CIS Controls v8.1 Guide To Implementation Groups 2024 - 11
CIS Controls v8.1 Guide To Implementation Groups 2024 - 11
Implementation
Groups (IG)
CIS Critical Security Controls v8.1
November 2024
Acknowledgments
The Center for Internet Security® (CIS®) would like to thank the many security experts who volunteer
their time and talent to support the CIS Critical Security Controls (CIS Controls) and other CIS
work. CIS products represent the effort of a veritable army of volunteers from across the industry,
generously giving their time and talent in the name of a more secure online experience for everyone.
As a nonprofit organization driven by its volunteers, we are always in the process of looking for new
topics and assistance in creating cybersecurity guidance. If you are interested in volunteering and/
or have questions, comments, or have identified ways to improve this guide, please write us at:
[email protected].
All references to tools or other products in this guide are provided for informational purposes only,
and do not represent the endorsement by CIS of any particular company, product, or technology.
Editor
Valecia Stocchetti, CIS
Contributors
Josh Franklin, CIS
Robin Regnier, CIS
This work is licensed under a Creative Commons Attribution-Non Commercial-No Derivatives 4.0 International Public
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To further clarify the Creative Commons license related to the CIS Controls® content, you are authorized to copy and
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Contents
Introduction 1
Conclusion 14
In a world faced with varying degrees of cyber attacks, implementing a cybersecurity framework
can be a logical, but daunting, task. An enterprise needs a way to prioritize the implementation of
security controls. For those using or wanting to use the CIS Critical Security Controls (CIS Controls)
in their cybersecurity journeys, CIS has developed Implementation Groups (IGs) to help prioritize the
implementation of the CIS Controls—divided into IG1, IG2, and IG3. IGs are based on several factors—
Size and/or Complexity, Data Types, Resources and Technology, Threat Types, and Risk. Each IG
identifies a set of Safeguards1 that the enterprise should implement.
So where does an enterprise start? Every enterprise should begin Figure 1 | Implementation Groups
with IG1, as it represents a minimum standard of information
security that is the on-ramp to implementation of the CIS
56 IG1
Controls. Referred to as essential cyber hygiene, IG1 provides
ESSENTIAL CYBER HYGIENE
effective security value with technology and processes that are
generally already available, while providing a basis for more
tailored and sophisticated action, if warranted. Once IG1 has been Cyber Defense
Safeguards
implemented, enterprises can move to Safeguards in IG2 and
IG3, based on the factors mentioned above. Keep in mind that
Safeguard implementation is not a one-time activity. Instead, it
74 IG2
is an iterative approach to protecting an enterprise from cyber ESSENTIAL CYBER HYGIENE
23 IG3
when it comes to defending against cyber attacks. This brings ESSENTIAL CYBER HYGIENE
Total Safeguards
153
1 The CIS Controls are made up of 18 top-level Controls and 153 Safeguards, or actions that are taken to implement a specific Control.
For adopters of the CIS Controls, one of the most important steps in building a cybersecurity program
is selecting the most appropriate IG for the enterprise. Since each enterprise is unique, there is not a
single approach that works for everyone. However, CIS recommends the following factors as a basis
for determining your IG: Size and/or Complexity, Data Types, Resources and Technology, Threat Types,
and Risk. Most cybersecurity decisions come down to one or more of these five factors.
