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The Operational Technology Cybersecurity Coalition (OTCC) is urging the Cybersecurity and Infrastructure Security Agency (CISA) to issue a binding operational directive (BOD) setting a mandatory cybersecurity baseline for operational technology (OT) in federal civilian executive branch agencies. Its proposal calls for clear agency ownership of OT security, broader application of existing federal requirements, and prioritized controls aligned with CISA performance goals. It is a coalition proposal—not an adopted CISA directive. In its October 6, 2026 report, CyberScoop reported that CISA did not respond to a request for comment before publication.
What OT means in this proposal
Operational technology is programmable equipment and software that monitors or changes the physical environment. Examples include industrial controllers, sensors and actuators, building automation, transportation systems, physical-access controls, and environmental monitoring. Federal OT can also include specialized hospital or laboratory equipment. The U.S. Government Accountability Office (GAO) describes these systems in its September 30, 2026 report, Internet of Things: OMB Action Needed to Ensure Agencies Secure Their Networked Devices.
Because OT interacts with physical processes, cybersecurity failures can affect safety and essential services as well as information systems. The coalition argues that this operational context calls for a baseline that agencies must follow while accounting for the distinct demands of OT environments.
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OTCC’s paper, “Know It. Control It. Contain It.: A Binding Operational Directive for OT Cybersecurity”, organizes its recommendations into three areas.
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1. Assign clear ownership and accountability
Each agency should designate a senior official or unified office accountable for OT cybersecurity governance. That responsibility would cover validated asset inventories, configuration baselines, backup and recovery, incident preparation, and risk reporting. The coalition also calls for OT risk to be integrated into enterprise risk management and for agencies to coordinate the roles of chief information officers and facilities teams.
2. Apply existing federal requirements to OT
The proposal asks CISA to review National Security Agency OT requirements and determine which apply to civilian agencies, enforce relevant existing CISA directives in OT environments, and require agencies to implement applicable Office of Management and Budget (OMB) requirements. OTCC acknowledges that some directives already include OT provisions: “To be fair, CISA has incorporated OT security requirements into prior directives (such as BODs 23-01, 23-02, and 26-04) alongside a host of technical guidance.”
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3. Prioritize controls around CISA performance goals
OTCC recommends aligning implementation with CISA’s Cross-Sector Cybersecurity Performance Goals, with priority attention to managed service providers, asset management, independent validation, identity and access management, least privilege, incident response, segmentation, backups, and preparedness. It also suggests CISA could develop OT-specific performance goals.
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The paper translates its governance recommendations into practical security work: maintain visibility into OT assets through continuous diagnostics and mitigation; establish pragmatic segmentation; make remote access enforceable; document incident-preparedness processes; define configuration baselines; and verify that backup and recovery capabilities work.
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- Know it: Build and validate an inventory so the agency can identify the devices and systems it must protect.
- Control it: Set and enforce access, configuration, and segmentation rules, including controls over remote connections.
- Contain it: Prepare response procedures and recovery capabilities that can limit disruption if an incident occurs.
These are proposed baseline components, not a final CISA checklist. The coalition’s paper says that “as AI reduces the technical barriers to sophisticated cyber operations,” adversaries may identify weaknesses and move laterally through poorly segmented environments more quickly and at greater scale; it argues that this makes an OT-focused directive timely.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Why OTCC says a directive is needed
The coalition identifies three problems: CISA lacks a holistic view of federal OT assets and risks, agencies apply existing requirements inconsistently, and OT incidents can disrupt safety and essential services. It points to attacks affecting water and wastewater systems as part of the broader case for stronger OT security. The proposal is not evidence that a new federal BOD would have prevented those attacks, and its focus is federal OT—not a rule governing the water sector.
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GAO’s September 2026 audit offers a separate measure of implementation challenges. Among 22 civilian agencies covered by the Chief Financial Officers Act, GAO found:
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| OMB networked-device inventory measure | Agencies, out of 22 |
|---|---|
| Had established an inventory of covered networked devices | 15 |
| Were maintaining inventories | 11 |
| Included all information OMB required for each device | 10 |
| Had fully addressed all three OMB requirements | 7 |
These figures are GAO’s findings for the 22 reviewed agencies as of September 2026; the inventory measures cover networked Internet of Things and OT devices. They do not show that all OT in those agencies was unprotected, and they should not be generalized to every federal agency or to private infrastructure operators. GAO says agencies cited technical and resource constraints and competing priorities. It recommends that OMB issue updated cybersecurity guidance and oversee implementation. As GAO put it: “Until OMB issues this guidance, agencies will lack appropriate direction on how and when to complete their device inventories.”
Who would be bound—and who would not
A BOD of the kind proposed would set requirements for the covered federal civilian agencies. It would not, by itself, require private companies, state agencies, or local operators to follow the directive. OTCC argues that federal action could still send those operators a signal about practices government considers important. Michael Garcia, OTCC policy director, described that rationale to CyberScoop: “One, it does make sure that the government is taking its own medicine,” said Garcia, who until recently worked at the agency. “You should practice what you preach. … Second, it sends a very strong signal to the private sector that, ‘This is what we think is important: As an OT partner, owner or operator or critical infrastructure owner or operator, [this is what] you should ask other providers to do.’”
How prevention and resilience fit together
OTCC describes its proposed BOD as a way to establish preventive and containment measures. It contrasts that role with CI Fortify, which the coalition says plans for assumed compromise, isolation, continued operations, and recovery. These are complementary layers: reducing the chance and reach of compromise does not remove the need to keep essential operations running and recover when defenses fail.
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