Executive Summary

The U.S. Coast Guard (USCG) is embarking on a landmark modernization of its cybersecurity capabilities, fueled by nearly $25 billion in new funding and expanded legal authorities. An analysis by the Center for Strategic and International Studies (CSIS) describes this as a 'generational change' that will transform the agency's ability to protect the U.S. Marine Transportation System (MTS) from cyber threats. The investment will enable the USCG to upgrade legacy technology, implement a zero-trust architecture, and enhance its role in national cybersecurity operations. Furthermore, new and proposed regulations will empower the USCG to enforce minimum cybersecurity standards on vessels and maritime facilities, marking a significant step towards securing the nation's critical maritime infrastructure.

Regulatory Details

The transformation is driven by a combination of funding and policy changes:

• Funding: The 'One Big Beautiful Bill Act' provides unprecedented resources, including $2.2 billion specifically for the maintenance and modernization of command, control, communication, computer, and cyber (C5) assets. This funding supports the USCG's 'FD 2028' modernization plan.

• Expanded Authorities: Recent regulatory updates and the pending USCG Authorization Act (CGAA) of 2025 broaden the USCG's mandate. The Captain of the Port (COTP) is now explicitly empowered to address cyber threats to vessels and facilities within their jurisdiction. New rules also mandate cyber incident reporting from maritime stakeholders.

• Proposed Rulemaking: A Notice of Proposed Rulemaking (NPRM) aims to establish baseline cybersecurity standards for the industry. This would require U.S.-flagged vessels and certain facilities to develop and maintain cyber incident response plans, conduct regular security drills, and designate a qualified cybersecurity officer.

Affected Organizations

This overhaul will affect the entire U.S. maritime ecosystem:

• U.S. Coast Guard: The agency itself will undergo a significant technological and organizational transformation, with upgrades to its USCG Cyber Command and the establishment of a new program office for C5 and Intelligence.
• Marine Transportation System (MTS) Stakeholders: Ship owners, port operators, terminal facilities, and other private sector partners will be required to comply with new cybersecurity standards and reporting mandates.

Compliance Requirements

The proposed rules will likely require MTS stakeholders to:

1. Develop Cyber Incident Response Plans: Create formal plans for how to respond to and recover from a cybersecurity incident.
2. Conduct Drills and Exercises: Regularly test their response plans to ensure effectiveness.
3. Designate a Cybersecurity Officer: Appoint a specific individual responsible for the organization's cybersecurity posture and compliance.
4. Implement Minimum Security Controls: Adhere to a baseline of cybersecurity best practices, which will likely align with frameworks like the NIST Cybersecurity Framework.
5. Report Incidents: Comply with mandatory reporting requirements for significant cyber incidents.

Implementation Timeline

While the funding is being allocated now, the full implementation of the FD 2028 modernization plan will occur over the next several years. The timeline for the proposed rulemaking to become final and enforceable is still pending, but maritime organizations should begin preparing for these new requirements now.

Impact Assessment

• For the USCG: The funding and authorities will allow the agency to transition from a reactive to a proactive cybersecurity posture, better equipping it to defend against nation-state and criminal threats targeting the maritime sector.
• For the Maritime Industry: The new regulations will increase the operational and financial burden on some stakeholders but will ultimately raise the security baseline for the entire industry, reducing systemic risk. Companies that have already invested in cybersecurity will be well-positioned, while those lagging behind will face a significant compliance challenge.
• National Security: This initiative strengthens the security and resilience of critical national infrastructure, protecting the flow of commerce and military logistics that depend on the MTS.

Compliance Guidance

Maritime organizations should take the following steps to prepare:

1. Conduct a Gap Analysis: Assess your current cybersecurity posture against established frameworks like the NIST Cybersecurity Framework and the anticipated requirements of the NPRM.
2. Appoint a Cybersecurity Lead: If you don't already have one, designate a person responsible for cybersecurity to lead compliance efforts.
3. Develop an Incident Response Plan: Don't wait for the rule to be finalized. Begin developing or refining your incident response plan now.
4. Budget for Investment: Plan for necessary investments in cybersecurity technology, personnel, and training to meet the new standards.