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Cybersecurity Regulatory Landscape in Saudi Arabia:

 

An Analysis of SAMA CSF, NCA ECC, and CST CRF

 

Author: Cyberatos Team

 

 

 

 

Table of Contents

 

I       Introduction

II      The Evolution of Cybersecurity Landscape in Saudi Arabia

III     The SAMA Cybersecurity Framework (CSF)

IV     The NCA Essential Cybersecurity Controls (ECC)

V      The CST Cybersecurity Regulatory Framework (CRF)

VI     Strategic Considerations for Compliance with Saudi Cybersecurity Regulations.

VII    Conclusions

VIII   How Cyberatos can help you?

 

 

 

I. Introduction

 

This document provides an in-depth analysis of three pivotal cybersecurity frameworks shaping the regulatory environment in the Kingdom of Saudi Arabia: the Saudi Arabian Monetary Authority (SAMA) Cybersecurity Framework (CSF), the National Cybersecurity Authority (NCA) Essential Cybersecurity Controls (ECC), and the Communications, Space & Technology Commission (CST) Cybersecurity Regulatory Framework (CRF). These frameworks are central to understanding the Kingdom's approach to cybersecurity governance, risk management, and compliance. Their distinct yet complementary roles underscore a national commitment to securing digital assets across critical sectors. This report focuses on these specific frameworks due to their significant impact on financial institutions, government bodies, critical national infrastructure, and the information and communications technology (ICT) sector, collectively forming the bedrock of Saudi Arabia's cybersecurity regulatory ecosystem. Understanding their individual mandates, interdependencies, and the strategic implications for organizations is crucial for effective cybersecurity posture management and regulatory adherence within the Kingdom.

 

II. The Evolving Cybersecurity Landscape in Saudi Arabia

 

The Kingdom of Saudi Arabia is undergoing a period of profound transformation, with digital technologies at the forefront of its national development agenda. This rapid digitalization, while offering immense opportunities, also introduces new and complex cybersecurity challenges. Consequently, the Kingdom has placed a significant emphasis on establishing a robust cybersecurity posture to protect its burgeoning digital economy and critical infrastructure.

 

A. Cybersecurity in the Context of Vision 2030

Saudi Arabia's Vision 2030 is a comprehensive blueprint for economic and social reform, heavily reliant on digital transformation, economic diversification, and the creation of technologically advanced urban centers such as NEOM. The accelerated adoption of technologies including 5G, Artificial Intelligence (AI), the Internet of Things (IoT), and cloud computing is fundamental to achieving these ambitious goals. However, this digital expansion inherently broadens the cyber-attack surface, making comprehensive cybersecurity strategies not merely advisable but essential for the protection of national interests, critical infrastructure, and sustained economic growth. Cybersecurity is explicitly recognized as crucial for national resilience, fostering trust, and enabling economic development within this interconnected digital environment.  

The ambitious digital transformation goals embedded in Vision 2030 serve as a direct catalyst for the development and stringent enforcement of cybersecurity frameworks. As the Kingdom moves towards a digitally-driven economy, the proliferation of digital services and interconnected systems naturally increases vulnerability to cyber threats. This heightened risk environment necessitates stronger defensive measures and a proactive approach to cybersecurity. In response, regulatory bodies such as the National Cybersecurity Authority (NCA), the Saudi Arabian Monetary Authority (SAMA), and the Communications, Space & Technology Commission (CST) have been tasked with issuing and continually updating robust cybersecurity frameworks. These frameworks are designed to manage the evolving risks and ensure that the objectives of Vision 2030 can be realized securely.

Furthermore, the overall success of Vision 2030 is intrinsically linked to the Kingdom's capacity to establish and maintain a digital ecosystem that is both secure and trusted by domestic and international stakeholders. A failure to adequately address cybersecurity risks could undermine efforts towards economic diversification, deter foreign investment, and erode public confidence in digital services. Therefore, the cybersecurity frameworks in place are not just technical guidelines but are critical instruments for building and preserving this trust, thereby directly supporting the broader economic and societal goals articulated in Vision 2030.

 

B. Key Regulatory Authorities and Their Mandates

To navigate the complexities of the modern cyber threat landscape, Saudi Arabia has established several key regulatory authorities, each with a specific mandate to oversee and enhance cybersecurity within distinct sectors. This multi-authority model reflects a strategic approach to addressing the diverse security needs across the Kingdom's economy.

 

 

 

 

 

 

 

 

 

1. National Cybersecurity Authority (NCA): The NCA stands as the central and overarching authority for cybersecurity in Saudi Arabia. It is responsible for formulating national cybersecurity strategies, developing policies and frameworks, and issuing guidelines to protect the Kingdom's national security, critical national infrastructure (CNI), and government services. The NCA's mandate extends across all sectors, establishing it as the primary reference point for cybersecurity matters in the Kingdom. One of its most significant contributions is the Essential Cybersecurity Controls (ECC).  

2. Saudi Arabian Monetary Authority (SAMA): As the central bank of Saudi Arabia, SAMA is also the primary regulator for the financial sector. This includes banks, insurance companies, financing companies, and other financial institutions. SAMA issues specific cybersecurity frameworks, most notably the SAMA Cybersecurity Framework (CSF), designed to ensure the operational resilience and security of financial institutions against cyber threats. 

