With compliance frameworks multiplying, regulatory pressure has never been higher. Comply or Cry goes framework by framework through what actually matters: what you're required to do, why the framework exists, and what it means in practice for MSPs managing clients at scale.
In this first episode, Microsoft 365 Solutions Architects Dakota McElligott and Tim Oelkers map the landscape: why frameworks exist, what they want, and the critical difference between what you're required to do versus what's merely recommended.
DORA is law, not guidance. In this episode, Tim Oelkers tells you exactly what's required - incident reporting timelines, ICT risk management, third-party oversight - and which M365 controls satisfy it. Plus: where M365 stops and your wider programme must take over.
Hello everyone. Hopefully you can all hear me. Can I get some thumbs up if you guys can hear me? Oh yeah, cool. Great. Excellent. And you can see the screen. Some more thumbs up for that would be awesome. Even better. Cool. I would say, can you see me? But it's daunting as it is, so we'll leave that one. Sweet. We'll give everyone just another minute or so just to join and then we'll make a start. Sweet, numbers slowly rising. Less is better. Sweet. Well, I mean it is recorded, so we can always come back to this at a later date or they can always re-watch the recording. But I think we should get started, guys. So, just to kind of start things off nice and easily for you, I don't expect this to take a solid hour, but if you’ve got any questions, please put them in the chat and at the end I’ll do my best to respond to them or I’ll reach out to you privately where required, depending on time. This is episode two of the compliance cry series. It’s focused seriously and strongly around the Digital Operations Resilience Act. For those that don’t know, this has already been out for quite a while, at least a year, I think January from memory last year, although I could be slightly wrong. This is again part of that compliance cry series that we’ve got running and it’s really designed for those, and I’m assuming anyone on this call today, who has customers focused on the financial sector in the EU. So thumbs up please to confirm you’re all having to deal with EU regulations. Yeah, got quite a few of you there. Sweet. Very relevant to what we’re dealing with today. This episode is designed to cover the Microsoft element, what we as MSPs have to deal with, whether we’re actually impacted, talk more about the journey that DORA is on, where it started, what we need to deal with, and the areas we need to focus on. I’ve been dealing with DORA for about 18 months now and I’ve got a couple of opportunities and links I can give you, including an Excel readiness check sheet and an HTML report that gives you an overview of what’s relevant to you. To get started, it’s fair to start with what is DORA. This is EU law and regulation designed to reshape the industry by taking fragmented country-specific rules and creating a single consistent framework. DORA stands for Digital Operational Resilience Act and it’s an EU regulation reshaping the financial services sector for managed ICT risk. We’ve seen too many cyber incidents and IT outages hit banks and insurers over the past several years, and the EU has created a unified rulebook where MSPs and ICT services are being redefined. Two key areas under DORA are Regulatory Technical Standards and Implementing Technical Standards. These are where our primary focus lies in the ICT space. RTS covers controls, governance and evidence, while ITS focuses on incident response. Think left of boom versus right of boom. RTS ensures controls and governance are in place and evidence can be produced. ITS focuses on how incidents are handled once something goes wrong. For MSPs, this matters because we are at the forefront of the IT foundations for our customers, especially financially regulated firms. We’re pivotal in testing, third-party configurations, policy implementation beyond Microsoft, including firewalls, networks, switches, VLANs, and more. Every part of the IT estate must meet the same RTS and ITS standards, be measured, and be demonstrable. Auditors will expect a checklist and documented evidence. I will share a modern work checklist with you after the session. We’re managing multiple customers, and audits will happen, so we must be ready. DORA is EU regulation 2022/2554, effective from 17 January 2025. It ensures banks, insurers, investment firms, and IT service providers can withstand, respond to, and recover from IT disruptions. It applies to 21 types of financial entities and extends to third-party MSPs and the entire IT supply chain, including print management and SaaS vendors like Bloomberg. The entire supply chain supporting EU-regulated financial firms must comply. MSPs are especially at risk because we hold administrative access to critical systems. With DORA in place, MSPs are now prime targets, so we must meet the same security standards as financial firms. DORA harmonises IT risk rules across EU member states, eliminating fragmented country-based regulations. For MSPs, this simplifies compliance but raises the baseline significantly. There are five key DORA pillars: risk management, incident reporting, digital resilience testing, third-party risk management, and information sharing. Risk management focuses on identifying and mitigating IT risks through governance and continuous monitoring. Incident reporting requires detection, classification, and reporting of IT incidents within strict timelines using standardised templates. Digital resilience testing includes penetration testing, disaster recovery, business continuity, and threat-led penetration testing. Third-party risk management is critical for MSPs, requiring registration of IT providers, contractual compliance, evidence, and exit strategies. MSPs must prove internal controls such as DLP, employee processes, and vendor compliance. Information