Replacing the FFIEC CAT with NIST CSF 2.0

After nearly a decade of use, the Federal Financial Institutions Examination Council (FFIEC) is officially retiring its Cybersecurity Assessment Tool (CAT) on August 31, 2025. Originally released in 2015, the CAT served as a foundational tool for financial institutions—especially banks and credit unions—to assess their cybersecurity preparedness and benchmark control maturity. But in today’s rapidly evolving threat landscape, a more flexible, comprehensive, and forward-looking framework is needed.

Enter the NIST Cybersecurity Framework (CSF) 2.0—a modern, government-backed alternative that financial institutions are being urged to adopt in place of the CAT. This transition is not simply a matter of regulatory compliance; it’s an opportunity to enhance your institution’s resilience and future-proof your cybersecurity program.

Why the FFIEC Is Retiring the CAT

The FFIEC CAT was a widely adopted tool that translated cybersecurity principles into practical evaluation criteria across key domains like cyber risk management, threat intelligence, and incident response. However, the tool has not seen meaningful updates since its release. Several limitations prompted its retirement:

• Static structure: It could not easily keep pace with emerging cyber threats.
• Limited scope: Areas such as supply chain risk, governance, and continuous monitoring were insufficiently addressed.
• Lack of flexibility: It focused more on assessment than on implementation and improvement.

As regulatory expectations have grown and cyber threats have intensified, the FFIEC made a deliberate choice not to update the CAT, but rather to encourage adoption of dynamic frameworks such as NIST CSF 2.0 and other complementary tools.

What Makes NIST CSF 2.0 a Better Fit?

Released in February 2024, NIST CSF 2.0 builds upon the original 2014 version and offers a more comprehensive and scalable approach to cybersecurity. Its structure is rooted in six core functions:

1. Govern – Define policies, risk tolerance, roles, and responsibilities.
2. Identify – Understand and document cybersecurity risks to systems and assets.
3. Protect – Implement controls to safeguard systems and limit impacts.
4. Detect – Monitor and identify cybersecurity events promptly.
5. Respond – Take appropriate actions to contain and recover from incidents.
6. Recover – Restore capabilities or services after a disruption.

Key advantages of NIST CSF 2.0 include:

• Current and adaptive: Reflects today’s threat landscape and continues to evolve.
• Comprehensive scope: Covers governance, third-party risk, supply chain, and continuous improvement—areas lacking in the CAT.
• Regulatory recognition: Widely acknowledged by federal regulators (e.g., NCUA, OCC, FDIC) as a gold standard.
• Scalable and sector-neutral: Applicable to organizations of all sizes and levels of maturity.
• Alignment with supporting tools: Designed to work alongside resources such as the CISA Cybersecurity Performance Goals, CRI Cyber Profile, and CIS Critical Security Controls.

Practical Steps for Transitioning to NIST CSF 2.0

Replacing the CAT with NIST CSF 2.0 requires more than just adopting a new checklist. Institutions must take a strategic and phased approach to ensure a smooth transition.

1. Perform a CAT-to-CSF Mapping and Gap Analysis

• Compare your existing CAT results to the CSF 2.0 structure.
• Identify gaps in governance, supply chain security, and continuous monitoring.
• Use the CRI Cyber Profile as a mapping bridge for a familiar experience.

2. Select a Framework That Aligns with Your Institution’s Needs

• While NIST CSF 2.0 is the most comprehensive, smaller or less resourced institutions may also benefit from using CISA’s Cross-Sector CPGs as a stepping stone.

3. Engage Leadership and Stakeholders

• Cybersecurity is an enterprise-wide concern. Secure buy-in from the board, senior management, and compliance teams.
• Use executive-friendly summaries, like those provided in frameworks such as the Adaptive Cybersecurity Framework (aCSF), to communicate progress.

4. Develop a Transition Plan

• Include a gap analysis, risk prioritization, staffing/resource requirements, and training.
• Establish a timeline for implementation and periodic reassessment.

5. Formalize Cybersecurity Governance

• Governance is a new pillar in CSF 2.0 and must be treated as a foundational function.
• Ensure policies are documented, responsibilities are assigned, and accountability is clear.

6. Invest in Continuous Improvement

• Leverage tools like automated threat intelligence and ongoing monitoring.
• Embrace the iterative nature of the CSF to maintain relevance over time.

7. Prepare for Evolving Regulatory Expectations

• Document your transition strategy, governance structures, and selected tools.
• Be ready to explain to regulators how your new framework meets or exceeds previous CAT expectations.

Addressing Common Challenges in the Transition

For many institutions—especially credit unions and smaller banks—implementing NIST CSF 2.0 can feel daunting. Challenges may include:

• Resource limitations (personnel, time, and budget)
• Complexity of the framework
• Translating high-level concepts into action
• Communicating risks effectively to non-technical boards

Solutions include partnering with advisors familiar with both NIST CSF 1.1 and 2.0, using services like the Adaptive Cybersecurity Framework (aCSF) to operationalize the CSF, and leveraging simplified resources such as the NIST CSF Quick Start Guides.

Why Acting Now Matters

Financial institutions can’t afford to wait until the CAT’s retirement date to begin planning. Delaying the transition risks falling behind in both compliance and cybersecurity maturity. Immediate benefits of starting now include:

• Regulatory readiness: Demonstrate proactive alignment with examiner expectations.
• Improved cyber resilience: Better address evolving threats like ransomware and supply chain attacks.
• Streamlined board communication: Provide clarity and confidence in cybersecurity investments.
• Modernized risk posture: Build a future-proof, risk-based security program.

Final Thoughts: A Strategic Opportunity for Financial Institutions

The sunset of the FFIEC CAT marks a shift not just in tools, but in mindset. It’s an invitation for financial institutions to modernize their cybersecurity strategies and embed a culture of continuous improvement. NIST CSF 2.0 isn’t just a framework—it’s a blueprint for resilience in the face of an increasingly complex cyber landscape.

Whether you're a large regional bank, a small credit union, or something in between, now is the time to take stock, plan your path forward, and adopt a framework that evolves with the threats you face.

How Compass Can Help Your Institution Transition to NIST CSF 2.0

Successfully transitioning from the FFIEC CAT to NIST CSF 2.0 requires more than simply adopting a new framework—it demands a comprehensive understanding of regulatory expectations, cybersecurity best practices, and practical implementation strategies. That’s where Compass IT Compliance can help. Since 2010, our team has worked with financial institutions of all sizes to assess cybersecurity maturity, reduce risk, and align with evolving regulatory standards. We offer tailored services to guide your organization through every phase of the transition—from conducting CAT-to-CSF mapping and gap analysis, to developing a custom roadmap based on your risk profile, to providing ongoing advisory support and reporting that resonates with executive leadership and board members.

Our cybersecurity consultants and assessors bring deep expertise in NIST CSF 1.1 and 2.0, the CRI Cyber Profile, and CISA’s Performance Goals. We understand the challenges that financial institutions face—especially in areas such as third-party risk, limited staffing, or communicating risk to non-technical audiences—and we’re here to help you navigate those complexities. Whether you need a one-time assessment or a long-term partner, Compass can provide the tools, expertise, and strategic insight to help you build a resilient, sustainable, and regulator-ready cybersecurity program.

Contact us today to learn how Compass can support your cybersecurity maturity journey and ensure your institution is fully prepared for a post-CAT world.