Information Protection: CIP-011-3 R1
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By Gabriel Bailey
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In the 2026 Compliance Monitoring and Enforcement Program Implementation Plan (CMEP IP), the Electric Reliability Organization (ERO) identified Grid Transformation as a potential risk to the Bulk Electric System (BES). As the BES continues to expand and change, the increased reliance on third parties to perform day-to-day operations of generation facilities can increase the risk of unauthorized personnel accessing sensitive information, including BES Cyber System Information (BCSI).
To address this risk, the 2026 CMEP IP calls out CIP-011-3 R1, which calls on Responsible Entities to identify BCSI and implement methods to protect and handle it securely. In addition to implementing CIP-011-3 R1, Texas RE recommends taking the following best practices into consideration:
- Implement multi-factor authentication when accessing BCSI to reduce the risk of unauthorized access.
- Perform periodic training for applicable staff on how to securely handle BCSI.
- Ensure that Service Level Agreements (SLAs) cover the secure handling, maintenance, and destruction of BCSI if you are working with a cybersecurity vendor.
The establishment of a robust BCSI protection program can reduce the risk of exposing sensitive information. For further guidance on implementing best practices related to information protection, Texas RE encourages Responsible Entities to review the NIST Special Publication 800-53 Rev. 5.