sharing involves sharing cyber threat intelligence within trusted communities to strengthen collective defence. These pillars also create service opportunities beyond financial services. I don’t have chat access right now but I’ll review it at the end. Looking at Microsoft 365, it underpins nearly all financial services organisations and is therefore directly in scope. Under DORA, systems supporting critical business functions must be governed, monitored, and resilient. MSPs need a multi-tenant management solution with a single pane of glass. Identity, email, device compliance, threat detection, data protection, and collaboration are all mapped to DORA controls. Identity is the new perimeter, and misconfigurations create attack surfaces. Security controls map to prevention, detection, and response. Prevention includes conditional access, MFA, DLP, Intune compliance, and sensitivity labeling. Detection and response include Defender for Endpoint, audit logging, and incident reconstruction. MSPs are directly in scope because financial clients must verify DORA compliance and MSPs must verify their own supply chains. Scope is determined by customer EU presence, not MSP location. Non-compliance risks include loss of financial clients and reputational damage. MSP obligations include cooperation with regulators, business continuity planning, contractual compliance, exit strategies, and supplier verification. Penalties include fines up to €5 million for MSPs, mandatory remedial actions, public disclosure, and contract loss. DORA extends beyond Microsoft 365 to networks, SaaS, supply chains, on-prem systems, and backup and recovery with strict RTO mandates. MSPs must do significant work per customer, but automation opportunities exist. Where inforcer fits is supporting DORA compliance through security baselines, drift detection, compliance reporting, multi-tenant management, and remediation. Inforcer maps to DORA pillars through baseline enforcement, drift detection, audit-ready reporting, and evidence generation. Information sharing is also encouraged, similar to how inforcer supports community collaboration. To wrap up, we’ll provide an HTML report on DORA and Microsoft 365, an MSP readiness dashboard, control checklists, and a 90-day readiness plan. There is a lot to do, and we’ll support you through it. Thank you for your time and I’ll now open up for questions.
Not legally required, but one of the most practical frameworks available. This session maps CIS Controls v8 directly to M365 configuration - identity, endpoints, logging, data protection - and explains why 'configured' and 'enforced' are not the same thing across multi-tenant environments.
Cyber Essentials is a condition of many UK public sector contracts - and assessors will find gaps if you're not ready. This episode covers what the certification actually requires inside M365, what sits outside it, and how to stay audit-ready between renewals without the last-minute scramble.
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NIS2 expanded scope, tightened timelines, and put board-level accountability on the table. If your clients are in energy, health, transport, or digital infrastructure across the EU, this session covers what they must demonstrate - and where M365 controls either deliver or fall short.
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NIST is the common language of enterprise security - and 800-171 is mandatory for anyone in the US defence supply chain. This episode maps the Identify–Protect–Detect–Respond–Recover functions directly to M365, and shows what auditors, insurers, and procurement teams will want to see.
Hello everyone. Welcome back to the complier cry series. This is the series where we make compliance frameworks practical for the Microsoft 365 tenants that you actually manage. Today we are covering NIST. So NIST is the framework that gets name dropped in every cyber insurance questionnaire I would say every enterprise procurement document and every federal contract especially in North America. And yet most conversations I have a lot of MSPs and IT teams don't really have an idea of how to actually operationalize it inside of a Microsoft 365 tenant. So that is what we will be fixing today. By the end of the session you're going to understand the difference between N CSF and NIS 80071 when you need each one and also how they map onto the Microsoft 365 stack and more critically how to enforce them at scale using the inforcer platform. So, let's go ahead and get into it. For those who did not join the CIS session, quick intro. My name is Dakota Miguel. I am a Microsoft 365 solutions architect at inforcer. My day job is helping MSPs design and govern secure Microsoft 365 environments across hundreds and sometimes even thousands of tenants. I do spend a lot of time at the intersection of compliance frameworks and the Microsoft 365 platform itself. That means I am constantly translating standards like NIS, CIS, CMMC and even ISO into actual tenant settings, conditional access policies, defender configurations, the stuff that actually moves that needle. So my promise for this session, we're not going to really focus on a lot of theoretical stuff. It's mostly concepts that are grounding something that you can configure in Microsoft 365. Here is our road map for today. So, we're going to go ahead and start with the basics, cover what NIST actually is because people throw that acronym around without realizing NIST publishes hundreds of standards, right? So, we're going to narrow that down to the two that matter the most for you, I would say. Obviously, we'll touch on I think 853 a little bit in this conversation, but 8171 and CSF is top of mind. And then we're going to just spend some real time on each, what CSF 2.0 looks like in its new form and what 800171 actually requires if you ever touch federal data. After that, we're going to answer the why bother question. Why NIST is the right foundation even