The size/and or complexity of an enterprise can vary based on many criteria. For example, the Small
Business Administration (SBA) defines a small business as having fewer than 500 employees.2
However, even then there are exceptions to that rule, based on average annual receipts and/or
number of employees for a specific industry. There may also be state-specific factors in determining
what constitutes a small business, such as in California.3
Sometimes it can be difficult to select an IG simply based on size though. Complexity can also be
a variable in selecting an IG. Complexity can run concurrently with the size of an enterprise. For
example, a small enterprise is simpler in terms of complexity, while larger enterprises are much more
operationally complex. However, just because you are a smaller enterprise does not automatically
mean that you are less complex and fall under a lower IG (e.g., IG1). For example, a doctor’s office or
a small hospital may only employ 50-100 people, but they are responsible for the health information
of more than 1,000 patients, which would place them at a higher IG: IG2 and/or IG3. Regulations
and other variables can impact the IG that an enterprise selects to implement, which will be
2 https://advocacy.sba.gov/wp-content/uploads/2023/03/Frequently-Asked-Questions-About-Small-Business-March-2023-508c.pdf
3 https://www.dgs.ca.gov/PD/Services/Page-Content/Procurement-Division-Services-List-Folder/Certify-or-Re-apply-as-Small-Business-Disabled-
Veteran-Business-Enterprise
In terms of the CIS Controls, IG1 is intended for small and medium-sized enterprises (SMEs). If
an enterprise fits into a unique situation, as outlined above, then it may warrant IG2 and/or IG3
Safeguards to be implemented to demonstrate compliance. Regardless of which IG an enterprise
selects, IG1 is the starting point for all enterprises. It is why we have classified it as a minimum
standard of information security and why we refer to it as essential cyber hygiene. A well-built
cybersecurity program must rest on a solid foundation, which IG1 addresses.
Determining when an enterprise moves to IG2 will depend on the size and complexity of the
enterprise. IG2 is for enterprises managing Information Technology (IT) infrastructure that spans
multiple departments with differing risk profiles and increased operational complexity. An IG3
enterprise often includes large enterprises that are operationally complex and have an increased risk
profile that is widespread across the enterprise, not just in a few areas of the enterprise. Shown below
in Figure 3 is a summary of the Size and/or Complexity factors that may impact IG selection.
Data Types
The types of data an enterprise handles and stores will also impact which IG it selects. The first
step in determining which types of data an enterprise handles and stores is to take an inventory
of the data and then classify it. The classification scheme will differ between enterprises. For
example, an enterprise may have a classification scheme that groups data by public, internal,
confidential (including sensitive and proprietary data), and restricted. However, there are many
other categories that can be used to classify data, including private, critical, and regulatory data.
Whichever classification scheme an enterprise chooses, ensure that it is defined and consistently
Some data types have special considerations due to specific laws and/or regulations that are put
in place to protect and secure that data. The applicable laws and regulations that an enterprise is
subject to may be determined by variables such as the sector they are classified as, the types of
entities they work with (e.g., federal), or the types of data that are handled (e.g., health, credit card).
For example, health insurance companies and health care providers are just some of the entities
that are regulated under the Health Insurance Portability and Accountability Act (HIPAA). Another
example is when an enterprise collecting data on European Union (EU) citizens and residents is
subject to regulation under the General Data Protection Regulation (GDPR).
Most IG1 enterprises handle data with low sensitivity and no regulatory or compliance oversight
(e.g., an enterprise that handles unregulated employee and company financial information). To
understand what data is regulated, go back to the first step of inventorying data. When an enterprise
moves to IG2, this is where they often begin to move into compliance and regulations. It may not be
widespread, but some departments/systems/data can be regulated, require additional Safeguards to
be implemented, and be subject to external audits. If not regulated, it could mean that the enterprise
handles more sensitive data, which requires additional protections found in IG2. An IG3 enterprise
deals with the highest regulatory burdens and is subject to external audits to ensure compliance
on a recurring basis (e.g., annually). They also store and process sensitive and confidential data
and, therefore, must uphold the confidentiality, integrity, and availability (CIA) of that data, as is the
case with any data. Shown in Figure 4 below is a summary of how Data Types impact the selection
of an IG. It is worth noting that the types of data an enterprise handles are one of the more heavily
weighted factors when it comes to selecting an IG.
Data Types
Aside from the size, complexity, and data types that can factor into IG selection, resources and
technology will also play a role. The three main resources that often impact implementation in an
enterprise are time, budget, and skill set. Some enterprises can face challenges in one or more
of these areas. For example, an enterprise may have the time to implement a technology, but not
the budget or skill set. Likewise, they have the skill set and budget, but no time due to competing
priorities. In these cases, enterprises should determine which areas (time, budget, skill set) need
more focus to succeed at implementation. Technology may also play a role in implementation. For
example, some enterprises use existing or no-cost technology, commercial off-the-shelf (COTS)
products, or they also use proprietary/custom-built software. Again, this comes back to the question
of resources, which will determine the type(s) of software used.