3. Communications, Space & Technology Commission (CST): Formerly known as the Communications and Information Technology Commission (CITC), the CST is tasked with regulating the telecommunications, space, and technology sectors within Saudi Arabia. This includes oversight of Information and Communications Technology (ICT) service providers. The CST issued the Cybersecurity Regulatory Framework (CRF) to bolster the cybersecurity maturity and practices within the ICT sector. The CST's role has evolved, reflecting the growing importance of these sectors in the national economy.

 

The establishment of these distinct regulatory bodies signifies a deliberate strategy to implement tailored cybersecurity governance. Different sectors, such as finance, government operations, critical national infrastructure, and ICT services, possess unique risk profiles, operational characteristics, and technology dependencies. A single, generic cybersecurity framework might not adequately address these nuanced requirements. Consequently, specialized authorities—SAMA for the financial sector, NCA for government and CNI, and CST for the ICT sector—are empowered to develop and enforce sector-specific frameworks. This allows for more targeted, relevant, and ultimately more effective cybersecurity regulation.

 

However, while such specialization offers clear benefits in terms of focused oversight, a multi-authority model can introduce complexities for organizations, particularly those whose operations span the jurisdictional boundaries of more than one regulator. For instance, an ICT service provider might also handle data classified as part of critical national infrastructure or process financial transactions. Such entities could find themselves needing to understand, implement, and demonstrate compliance with multiple frameworks (e.g., CST CRF, NCA ECC, and SAMA CSF). This can lead to challenges in mapping controls, allocating resources efficiently, and navigating potentially overlapping or even conflicting requirements during audit processes. These interdependencies and potential complexities will be explored further in this report.

 

III. The SAMA Cybersecurity Framework (CSF)

 

The Saudi Arabian Monetary Authority (SAMA) Cybersecurity Framework (CSF) is a critical regulatory instrument designed to fortify the cybersecurity posture of the Kingdom's financial sector. Recognizing the increasing sophistication and frequency of cyber threats targeting financial institutions, SAMA developed the CSF to provide a structured approach to identifying, managing, and mitigating these risks.

 

A. Overview, Objectives, and Scope

The SAMA CSF is fundamentally designed to assist financial institutions in the robust identification and effective management of their cybersecurity risks. The primary objectives of the framework are multi-faceted: to establish a common and consistent approach to addressing cybersecurity concerns across all member organizations; to achieve an optimal and progressively improving level of maturity in the implementation of cybersecurity controls; and to ensure the sound and comprehensive management of cybersecurity risks throughout these institutions. The framework draws inspiration from established international cybersecurity standards and best practices, including those from NIST, ISF, ISO, BASEL, and PCI, adapting them to the specific context of the Saudi financial sector.  

 

The SAMA CSF's applicability is extensive, covering all financial institutions that are regulated by SAMA. This includes, but is not limited to, banks, insurance and reinsurance companies, financing companies, credit bureaus, and financial market infrastructures. The framework's protective ambit extends over a wide range of information assets critical to these institutions. These assets encompass electronic data, physical records, computing devices (such as workstations and ATMs), the technical infrastructure supporting operations (including facilities, equipment, and communication networks), data storage devices, and various applications, software, electronic services, and databases.

 

Furthermore, SAMA has also introduced the Cybersecurity Regulatory Framework and Requirements (CRFR, which appears to be an extension or integral component of the CSF, specifically aimed at evaluating the cybersecurity defenses of Financial Technology (FinTech) enterprises operating within the Kingdom. Also, SAMA introduced the Minimum Verification Controls (MVC, which are standards for identity verification thta must be folowed by member organizations providing services, such as digital wallets, online lending applications, insurance aggregators, and open banking platforms. 

 

A core tenet of the SAMA CSF is its emphasis on a risk-based methodology. This approach is intended to elevate the overall cybersecurity maturity of the entire financial sector, rather than focusing merely on the compliance of individual institutions. The financial sector is characterized by a high degree of interconnectedness, where a vulnerability or security incident at one institution can potentially have systemic repercussions, impacting other entities and overall market stability. By setting a baseline for security controls and encouraging continuous improvement across all regulated entities, the SAMA CSF aims to foster a collective strengthening of defenses. This holistic enhancement contributes significantly to the resilience and trustworthiness of the entire financial ecosystem.

 

Moreover, the framework's explicit goal of facilitating early risk identification and management signals a strategic shift towards proactive, rather than merely reactive, cybersecurity postures. A reactive approach, which primarily involves addressing security breaches after they have occurred, is often significantly more costly and damaging in terms of financial loss, reputational harm, and regulatory consequences. In contrast, proactive cybersecurity, which focuses on identifying potential vulnerabilities and mitigating risks before they can be exploited, is a more effective and sustainable strategy. The SAMA CSF actively promotes this proactive stance by mandating comprehensive risk assessments and the diligent implementation of preventative controls.  

 

B. Key Domains and Principles

The SAMA Cybersecurity Framework (CSF) is structured around several key domains, each addressing a critical aspect of an organization's cybersecurity posture. This domain-based structure ensures a comprehensive approach to managing cyber risks within financial institutions. The principal domains are:

 

 

 

 

SAMA CSF Key Domains

 

 

1. Cyber Security Leadership and Governance: This domain underscores the critical role of senior management and the board of directors in overseeing cybersecurity. It mandates the establishment of clear roles, responsibilities, and accountability for cybersecurity across the organization. Furthermore, it requires the implementation of robust governance frameworks to guide decision-making, risk management processes, and the strategic alignment of cybersecurity objectives with business goals.  