if you're not in defense or government work. Then we're going to go ahead and map both frameworks onto Microsoft 365. Which services line up with which controls? And then finally, we're just going to show how inforcer operationalizes all of this so you're not maintaining spreadsheets and screenshots to prove compliance. We will also go ahead and stick around for the inforcer section at the end. That's where this kind of gets a little bit more concrete for anyone running multiple tenants. So let's go ahead and get started with NIST CSF, the cybersecurity framework. NIST CSF was originally developed for critical infrastructure back in 2014. Version 2.0 shipped earlier in 2024 and it broadened the audience to all organizations not just power plants and pipelines. So two things here to internalize about CSF. I would say number one it's voluntary, right? So it's voluntary and it's outcome based. Voluntary means no regulator is going to fine you for not adopting it. Outcome based means it's telling you what good security looks like, but it's not actually telling you how to achieve that. So that distinction is definitely going to matter later in this presentation as well. NIST CSF 2.0 also introduced a new function, govern. So we used to have five functions, now we have six. And govern kind of sits at the center and covers strategy, oversight, supply chain risk, and also policy. Identify, protect, detect, respond, and recover are the original five. And those map roughly to the life cycle of a security incident. So underneath the six functions you have 22 categories things like asset management, identity management, awareness and training. And then under those we have more than 100 subcategories that get into the specifics. So subcategories are where you start to see actual implementation guidance and they're what we're going to actually map to M365 services later in our conversation. So this is the other NIST standard that you need to know. It is the special publication 800171. It is a fundamentally different framework than CSF. CSF is voluntary and it's outcome based. 800171 is mandatory and prescriptive. So if you handle what the government calls controlled unclassified information or CUI in a non-federal system, you must meet these requirements. So CUI is the gray area data. It's not classified, it's not top secret or confidential, but it's also not public. So think technical drawings, research data, contract details, infrastructure schematics. If your customer is a DoD contractor or any federal supplier and that data lives in their Microsoft 365 tenant, then 800171 will apply. There are 110 security requirements organized into 14 control families. So some of them you already are probably doing. We have access control, audit, logging, incident response. Others are more involved. So think configuration management, physical protection, personnel security, etc. And one more thing to remember here too about 8171. It is the foundation as well to CMMC level 2. So if your customer needs CMMC certification, and a lot of them will, you're going to encounter 800171 whether you want to or not. I will say too, 800171’s Rev 3 update definitely tightened a lot of the language and now better aligns with the broader NIST 853 category and catalog, which is really nice. So even if you don't really want to start working on Rev 3, I would recommend it because one, it's going to be the new standard and new expectation and also it maps out really prescriptively and more easily to NIST 853. So CSF has this concept called the implementation tiers and people often confuse them with a maturity model. It's not really like the CIS controls implementation groups. Tiers describe how rigorously and holistically you apply CSF across your entire organization. So there are four of them. Tier one is partial. So cybersecurity activities happen but they're ad hoc and reactive. Somebody puts out a fire when the fire happens. Risk is not really understood at an organizational level. Tier 2 is risk informed. So leadership is aware of cyber risk, there are some policies but practices vary across teams. There's no consistent process and a lot of small businesses kind of live in the tier 2 sector. Tier 3 is repeatable. So practices are formally defined, documented and funded. The whole organization follows the same playbook and this is where most mid-market organizations should aim to land. Tier 4 is adaptive. So practices evolve based on lessons learned, threat intelligence, and information shared with peers. So you're not just following the playbook, you're improving it continuously. Where most MSP customers kind of live today is somewhere between tier 1 and 2. Where we want to take them is tier 3, and I would say tier 4 is aspirational. It's there as a big goal, but it's frankly overkill if you're not a massive enterprise. When you crack open 800171, you're going to see that every one of the 110 requirements is split into two categories. We have basic and derived requirements. Basic requirements are the high-level objectives. They come from FIPS publication 200, which is the federal minimum security standard. And then basic requirements tell you what must be protected for each one of the 14 control families. So think like limited system access to authorized users, broad and outcome focused. Then we have derived requirements. Derived requirements are the prescriptive controls. They come from NIST special publication 853 which is the catalog of every security control NIST has ever defined. So derived requirements tell you how to achieve the basic objectives. So under limit system access to authorized users, you'll have specific derived requirements like enforce session lock after 15 minutes of inactivity or terminate sessions after a defined condition. So the takeaway here is you don't have to invent how to comply. This gives you both the outcome and the implementation guidance and the 110 figure you hear is the total of both basic and