It is important to note that if an enterprise is classified under a higher IG (e.g., IG3), but does not have
the resources to implement those Safeguards, it does not reduce the threshold for which IG they
would select. This means that if an enterprise is heavily regulated, but does not have the budget to
implement IG3 Safeguards, then a deeper look into why that is happening is required. For example, it
might require more work to get leadership buy-in and secure additional funding or may necessitate
looking outward at a third party to take on some of the burden that the enterprise cannot handle in-
house. It also means that an IG3 enterprise needs to start at IG1 regardless. If there are challenges or
barriers to implementation, start small and work up from there as resources allow.
From there, an IG3 enterprise employs in-house expertise that specializes in various areas of
technology and cybersecurity. They have a fully formed Information Technology (IT) department, an
in-house information security team, an engineering team, and more. They also have other teams that
support these areas, such as legal and procurement, which play a role in many enterprise processes
(e.g., software procurement). In addition to the use of COTS products, they use software designed
Threat Types
There are different types of threats that an enterprise can be exposed to, such as cyber attacks (e.g.,
ransomware), physical threats (e.g., flood), or hybrid threats (e.g., power grid attack). For the CIS
Controls, the Safeguards are primarily focused on cyber threats. Cyber attacks can be opportunistic
attacks, where the attacker takes advantage of an opportunity but is not necessarily targeting an
enterprise. They may also be targeted and planned well in advance of the actual attack, aiming to
elicit a specific result.
Additionally, cyber threats can have different motivations, such as geopolitical, financial, ideological,
or dissatisfaction. The type of threat actor can change based on motivation, including nation-state
threat actors, cybercriminals, terrorist groups, or insiders. There is another type of threat that is less
innocuous in nature, and that is human error. While the intent is not necessarily malicious, human
error still poses a threat to enterprises and can result in significant harm depending on the error. An
example is a user who fails to securely configure a database, which leads to leaked data and results
in a data breach.
When selecting an IG, the types of threats that an enterprise faces can vary. For enterprises that
handle large amounts of intellectual property (IP), a nation-state threat actor may be one of their
biggest threats. For financial institutions, a cybercriminal may be the most common threat actor they
Threat Types
Risk
Risk management is at the center of most enterprises’ business operations. There are different
facets of risk management, but two key components that often factor into the selection of IGs are
risk tolerance and risk appetite. Explained in basic terms, risk appetite is compared to a speed limit
sign on a highway, whereas risk tolerance is how much the driver is willing to go over the speed limit.
In the realm of cyber threats, an enterprise may have a risk appetite for service disruptions to their
website, but one of the risk tolerance criteria indicates that the enterprise’s website can be down no
longer than three hours.
Risk
There are times where your enterprise requires a unique approach to cybersecurity. Just as you
tailor your clothing, you may also tailor which Safeguards to implement. In more technical terms,
while the CIS Controls address general best practices that enterprises should implement to protect
their environment, some operational environments may present unique requirements. For example,
if implementing a technology costs $1 million, but the enterprise’s revenue is $500,000 a year, then
it might not be reasonable to implement that technology as it could bankrupt the enterprise. In
this case, they can choose to implement a different technology or compensating control that will
still safeguard the enterprise, but not put them out of business. On the other hand, perhaps it is
reasonable to implement the Safeguard with a small loan and then move forward based on the
positive impact that it can have on the enterprise (e.g., mitigating a large threat). Each situation will
be unique to the enterprise.