 

2. Cyber Security Risk Management and Compliance: This domain focuses on the systematic identification, analysis, evaluation, and treatment of cybersecurity risks. It requires financial institutions to develop and implement comprehensive risk management methodologies. Additionally, it emphasizes the importance of adhering to relevant national and international regulatory requirements and standards.  

 

3. Cyber Security Operations and Technology: This domain addresses the operational and technical aspects of cybersecurity. It includes requirements for effective incident response capabilities, robust threat detection mechanisms, continuous security monitoring, secure data protection practices, and the implementation of appropriate technological controls such as access controls and encryption.  

 

4. Third-Party Cyber Security: Recognizing the increasing reliance on external vendors and outsourcing, this domain mandates the management of cybersecurity risks associated with third-party relationships. Financial institutions are required to assess and mitigate risks introduced by their suppliers and service providers.  

 

An important development within the SAMA CSF is the integration of Cyber Threat Intelligence (CTI) Principles. These principles, introduced in March 2022, are now an integral component of the CSF, and compliance with them is essential for overall SAMA CSF adherence. This includes strategic CTI principles related to identifying the goals, motivations, and intentions of threat actors.

 

The domain structure of the SAMA CSF reflects a holistic and multi-faceted view of cybersecurity. It acknowledges that effective security is not solely a technical issue but requires strong leadership, robust risk management processes, diligent operations, and careful management of the extended enterprise, including the supply chain. Technical controls, while essential, are insufficient if not supported by appropriate governance structures and a clear understanding of risks. The "Cyber Security Leadership and Governance" domain ensures that there is top-level buy-in and that clear policies are in place. The "Cyber Security Risk Management and Compliance" domain ensures that risks are systematically identified, assessed, and managed. The "Cyber Security Operations and Technology" domain ensures that day-to-day security measures are effectively implemented and maintained. Finally, the "Third-Party Cyber Security" domain addresses the reality that an organization's security is often dependent on the security of its partners and vendors. This comprehensive structure ensures that all critical facets of cybersecurity are considered and addressed.

 

C. Maturity Levels and Compliance Requirements

The SAMA Cybersecurity Framework (CSF) incorporates a structured maturity model to guide financial institutions in progressively enhancing their cybersecurity capabilities. This model defines several distinct maturity levels, typically ranging from Level 0 (Non-existent) to Level 5 (Adaptive). A critical benchmark within this model is Level 3 (Structured and Formalized), which SAMA has stipulated as the minimum acceptable level of cybersecurity maturity for regulated financial institutions. Achieving Level 3 necessitates that an organization has well-defined and formally approved cybersecurity controls in place and, importantly, can consistently demonstrate the effective adoption and implementation of these controls. This includes having a board-endorsed cybersecurity policy that is clearly communicated to all relevant stakeholders, including staff, customers, and third-party vendors.

 

 

 

 

 

SAMA Maturity Model

 

 

 

Compliance with the SAMA CSF involves a comprehensive set of activities and the implementation of specific controls. Key compliance requirements include, but are not limited to:

 

1. Data Protection: Ensuring the secure storage, processing, and transmission of sensitive financial data to prevent unauthorized access, disclosure, or breaches.  

2. Incident Response: Developing, documenting, and regularly testing robust incident response plans to enable swift and effective action to address and mitigate cyber threats, thereby minimizing potential damage. 

3. Vulnerability Management: Establishing processes for regularly assessing systems and applications for vulnerabilities and promptly remediating them to mitigate the risk of exploitation.  

4. Access Control: Implementing strict access control mechanisms to ensure that sensitive financial information and critical systems are accessible only to authorized personnel based on the principle of least privilege.  

5. Security Awareness and Training: Providing comprehensive and ongoing cybersecurity awareness training to all employees to help them recognize, report, and effectively respond to potential cybersecurity threats.  

6. Risk Assessment and Gap Analysis: Conducting thorough and periodic risk assessments to identify potential threats and vulnerabilities, and performing gap analyses to compare current security practices against SAMA CSF requirements.  

7. Continuous Monitoring: Implementing systems and processes for the continuous monitoring of security events and logs to detect and respond to suspicious activities in a timely manner.

 

A significant aspect of SAMA CSF compliance is the substantial evidentiary burden placed upon financial institutions. The requirement to "demonstrate adoption" of controls and the consistent emphasis across various sources on maintaining thorough documentation for audit purposes highlight this. Regulators and auditors require tangible proof that controls are not just documented in policies but are actively and effectively implemented and maintained in practice. This necessitates meticulous record-keeping of all compliance-related activities, including policies, procedures, risk assessment reports, training records, incident response actions, system logs, and evidence of control implementation and testing.

 

D. Auditing and Enforcement

SAMA maintains a rigorous oversight role to ensure adherence to its Cybersecurity Framework (CSF). This includes conducting regular audits of financial institutions to assess their level of compliance with the mandated controls and principles. These audits serve as a key mechanism for SAMA to verify that institutions are not only claiming compliance but are actively implementing and maintaining effective cybersecurity measures. The CSF itself is designed to be a tool for these periodic assessments, providing a clear benchmark against which institutions are evaluated.  

 

The consequences of non-compliance with the SAMA CSF are significant and can have severe repercussions for financial institutions. These penalties are designed to act as a strong deterrent and underscore the critical importance SAMA places on cybersecurity within the financial sector. Non-compliance can lead to a range of enforcement actions, including:

 

1. Heavy Fines: SAMA has the authority to impose substantial monetary penalties on institutions that fail to meet the CSF requirements.  

