but also creates a feedback-driven regulatory ecosystem.
In the AI era, where both defenders and attackers are leveraging machine learning, shared visibility becomes the foundation of collective defense. Federal frameworks should incorporate AI governance principles, ensuring transparency in data usage, algorithmic accountability and protection against model exploitation, while enabling safe, responsible innovation across critical infrastructure.
A unified future for resilience governance
CIRCIA and NIST Cybersecurity Framework 2.0 have laid the groundwork for a new era of harmonized oversight — one that treats resilience as a measurable capability rather than a compliance checkbox.
Achieving that vision will require a mindset shift at every level of governance. Federal regulators must coordinate across agencies, industry partners must participate in shaping standards, and both must view oversight as a dynamic, adaptive process.
When frameworks align, insights flow freely, and regulations evolve as quickly as the threats they are designed to mitigate, compliance transforms from a bureaucratic exercise into a national security asset. Oversight modernization is the blueprint for a more resilient nation.
Dr. Jerome Farquharson is managing director and senior executive advisor at MorganFranklin Cyber.
The post Harmonizing compliance: How oversight modernization can strengthen America’s cyber resilience first appeared on Federal News Network.