derived combined. So wanted to segment out this point for a reason. If you're wondering why we’re bothering spending an entire episode on NIST, this is the answer. NIST has effectively become the most common framework in North America, second to CIS I would say. Federal regulators reference it, cyber insurance carriers explicitly ask about it on their underwriting questionnaires, and they offer better premiums to organizations that can demonstrate NIST alignment. Enterprise procurement teams build vendor risk questionnaires on top of NIST controls and state and local governments are increasingly mandating NIST alignment for their suppliers as well. So even if you have zero government customers today, the moment you want to sell into a regulated industry, get cyber insurance or land a Fortune 500 customer, you're going to be asked NIST-shaped questions. So adopting NIST early is a strategic move not just a compliance exercise. And this is a slide I definitely want everyone watching this to internalize. The single most important distinction in the entire presentation: CSF is recommendations, 8171 are requirements. CSF gives you that maturity language. Nobody's going to audit you against CSF. There's no certifying body for CSF. You adopt it because it makes you better at security, because it gives your business stakeholders a common vocabulary and because it dramatically shortens cyber insurance questionnaires, but it is voluntary. Then 800171 on the other hand is the law of the land if you handle CUI. DFARS clause 7012 requires it. CMMC level 2 requires it as well. So if you fail an audit against it you can lose the contract, face fines under the False Claims Act, or even be suspended from federal procurement entirely. So two completely different beasts. They share the NIST brand and underlying thinking, but operationally they live in different worlds. You’ll likely end up doing both: CSF as your daily maturity model and 800171 as that contract-specific compliance lift. So here’s the strategic argument for why NIST should be your first compliance framework even if no one is forcing you to adopt it yet. Almost every US compliance regime traces back to NIST publications. CMMC is built directly on NIST 800171, FedRAMP is built on NIST 853, FISMA aligns to 853, and HIPAA maps to NIST standards as well. Practically, if you do NIST well, you’ve done 70–90% of the work for other frameworks. The vocabulary transfers, the controls transfer, and the evidence transfers. You’ll answer procurement questionnaires in half the time because the answers are already documented. I tell every prospect and customer the same thing, especially when working with inforcer. We have CIS as the foundation, but that maps to NIST for government contractor customers, and any future compliance lift becomes much faster. One thing I love about NIST is that it’s completely free. There’s no paywall. You don’t need a consultant just to access it. Everything is available at nist.gov/cybersecurity framework, including CSF 2.0, quick start guides, and implementation examples. Then here’s the good news for anyone already invested in Microsoft 365. The platform was essentially built to be NIST friendly. Microsoft maps their entire security stack to NIST in official documentation. Entra ID handles access control and identity. Exchange Online with Defender for Office 365 covers system and information integrity. SharePoint and OneDrive with sensitivity labels handle media protection and configuration management for CUI. Purview handles classification and DLP. Across CSF functions, Entra ID and Purview map to identify, Conditional Access, Intune and Defender map to protect, Defender XDR handles detect, and Sentinel supports respond and recover. So let’s get specific about inforcer. Inforcer ships a pre-built CIS policy library, and because CIS safeguards have official mappings to NIST CSF and NIST 800171, applying CIS-aligned baselines gives you NIST coverage through mapping. Inforcer uses that crosswalk to make NIST operational inside Microsoft 365. Operationally, that gives you one-click application of NIST-aligned baselines across every tenant you manage, continuous drift detection when tenants fall out of alignment, a multi-tenant compliance dashboard showing posture across customers, and policy-level mapping back to specific NIST controls for audit evidence. Critically, there are no more spreadsheets or screenshots. When auditors or insurers ask for NIST coverage, you export an inforcer report instead of digging through old documentation. If you take one thing away, it’s this: NIST CSF is your maturity language. It’s how you talk about cybersecurity internally and externally. It gives a shared vocabulary with executives, auditors, insurers, and procurement teams. NIST 800171 is your compliance lift, but only where contracts demand it. Don’t try to apply all 110 controls everywhere. Target it where CUI exists and where DFARS or CMMC obligations apply. Trying to apply it universally will burn you out and your customers too. Overall, you can use inforcer as the enforcement engine that makes both frameworks achievable at scale. Applying inforcer baselines improves CSF outcomes and 800171 control coverage simultaneously. It’s one enforcement engine delivering multiple frameworks of evidence. Strategy at the top, contract-specific lifts where needed, and technical enforcement through inforcer. I hope that was informative. This is normally where we would take questions, but this is a recorded YouTube series. Thank you so much for joining, and we hope you continue on to the final episode where we tie together all the frameworks covered in this series.
NIST is the common language of enterprise security - and 800-171 is mandatory for anyone in the US defence supply chain. This episode maps the Identify–Protect–Detect–Respond–Recover functions directly to M365, and shows what auditors, insurers, and procurement teams will want to see.
Register now