2. Operational Restrictions or Shutdowns: In cases of serious or persistent non-compliance, SAMA may impose restrictions on an institution's operations or, in extreme cases, order a temporary shutdown.  

3. License Suspension or Revocation: For severe violations, SAMA holds the authority to suspend or even revoke an institution's operating license, effectively halting its ability to conduct business in the Kingdom.

 

IV. The NCA Essential Cybersecurity Controls (ECC)

 

The National Cybersecurity Authority (NCA) Essential Cybersecurity Controls (ECC) represent a cornerstone of Saudi Arabia's national cybersecurity strategy. These controls are designed to establish a foundational level of cybersecurity across vital sectors of the Kingdom, ensuring the protection of critical assets and information.

 

A. Overview, Objectives, and Scope

The NCA ECC were first introduced in 2018 as ECC-1:2018 and have since been updated, with the latest version being ECC-2:2024, released in October 2024. The fundamental objective of the ECC is to establish a minimum cybersecurity baseline for organizations deemed critical to the Kingdom's operations and security. This initiative aims to protect Saudi Arabia's national interests, its Critical National Infrastructure (CNI), government services, and sensitive data from the ever-evolving landscape of cyber threats.  

 

Compliance with the ECC is mandatory for a specific set of organizations. This includes all government organizations and entities, encompassing ministries, authorities, and establishments, whether they are located inside or outside the Kingdom of Saudi Arabia. Additionally, private sector organizations that own, operate, or host Critical National Infrastructure (CNI) are also mandated to comply with the ECC. The ECC-1:2018 framework was originally structured with 5 main cybersecurity domains, 29 subdomains, and 114 cybersecurity controls. The updated ECC-2:2024 has been streamlined, now comprising 4 main domains, 108 cybersecurity controls, and 92 sub-controls.

 

 

 

 

 

 

ECC Domains & Controls

 

 

The primary focus of the ECC on government entities and Critical National Infrastructure (CNI) highlights its crucial role in safeguarding national security and the continuity of essential services. Government bodies and CNI are often high-value targets for sophisticated cyber adversaries, including state-sponsored actors and organized cybercriminal groups. Any disruption or compromise of these entities could have severe and far-reaching consequences for national security, public safety, economic stability, and the overall functioning of the state. The ECC, therefore, provides a mandatory and robust baseline of security measures to ensure these vital sectors are adequately protected against such threats.

 

B. Key Domains and Controls (ECC-2:2024)

The updated NCA Essential Cybersecurity Controls (ECC-2:2024) are structured around four main domains, a refinement from the five domains present in the earlier ECC-1:2018 version. These domains provide a comprehensive framework for addressing cybersecurity across various organizational functions:

 

 

 

 

NCA ECC Key Domains

 

 

 

 

1. Cybersecurity Governance: This domain establishes the foundational elements for an effective cybersecurity program. It encompasses the development and enforcement of cybersecurity policies and procedures, the definition of clear roles and responsibilities for cybersecurity personnel, comprehensive cybersecurity risk management processes, ensuring compliance with relevant standards, laws, and regulations, and fostering cybersecurity awareness and training programs throughout the organization.  

2. Cybersecurity Defense: This domain focuses on the technical and operational measures required to protect an organization's information assets and systems. Key areas include asset management (identifying and classifying assets), Identity and Access Management (IAM), protection of information systems and processing facilities, email and network security management, security for mobile devices, data and information protection (including cryptography), backup and recovery management, vulnerability management, penetration testing, and cybersecurity incident and threat management. Trellix, for example, maps its portfolio to various ECC controls covering many of these defensive measures.  

3. Cybersecurity Resilience: This domain addresses an organization's ability to withstand, adapt to, and recover from cybersecurity incidents. It specifically focuses on the cybersecurity resilience aspects of Business Continuity Management (BCM), ensuring that organizations can maintain critical operations and services, or recover them promptly, in the event of a cyber-attack or other disruptive incidents.  

4. Third-Party & Cloud Computing Cybersecurity: This domain acknowledges the increasing reliance on external entities and cloud services. It mandates controls to manage cybersecurity risks associated with third-party vendors, outsourcing arrangements, and the use of cloud computing and hosting services. This includes ensuring proper due diligence, contractual obligations, and security measures for data processed or stored by third parties or in cloud environments.

 

While ECC-1:2018 included a distinct domain for Industrial Control Systems (ICS) Cybersecurity , the specific placement of ICS/Operational Technology (OT) controls within the ECC-2:2024 structure requires verification from the official documentation, as it might be integrated into other domains or addressed more extensively by specialized NCA standards like the Operational Technology Cybersecurity Controls (OTCC), as well as the Critical Systems Cybersecurity Controls (CSCC).

 

Similar to the SAMA CSF, the domain structure of the NCA ECC demonstrates a comprehensive and holistic approach to cybersecurity. It recognizes that effective protection requires more than just technical solutions. Strong governance sets the strategic direction and accountability. Robust defensive measures provide the necessary technical and operational safeguards. Resilience capabilities ensure that the organization can recover from incidents. Addressing third-party and cloud risks acknowledges the realities of modern, interconnected IT environments where organizational boundaries are increasingly permeable. By structuring the ECC across these critical areas, the NCA ensures that government entities and CNI operators address the full spectrum of cybersecurity challenges.