It was previously mentioned under Data Types that laws and regulations can impact the selection of
IGs. It is also one of the largest areas that may require tailoring. This could be due to industry-specific
regulations. For example, the Federal Information Security Management Act (FISMA) applies to
several organizations including federal agencies, contractors working with the federal government,
service providers who handle federal data (e.g., CSPs, MSPs), state agencies, and more. NIST® SP
800-534 and NIST SP 800-171 play a crucial role in FISMA compliance. For IG1 and IG2 enterprises,
there are likely certain systems or data that require additional protections (i.e., Safeguards from a
higher IG). The CIS Controls help bridge that gap between frameworks by providing mappings to
over 25 different frameworks.5
Auditing is another element that is often related to compliance and regulations. There are two main
types of audits: internal and external. Audits in general are a great way to help facilitate growth
and maturity in an enterprise in defending against cybersecurity threats while also demonstrating
compliance. This could involve an internal audit, as a way to assess control implementation. It can
also involve an external audit, which will consist of an independent assessor evaluating control
implementation for compliance or security purposes. A common way for enterprises to prepare for an
Cyber Insurance
Cyber insurance often requires a specific set of protections to be put in place in order to obtain
coverage. Additionally, coverage may vary depending on the levels of protection an enterprise has in
place. This may be determined by the insurer through questionnaires, assessments, or a combination
of the two. Keep in mind that not all types of threats are covered by cyber insurance, so it should
not act as failproof protection, but instead as a supplemental way to transfer some of the risk an
enterprise holds.
For enterprises wanting to understand more about how to select an IG to implement, following the
guidance from these five factors is key. The IGs provide a solid foundation for an enterprise to build a
cybersecurity program.
CHARACTERISTICS
• Small and medium-sized • Data is low sensitivity • Limited cybersecurity • Exposed to general, • Limited tolerance for
enterprises • Stores unregulated expertise, may outsource non-targeted attacks (e.g., downtime
IG1 • Starting point for all
enterprises
employee and company
financial information
IT/cybersecurity needs
• Uses existing and/or cost-
Ransomware, Malware,
Web Application Hacking,
• Focus is to keep business
operational
ESSENTIAL
CYBER • No regulatory or effective technology and Insider and Privilege
HYGIENE compliance oversight processes Misuse)
• Uses Commercial off-the-
Shelf (COTS) products
• Enterprises managing IT • Stores and processes • Implements enterprise- • Exposed to more • Faces an increased risk
infrastructure spanning sensitive client or grade technology advanced cyber threats, exposure (probability x
multiple departments enterprise information • Has specialized expertise resulting in a loss of potential losses)
with differing risk profiles • Pockets of regulatory or to install and properly public trust • Can withstand short
IG2 • Increased operational compliance oversight configure software • Exposed to industry- interruptions of service
complexity • Use COTS products, and specific threats • Concern is loss of public
may be using proprietary/ trust if a breach occurs
in-house software
• Large enterprises that are • Stores and processes • Employs security experts • Exposed to sophisticated • Faces the highest risk
operationally complex sensitive and confidential that specialize in various and targeted attacks, exposure
• Increased risk profile data areas of cybersecurity including zero-day • Cannot withstand
across the enterprise • Subject to regulatory and • Likely using software attacks and/or nation- interruptions of service
compliance oversight designed in-house state threat actors
IG3 or proprietary to the • Successful attacks can
enterprise, in addition to cause significant harm to
COTS products the public welfare
• Ability to purchase
dedicated cybersecurity
software for specific tasks
There is one last question to consider: What impact and benefits does an enterprise receive by
selecting a particular IG?
IG1
An enterprise selecting IG1 receives the most security value for the least number of “actions”
(Safeguards) to implement. IG1 consists of 56 Safeguards that span across 15 (of the 18) Controls.
This is backed by the CIS Community Defense Model (CDM) v2.0, where we assert that, independent
of any specific attack type, implementing IG1 defends against 74% of the (sub-)techniques found
in the MITRE ATT&CK® Enterprise framework.6 Additionally, enterprises selecting IG1 can expect to
implement many procedural Safeguards, along with some technical Safeguards, that have minimal
impact on usability.
