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Here’s How the OT Cybersecurity Coalition Wants CISA to Protect Federal OT

By Freedom251 Team · · 5 min read

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The Operational Technology Cybersecurity Coalition (OTCC) is urging the Cybersecurity and Infrastructure Security Agency (CISA) to issue a binding operational directive (BOD) requiring federal civilian agencies to adopt a clearer, enforceable baseline for operational technology security. The proposal would assign agency-level responsibility, apply relevant existing requirements to OT, and prioritize controls such as asset inventories, segmentation, access management, incident preparation, and verified recovery. It is a coalition proposal—not an adopted CISA directive. In its October 6, 2026 report, CyberScoop said CISA had not responded to a request for comment before publication.

What OT means in federal agencies

Operational technology (OT) comprises programmable systems and devices that monitor or affect the physical environment. It includes industrial control systems, building automation, transportation systems, physical-access controls, and environmental monitoring. Federal OT can also include specialized equipment used in hospitals and laboratories. The Government Accountability Office (GAO) describes these examples in its September 30, 2026 report, Internet of Things: OMB Action Needed to Ensure Agencies Secure Their Networked Devices.

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Because OT interacts with physical processes, cybersecurity failures can affect safety and essential services, not just data or office IT. The OTCC argues that agencies need security requirements that account for those operational realities while making responsibilities and minimum expectations clearer.

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What the coalition wants CISA to require

The OTCC’s October 6, 2026 paper, “Know It. Control It. Contain It.: A Binding Operational Directive for OT Cybersecurity”, organizes its proposal around three recommendations.

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1. Give OT cybersecurity a clear owner

Agencies would designate a senior official or unified office to oversee OT cybersecurity governance. The coalition says that responsibility should cover validated asset inventories, configuration baselines, backup and recovery, incident preparation, and risk reporting. It also calls for OT risk to be integrated into enterprise risk management, with CIOs and facilities teams coordinating their security roles.

2. Apply relevant federal requirements to OT

The coalition wants CISA to review National Security Agency OT requirements and determine which apply to civilian agencies, enforce relevant existing CISA directives in OT environments, and require implementation of applicable Office of Management and Budget (OMB) requirements. It acknowledges that CISA has already included OT requirements in some directives: “To be fair, CISA has incorporated OT security requirements into prior directives (such as BODs 23-01, 23-02, and 26-04) alongside a host of technical guidance.” The coalition’s case is for an encompassing directive focused specifically on OT, rather than an assertion that current federal guidance contains no OT provisions.

3. Prioritize controls around CISA performance goals

The proposal would align implementation with CISA’s Cross-Sector Cybersecurity Performance Goals, prioritizing controls for managed service providers, asset management, independent validation, identity and access management, least privilege, incident response, segmentation, backups, and preparedness. The coalition also suggests that CISA could establish OT-specific performance goals.

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What “know it, control it, contain it” means in practice

The coalition’s phrase describes a practical security sequence: understand which OT assets exist, put enforceable safeguards around them, and limit the damage if a system is compromised. Its proposed implementation areas include:

  • Know it: Improve OT visibility through continuous diagnostics and validated asset inventories, and document configuration baselines.
  • Control it: Use pragmatic microsegmentation, enforce remote-access rules, and apply identity, access, and least-privilege controls.
  • Contain it: Prepare documented incident-response processes and maintain backup and recovery capabilities that have been verified.

These are proposed priorities, not proof that every agency currently lacks each control. The coalition is asking for a consistent federal baseline and clearer accountability for implementing it.

Why the proposal is timely—and what GAO found

The coalition says CISA lacks a holistic view of federal OT assets and risks, that agencies apply existing requirements inconsistently, and that OT incidents can disrupt safety and essential services. It points to attacks affecting water and wastewater systems as part of the broader context for improving OT security, but the proposed directive is aimed at federal civilian agencies; it is not a claim that a new BOD would have prevented those water-sector incidents.

A September 2026 GAO review offers a specific measure of federal implementation. Among the 22 civilian agencies covered by the Chief Financial Officers Act that GAO reviewed, the agency-reported status of inventories for covered networked Internet of Things and OT devices was:

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OMB inventory requirement Agencies meeting it
Had established an inventory of covered networked devices 15 of 22
Were maintaining inventories 11 of 22
Included all information OMB required for each device 10 of 22
Had fully addressed all three OMB requirements 7 of 22

These figures are GAO’s September 2026 snapshot of the 22 agencies it reviewed, not a count of every federal agency and not a measure of private-sector security. GAO said agencies cited technical and resource constraints and competing priorities. Its report recommended that OMB issue updated cybersecurity guidance and oversee implementation. GAO summarized the gap this way: “Until OMB issues this guidance, agencies will lack appropriate direction on how and when to complete their device inventories.” The findings show incomplete implementation of specific inventory requirements; they do not establish that all OT was unprotected or that a new CISA directive would prevent incidents.

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Who would be bound by a directive

The proposed BOD would establish requirements for the federal civilian agencies within its scope. It would not, by itself, require private companies, state agencies, or local operators to follow the directive. The coalition does expect a federal mandate to signal which practices CISA considers important to infrastructure owners and operators.

Michael Garcia, OTCC policy director and, until recently, an agency employee, described that signaling rationale to CyberScoop: “One, it does make sure that the government is taking its own medicine,” said Garcia, who until recently worked at the agency. “You should practice what you preach. … Second, it sends a very strong signal to the private sector that, ‘This is what we think is important: As an OT partner, owner or operator or critical infrastructure owner or operator, [this is what] you should ask other providers to do.’”

How a dedicated directive would fit with resilience planning

The coalition presents a dedicated OT BOD as complementary to resilience planning, not a substitute for it. In its account, CISA’s CI Fortify plans for an assumed compromise, isolation, continued operations, and recovery. A dedicated directive would establish prevention and containment measures, including asset visibility, segmentation, and access controls. Together, those layers address both reducing the chance or spread of compromise and sustaining or restoring operations if a compromise occurs.

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The coalition also argues that OT deserves an encompassing directive as cyber operations become more capable. Its paper says: “But as AI reduces the technical barriers to sophisticated cyber operations, enabling adversaries to identify weaknesses, accelerate reconnaissance, and move laterally through poorly segmented operational environments with greater speed and scale, it is time for an encompassing BOD solely focused on OT security.” This is the coalition’s rationale for its proposal, not an adopted CISA assessment or a guarantee that a directive would prevent attacks.

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CISAcybersecurityfederal agenciesoperational technologyOT-Security

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