 

C. Compliance Obligations and Enforcement

Adherence to the National Cybersecurity Authority (NCA) Essential Cybersecurity Controls (ECC) is a mandatory requirement for all designated organizations. This includes government bodies and private sector entities that own, operate, or manage Critical National Infrastructure (CNI). The NCA has established a clear set of obligations to ensure that these entities not only adopt the ECC but also maintain ongoing compliance.  

 

Organizations subject to the ECC are required to:

1. Conduct Self-Assessments: Regularly evaluate their cybersecurity posture against the ECC requirements using compliance tools and methodologies provided or endorsed by the NCA.

2. Submit Periodic Compliance Reports: Provide regular reports to the NCA detailing their compliance status, the implementation of controls, and any identified gaps or remediation plans.

3. Undergo On-Site Audits: Be prepared for and facilitate on-site audits conducted or mandated by the NCA to independently verify compliance with the ECC.

 

Failure to comply with the ECC can lead to a range of serious consequences. These enforcement measures are designed to ensure that the mandated cybersecurity standards are taken seriously and implemented effectively. Non-compliance can result in:

 

1. Regulatory Sanctions: The NCA has the authority to impose various sanctions on non-compliant organizations.  

2. Restrictions from Government Contracts: A significant deterrent, particularly for private sector CNI operators, is the potential restriction from participating in or being awarded government contracts.  

 

 

D. Auditing Methods for ECC Compliance

Ensuring compliance with the National Cybersecurity Authority (NCA) Essential Cybersecurity Controls (ECC) involves a structured auditing process. Organizations subject to the ECC must be prepared for thorough assessments of their cybersecurity practices. The NCA itself may conduct these audits, or they may be carried out by accredited third-party auditors.

 

The preparation for an NCA compliance audit is a comprehensive undertaking. Key steps typically include:

 

1. Understanding the NCA Cybersecurity Framework: Organizations must first gain a deep understanding of the ECC requirements, including its domains, controls, and sub-controls, as detailed in the latest official ECC documentation (e.g., ECC-2:2024).

2. Conducting a Self-Assessment: A critical preparatory step is to perform a thorough self-assessment or gap analysis against the ECC requirements. This helps identify areas of non-compliance or weakness that need to be addressed before an official audit. The NCA provides compliance tools and assessment toolkits to facilitate this process.  

3. Assigning a Compliance Team: A dedicated internal team should be made responsible for managing ECC compliance and preparing for the audit. This team typically includes representatives from IT, security, legal, and relevant business units.  

4. Collecting and Organizing Documentation: Auditors will require extensive documentation as evidence of compliance. This includes, but is not limited to:

• Cybersecurity policies and procedures

• Risk assessment reports

• Incident response plans and records

• Access control logs and reviews

• Employee training records and awareness materials

• System configuration documents

• Vulnerability assessment and penetration testing reports

• Evidence of implemented technical controls.  

5. Staff Training: Ensuring that staff are aware of their cybersecurity responsibilities and relevant ECC requirements is crucial. Training records will likely be reviewed during an audit.  

6. Remediating Gaps: Any deficiencies identified during the self-assessment must be addressed through corrective actions. This may involve updating policies, implementing new technical controls, or enhancing existing processes.  

7. Performing a Mock Audit (Optional but Recommended): Conducting an internal mock audit, or engaging an external consultant to do so, can help simulate the actual audit experience and identify any remaining weaknesses.

 

The actual NCA audit process typically involves several stages :  

1. Kick-Off Meeting: The audit usually begins with an initial meeting between the auditors and the organization's compliance team and key stakeholders. During this meeting, the audit scope, objectives, methodology, and timeline are discussed.

2. Documentation and Policy Review: Auditors will meticulously review the organization's cybersecurity policies, procedures, and other relevant documentation to assess their alignment with ECC requirements.

3. Interviews: Auditors will conduct interviews with key personnel from various departments (e.g., IT, security, management, HR) to understand how cybersecurity policies are implemented in practice and to gauge the level of security awareness and understanding of protocols.

4. Technical System Checks and Testing: This phase involves the technical verification of implemented controls. Auditors may perform activities such as network scanning, examination of access control configurations, firewall rule reviews, endpoint security checks, and validation of data protection mechanisms.

5. Reporting: Following the audit, the auditors will prepare a formal report detailing their findings. This report will highlight areas of compliance, identify any non-conformities or weaknesses, and provide recommendations for improvement.

 

A fundamental characteristic of NCA audits is their reliance on evidence-based verification. Auditors require tangible proof that controls are not only documented but are also effectively implemented, consistently maintained, and regularly reviewed. This places a significant emphasis on meticulous record-keeping and the ability to produce clear, auditable evidence for each applicable ECC control. Organizations that lack thorough and organized documentation will face considerable challenges during an audit, irrespective of their actual, undocumented security measures.

 

 

V. The CST Cybersecurity Regulatory Framework (CRF)

 

The Communications, Space & Technology Commission (CST), formerly known as the Communications and Information Technology Commission (CITC), plays a vital role in regulating key technology sectors in Saudi Arabia. As part of its mandate, the CST issued the Cybersecurity Regulatory Framework (CRF) to address the specific cybersecurity needs of service providers within the Information and Communications Technology (ICT) sector.