IG2
Enterprises selecting IG2 can expect to implement an additional 74 Safeguards, the largest group
of the three IGs. They are comprised of procedural and technical defenses but lean heavily on the
technical side. For example, allowlisting software, encryption, and penetration testing are some of
the activities an enterprise will implement. IG2 also may have some impact on usability. In terms of
defenses, IG2 provides additional protection as compared with IG1.
IG3
IG3 enterprises have 23 additional Safeguards to implement that are heavily technical. These are
activities such as implementing an intrusion prevention solution, role-based access control, and
a data loss prevention solution. Implementing IG3 Safeguards also provides the highest defense,
defending against 86% of ATT&CK (sub-)techniques in the MITRE ATT&CK® framework. In terms of
impact, these are activities that will have an impact on usability.
Implementation Groups are the solution to implementing a cybersecurity framework while limiting
the “drinking from a firehose” experience. An enterprise needing to implement one or more
frameworks can use the CIS Controls as that bridge to reduce the need for multiple assessments
and help improve inefficiencies in control implementation. Enterprises wanting to determine which
IG to begin with should first focus on the five factors (Size and/or Complexity, Data Types, Resources
and Technology, Threat Types, and Risk) that impact IG selection. Once an IG is selected, an
enterprise can begin to look at specific needs that would require tailoring and start developing their
cybersecurity program (i.e., laws, regulations, compliance, and cyber insurance). Keeping in mind
that cybersecurity is a journey and not a destination, IG implementation is an iterative process that
should be continually reassessed and improved as technology and threats advance in the globally
connected world we live in.
The CIS Critical Security Controls (CIS Controls) are a prioritized set of actions that collectively form
a defense-in-depth set of best practices that mitigate the most common attacks against systems
and networks. They are developed by a community of Information Technology (IT) experts who
apply their first-hand experience as cyber defenders to create these globally adopted security best
practices. The experts who develop the CIS Controls come from a wide range of sectors, including
retail, manufacturing, healthcare, education, government, defense, and others.
The Implementation Group methodology was developed as a new way to prioritize the CIS Controls.
These IGs provide a simple and accessible way to help enterprises of different classes focus their
scarce security resources, while still leveraging the value of the CIS Controls program, community,
and complementary tools and working aids.
If you would like to know more about the CIS Controls and Implementation Groups, there are many
resources available on our website at https://www.cisecurity.org/controls/.
CIS Critical Security Controls® (CIS Controls®) v8.1 | Learn more about the CIS Controls, including
how to get started, why each Control is critical, procedures and tools to use during implementation,
and a complete listing of Safeguards for each Control.
CIS Community Defense Model (CDM) v2.0 | A guide published by CIS that leverages the open
availability of comprehensive summaries of attacks and security incidents, and the industry-endorsed
ecosystem that is developing around the MITRE ATT&CK Framework.
CIS Controls Navigator | Learn more about the Controls and Safeguards and see how they map to
other security standards (e.g., CMMC, NIST SP 800-53 Rev. 5, PCI DSS, MITRE ATT&CK). Available
for CIS Controls versions 8.1, 8, and 7.1.
CIS Controls Self Assessment Tool (CIS CSAT) | Enables enterprises to assess and track their
implementation of the CIS Controls for versions 8.1, 8, and 7.1.
CIS Cost of Cyber Defense | IG1: CIS has published The CIS Cost of Cyber Defense: Implementation
Group 1 (IG1), to help you answer these questions: Which protections to start with? Which tools will
be needed to implement those protections? and How much will an implementation will cost?
CIS Risk Assessment Method (CIS RAM) v2.1 | An information security risk assessment method
that helps enterprises implement and assess their security posture against the CIS Controls.
Establishing Essential Cyber Hygiene | IG1 is essential cyber hygiene and represents a minimum
standard of information security for all enterprises. This guide will help enterprises establish essential
cyber hygiene.
Guide to Asset Classes | In v8.1, CIS restructured Asset Classes and their respective definitions
to ensure consistency throughout the Controls. Learn more about our naming conventions and
what they mean.
www.cisecurity.org CenterforIntSec
[email protected] @CISecurity
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