Who Needs to Comply with NY DFS 23 NYCRR 500?
Even Out-of-State Agencies Must File
Many insurance agencies assume that if they aren’t headquartered in New York, they don’t need to comply. That’s false.
If your agency holds a New York insurance license—even if you’re based in another state—you must file annually with NY DFS.
Why do agencies get licensed in NY even if they’re not located there?
- They serve clients with vacation homes, boats, or other assets in New York.
- They insure clients whose children attend school in NY.
- They write auto policies for clients with NY-registered vehicles.
If your agency has any policies tied to New York, you’re required to file.
Limited Exemptions: Are You Partially Exempt?
Agencies may qualify for limited exemptions under NY DFS if they meet at least one of the following criteria:
- Fewer than 20 employees (including independent contractors) located in NY or responsible for NY business.
- Less than $7,500,000 in gross annual revenue from NY business in the last three fiscal years.
- Less than $15,000,000 in total year-end assets, including all affiliates.
💡 Important: If you qualify for a limited exemption, you must still file annually with NY DFS. You are only exempt from some sections of 23 NYCRR 500—not all.
What Sections Are Agencies With Limited Exemptions Exempt From?
If your agency qualifies for a limited exemption, you are exempt from the following sections:
- 500.4 – Chief Information Security Officer (CISO): Exempt agencies do not need to appoint a formal CISO.
- 500.5 – Penetration Testing & Vulnerability Assessments: Exempt agencies are not required to conduct annual penetration testing.
- 500.6 – Audit Trail: Exempt agencies do not need to maintain 5-year financial transaction records or 3-year cybersecurity event logs.
- 500.8 – Secure Software Development Practices: Exempt agencies are not required to follow specific development security protocols.
- 500.10 – Use of Qualified Cybersecurity Personnel: Exempt agencies do not need to hire an in-house cybersecurity expert or third-party provider.
- 500.14 – Cybersecurity Awareness Training: Exempt agencies are not mandated to conduct staff cybersecurity training programs.
- 500.15 – Multi-Factor Authentication (MFA) Policies: Exempt agencies are not required to enforce MFA in all cases.
- 500.16 – Encryption of Nonpublic Information: Exempt agencies do not need to encrypt all sensitive client data.
What Does This Mean for Your Agency?
Even if you qualify for some exemptions, your agency must still comply with the remaining sections of NY DFS 23 NYCRR 500—including filing your annual attestation.
What Happens If Your Agency Isn’t Compliant?
Failing to meet NY DFS cybersecurity requirements isn’t just risky—it can be costly.
🚨 Consequences of Non-Compliance:
❌ Severe financial penalties – Fines of up to $75,000 per day for agencies that knowingly fail to comply.
❌ Cybersecurity breaches & data loss – Agencies that lack proper safeguards are at higher risk of cyberattacks.
❌ Regulatory scrutiny – Failing to file can impact your ability to operate under DFS regulations.
❌ Loss of client trust – Customers expect their data to be protected—non-compliance damages your reputation.
How to Ensure Compliance Before April 15th
Many agencies think they’re compliant—until they take a closer look.
To help NY agencies quickly assess their compliance status, we’ve put together a free, easy-to-use checklist covering:
✅ What’s required under NY DFS 23 NYCRR 500
✅ The most common compliance gaps NY agencies face
✅ How to fix compliance issues before the April 15th deadline
📥 Download Your Free NY DFS Compliance Checklist Here
Don’t Wait Until It’s Too Late
With the April 15th NY DFS deadline approaching fast, agencies that wait until the last minute risk fines, regulatory scrutiny, and security vulnerabilities.
📥 Step 1: Download Your NY DFS Compliance Checklist
📅 Step 2: Schedule a Free Compliance Check
💡 Step 3: Ensure your agency is protected before the deadline.
🔍 Not sure if you’re compliant? Let’s find out together.
Get a Free NY DFS Compliance Consultation Before the Deadline
At Archway Computer, we specialize in helping NY insurance agencies meet cybersecurity compliance requirements.
For a limited time, we’re offering a free 10-minute compliance consultation where we’ll:
✔️ Review your agency’s cybersecurity & compliance setup
✔️ Identify gaps that could put your agency at risk
✔️ Provide actionable steps to fix compliance issues before April 15th