 

A. Overview, Objectives, and Scope

The CST Cybersecurity Regulatory Framework (CRF) was officially issued in June 2020. It is specifically designed for Service Providers (SPs) operating within the Information and Communications Technology (ICT) sector in Saudi Arabia. The overarching purpose of the CRF is to regulate and empower the cybersecurity practices of these ICT SPs, with the aim of increasing the overall cybersecurity maturity level of the sector. It also seeks to encourage the adoption of a robust risk management methodology and promote the application of good cybersecurity practices among these providers.  

 

The provisions of the CRF apply to all licensed and registered service providers that fall under the regulatory purview of the CST. A key distinction is that the CRF primarily targets ICT organizations that are not classified as Critical National Infrastructure (CNI). Entities designated as CNI are expected to primarily adhere to the National Cybersecurity Authority's (NCA) Essential Cybersecurity Controls (ECC). This delineation ensures that while the most critical assets are covered by the NCA's stringent requirements, other vital ICT service providers also have a dedicated framework to guide their cybersecurity efforts. The CRF is contextualized within the broader national goals of Vision 2030 and aligns with the provisions of the Telecommunications Act.  

 

The CRF aims to ensure that service providers maintain a robust and resilient level of cybersecurity, thereby safeguarding their own operations, protecting their diverse clientele, and contributing to the overall security and stability of the Kingdom's digital environment. Furthermore, the CRF acts as a complementary framework to the NCA ECC. While the ECC provides comprehensive and mandatory controls for entities designated as CNI, many ICT service providers deliver essential digital services without formally falling under this CNI classification. The CST CRF effectively fills this potential regulatory gap by establishing specific cybersecurity standards and expectations for these non-CNI ICT service providers. For those ICT SPs that are also classified as CNI, the NCA ECC would likely take precedence or apply concurrently with the CRF, ensuring that the highest and most appropriate level of security is applied to the Kingdom's most critical digital assets and services. This interplay necessitates careful consideration and navigation by ICT organizations to understand their full spectrum of compliance obligations.

 

B. Key Requirements and Compliance Levels

The CST Cybersecurity Regulatory Framework (CRF) is structured around a risk-based approach, featuring three distinct compliance levels (CLs) designed to accommodate the varying sizes, complexities, and risk profiles of ICT Service Providers (SPs). These levels are progressive, with increasing sophistication of controls:

 

 

CST CRF Compliance Levels

 

1. Level 1 (CL1): This foundational level includes the basic set of essential security controls that all applicable SPs must implement to establish a minimum cybersecurity posture.  

2. Level 2 (CL2): This intermediate level introduces more advanced cybersecurity requirements, building upon the controls established in CL1. It demands a greater depth of implementation and more mature security practices.  

3. Level 3 (CL3): This highest level focuses on efficiency monitoring, continuous improvement, and the optimization of the controls implemented in CL1 and CL2. It signifies a mature and proactive cybersecurity program.

 

C. Key Domains and Controls (CST-CRF)

The CRF outlines a comprehensive set of cybersecurity requirements across various domains. Key areas of focus, as detailed in the official CRF document and associated audit forms, include :

 

 

 

 

 

CST CRF Key Domains

 

 

 

 

1. Cybersecurity Governance: Establishing an appropriate cybersecurity organization structure, defining roles and responsibilities, ensuring compliance with internal policies and relevant external (national and international) regulatory requirements, managing cybersecurity in project management, and addressing cybersecurity in human resources.

2. Asset Management: Maintaining an accurate and up-to-date inventory of all information assets, classifying these assets based on risk to ensure appropriate protection, and defining controls for Bring Your Own Device (BYOD) scenarios and the secure disposal of assets.

3. Cybersecurity Risk Management: Establishing and implementing a suitable cybersecurity risk assessment approach to identify, analyze, and evaluate risks to information assets, and developing a corresponding risk treatment and monitoring approach.

4. Logical Security: This broad domain covers numerous technical controls, including:

• Cryptography: Ensuring the effective and adequate use of encryption to protect the confidentiality, integrity, authenticity, and non-repudiation of information.

• Change Management: Managing changes to information assets in a controlled manner to mitigate unintended consequences.

• Vulnerability Management: Systematically identifying, assessing, and remediating vulnerabilities in systems and applications.

• Patch Management: Implementing processes for the timely application of security patches.

• Network Security: Protecting networks from malicious activities and ensuring their resilience against cyber threats.

• Logging and Monitoring: Collecting, monitoring, and protecting event logs from information assets and reporting suspicious events.

• Identity and Access Management (IAM): Controlling and managing user identities and their access to information assets.

• Application Whitelisting: Ensuring only authorized applications can execute.

5. Physical Security: Implementing measures to protect physical premises and assets.

6. Customer Cybersecurity Awareness: Defining and implementing requirements for raising cybersecurity awareness among customers of the ICT SPs.

 

C. Auditing and Enforcement

The Communications, Space & Technology Commission (CST) employs a variety of methods to monitor and enforce compliance with its Cybersecurity Regulatory Framework (CRF). These mechanisms are designed to ensure that Information and Communications Technology (ICT) Service Providers (SPs) adhere to the stipulated cybersecurity requirements. CST's oversight activities include, but are not limited to, requiring SPs to conduct self-assessments, conducting field inspections, organizing compliance workshops, and initiating proactive audits or audits triggered by specific incidents or intelligence.  

 

To facilitate the auditing process, an official "CRF Audit Form" has been developed. This document outlines the specific controls and includes detailed questions to assess an SP's compliance with the framework's requirements across its various domains and compliance levels. This standardized audit form provides a clear basis for evaluations, ensuring consistency in how compliance is assessed.  

 

Penalties for non-compliance with the CRF by service providers are explicitly linked to the Telecommunications and Information Technology Act. Specifically, Article Twenty-seventh of this Act stipulates the penalties that can be imposed on SPs found to be in breach of their cybersecurity obligations. Furthermore, the National Cybersecurity Authority (NCA) also retains certain rights concerning the cybersecurity posture of these service providers. The NCA is empowered to follow up on and verify the adequacy of the cybersecurity levels maintained by SPs. If an SP is found to be negligent in its cybersecurity duties, the NCA has the authority to charge the provider for the costs associated with such follow-up processes. Crucially, the NCA can also impose the penalties outlined in the aforementioned Article Twenty-seventh of the Telecommunications and Information Technology Act on service providers who breach these cybersecurity clauses.

 

The provisions within the Telecommunications and Information Technology Act suggest a potential for coordinated, and possibly dual-layered, oversight regarding the cybersecurity of ICT service providers. While the CST is the primary regulator for the ICT sector and utilizes its CRF to set specific standards, the NCA, as the overarching national cybersecurity authority, is also empowered by this Act to ensure that SPs adequately protect cybersecurity and critical infrastructure, in alignment with the NCA's own controls and guidelines. This implies that SPs are not only accountable to the CST concerning the CRF but may also be subject to scrutiny from the NCA, particularly if their services are deemed critical or if they fall under CNI classifications. This reinforces the necessity for SPs to have a comprehensive understanding of requirements emanating from both the CST and the NCA, and to ensure their compliance strategies address all applicable mandates.

 

 

VII. Strategic Considerations for Compliance With Saudi Cybersecurity Regulations

 

Achieving and maintaining compliance with Saudi Arabia's key cybersecurity frameworks—SAMA CSF, NCA ECC, and CST CRF—requires a strategic, well-resourced, and ongoing effort. Organizations face a range of common challenges but can adopt robust strategies to navigate this complex regulatory landscape effectively.

 

To effectively address these challenges and achieve sustainable compliance with the SAMA CSF, NCA ECC, and/or CST CRF, organizations should develop and implement a robust, multi-faceted compliance strategy. Key elements of such a strategy include:

 

1. Securing Leadership Buy-in and Establishing Strong Governance: Cybersecurity compliance must be driven from the top. Gaining active commitment and support from senior leadership and the board of directors is paramount. This involves establishing a clear cybersecurity governance structure with well-defined roles, responsibilities, and accountability.  

2. Conducting Comprehensive Gap Analyses and Risk Assessments: Organizations should begin by conducting thorough gap analyses to compare their current cybersecurity posture against the specific requirements of all applicable frameworks. This should be complemented by regular, comprehensive cybersecurity risk assessments to identify, analyze, and prioritize threats and vulnerabilities specific to their operational environment.  

3. Adopting an Integrated Governance, Risk, and Compliance (GRC) Approach: To manage the complexity of multiple frameworks and ensure consistency, organizations should adopt an integrated GRC approach. Utilizing GRC platforms or methodologies can help streamline compliance activities, map controls across different standards, manage documentation centrally, and automate reporting where possible.  

4. Developing a Prioritized Roadmap: Based on the findings of gap analyses and risk assessments, organizations should develop a clear, prioritized roadmap for addressing identified deficiencies and implementing required controls. This roadmap should include timelines, resource allocations, and responsible parties.  

5. Creating and Maintaining Comprehensive Policies and Documentation: Develop, approve, and disseminate a comprehensive suite of cybersecurity policies, standards, and procedures that align with the requirements of the applicable frameworks. All policies and compliance activities must be meticulously documented to serve as evidence during audits.  

6. Implementing Appropriate Technical Controls: Deploy and configure necessary technical safeguards, such as firewalls, intrusion detection/prevention systems, data encryption mechanisms, multi-factor authentication (MFA), endpoint detection and response (EDR) solutions, and secure data backup systems, as mandated by the frameworks.  

7. Investing in Employee Training and Awareness: Implement regular and engaging cybersecurity awareness training programs for all employees, including contractors and third parties with system access. Training should cover topics such as phishing recognition, strong password practices, safe data handling, and incident reporting procedures.  

8. Establishing Continuous Monitoring and Regular Auditing: Implement capabilities for continuous security monitoring of systems, networks, and data to detect and respond to threats in real time. Conduct regular internal audits and periodic external audits to validate compliance and the effectiveness of controls.  

9. Developing and Testing Incident Response Plans: Create, document, and regularly test robust incident response plans to ensure the organization can effectively identify, contain, eradicate, recover from, and learn from cybersecurity incidents. These plans should include clear communication protocols.  

10. Managing Vendor and Third-Party Risk: Establish a formal program for assessing, managing, and monitoring the cybersecurity risks associated with third-party vendors, suppliers, and cloud service providers. This includes due diligence, contractual security requirements, and ongoing oversight.

 

Aramco Cybersecurity Compliance Certification (CCC)

Saudi Aramco, a global leader in the energy sector, places paramount importance on the cybersecurity of its operations and supply chain. To this end, Aramco established the Cybersecurity Compliance Certification (CCC) Program. The primary goal of this program is to ensure that all third-party organizations providing services to Saudi Aramco adhere to a stringent set of cybersecurity requirements. This initiative is crucial for protecting Aramco's critical assets and sensitive information from the ever-evolving landscape of cyber threats. Compliance with these requirements and obtaining the CCC is mandatory for any organization wishing to conduct business with Saudi Aramco.

 

At the heart of the CCC Program is the Third Party Cybersecurity Standard, document SACS-002. This standard outlines the minimum cybersecurity controls that third parties must implement and maintain. SACS-002 is designed to ensure the confidentiality, integrity, and availability of Aramco's assets and data when handled by or accessed by its extensive network of suppliers and partners.

 

The Aramco CCC Program features two main levels of certification, tailored to the nature of the services provided by the third party :

 

1. Cybersecurity Compliance Certificate (CCC): This certification is generally for organizations providing services that fall under classifications such as General Requirements, Outsourced Infrastructure, Customized Software, and Cloud Computing. The process for CCC typically involves a self-compliance assessment against SACS-002, which is then verified remotely by an Aramco-Authorized Audit Firm.  

 

2. Cybersecurity Compliance Certificate Plus (CCC+): This more stringent certification is required for organizations whose services involve Network Connectivity to Aramco's systems or the processing of Critical Data. The CCC+ mandates an on-site compliance assessment conducted by an Authorized Audit Firm.  

 

If a third party's services fall under classifications requiring both CCC and CCC+, only the CCC+ certification is necessary to fulfill Aramco's requirements

 

 

VIII. Conclusion

 

The SAMA Cybersecurity Framework (CSF), the NCA Essential Cybersecurity Controls (ECC), and the CST Cybersecurity Regulatory Framework (CRF) collectively represent the cornerstone of Saudi Arabia's efforts to establish a secure and resilient digital environment. Each framework, while tailored to the specific needs and risk profiles of its target sector, plays an indispensable role in the Kingdom's broader national cybersecurity strategy.

 

The SAMA CSF is crucial for maintaining the stability, integrity, and trustworthiness of the Kingdom's financial sector, mandating robust cybersecurity practices for all regulated financial institutions. The NCA ECC serves as a foundational set of requirements for government entities and Critical National Infrastructure operators, directly contributing to the protection of national security, essential services, and sensitive governmental data. The CST CRF focuses on enhancing the cybersecurity maturity of the Information and Communications Technology (ICT) sector, which provides the essential digital backbone for many other industries and public services.

 

Organizations are encouraged to adopt a proactive, adaptive, and continuously improving cybersecurity posture that extends beyond achieving minimum compliance. The evolving nature of cyber threats and the dynamic technological landscape mean that a static approach to security is insufficient. True resilience is built through ongoing vigilance, regular assessment of risks and controls, investment in appropriate technologies and skilled personnel, and the cultivation of a strong security-aware culture

 

 

 

VIII. How Cyberatos Can Help?

 

Cyberatos® is a premier cybersecurity consultancy and strategic advisory firm, specializing in helping executives, government leaders, and decision makers develop and implement advanced security strategies. Our mission is to transform cybersecurity into a business enabler, ensuring resilience, compliance, and strategic advantage.

Founded by the former head of the National Cybersecurity Center (NCSC), Cyberatos® brings extensive experience in developing national and enterprise cybersecurity frameworks and policies. Cyberatos® believes that effective Governance, Risk, and Compliance (GRC) is not merely about fulfilling regulatory obligations to avoid penalties. Instead, it is about embedding security and resilience into the fabric of an organization, thereby protecting valuable assets, building stakeholder trust, and enabling the achievement of core business objectives. This philosophy underpins Cyberatos' approach, which emphasizes the seamless integration of people, processes, and technology.

 

Cyberatos® Startegic Approach

 

 

Cyberatos® stands ready as your strategic partner in navigating this intricate regulatory and enterprise compliance environment. Our unique value proposition lies in our deep-rooted expertise in the specific requirements of the SAMA CSF (including CRFR and MVC), the CST CRF, the NCA ECC. We offer comprehensive, end-to-end GRC services, from initial gap analysis and policy development to technical control implementation, maturity upliftment, and audit readiness. Our approach is not to provide generic solutions but to deliver tailored strategies that align with your organization's specific context, risk profile, and business objectives.

 

Cybersecurity that Fits Your Needs

At Cyberatos®, we firmly believe that effective cybersecurity is not a one-size-fits-all solution. Every organization, regardless of its size, industry, or current security maturity, faces unique digital risks and operates within distinct regulatory landscapes. That's why our approach is centered on understanding your specific business objectives and challenges first. We then leverage our deep expertise to design, implement, and manage cybersecurity strategies and services that are precisely tailored to your individual requirements, ensuring optimal protection and compliance without unnecessary complexity.

Our Approach

1. We meticulously study your organization's "as-is", conducting in-depth assessments to identify specific cybersecurity gaps against prevailing standards of your industry and Security and Privacy Regulations.
2. We develop a tailored Strategy/roadmap designed to guarantee not just compliance, but also to truly elevate your overall security posture and ensure robust data protection.
3. We guide and assist in the practical implementation of recommended security controls and remediation actions.
4. We develop and conduct tailored cybersecurity awareness programs to empower your personnel and strengthen your human firewall.

5. We establish mechanisms for ongoing monitoring of your security controls and compliance status, ensuring adaptability to new regulations and evolving threats.

 

 

Also visit our webpages for more information on our services against each one of the regulations:

• The NCA ECC 

• SAMA CSF

• CST CRF

 

 

Contact us Today