NIST Cybersecurity Expectations for IT Managed Service Providers

 

IT Managed Service Providers (MSPs) face unique cybersecurity challenges as they maintain privileged access to multiple client environments. NIST provides frameworks that can guide MSPs in establishing robust security programs that protect both their infrastructure and client systems.

 

Core NIST Frameworks for MSPs

 

• NIST Cybersecurity Framework (CSF) offers MSPs a flexible approach to managing cybersecurity risk through five functions: Identify, Protect, Detect, Respond, and Recover. This is particularly valuable for MSPs needing to demonstrate security maturity to clients.
• NIST Special Publication 800-171 guides the protection of Controlled Unclassified Information, critical for MSPs handling government client data or who serve defense contractors.
• NIST SP 800-53 provides detailed security controls that MSPs can implement to protect information systems, especially beneficial when serving federal clients.
• NIST SP 800-161 addresses supply chain risk management, essential for MSPs who represent a potential supply chain vulnerability to their clients.

 

MSP-Specific Security Considerations

 

• Multi-tenant security architecture is expected for MSPs to ensure client environments remain isolated from each other.
• Privileged access management must be rigorously implemented as MSPs typically maintain administrative access to numerous client systems.
• Secure remote access solutions should implement multiple authentication factors and encrypted connections for technicians accessing client networks.
• Incident response capabilities need to address both the MSP's internal systems and coordinated responses for client environments.

 

Implementation Approach for MSPs

 

MSPs should view NIST guidance as a progressive journey rather than a single compliance exercise. Begin by conducting a gap assessment against the NIST CSF, then prioritize improvements based on risk. Document your security program in ways that can be shared with clients during their vendor assessment processes. Creating a System Security Plan (SSP) based on NIST templates demonstrates your commitment to security and provides clients with transparency.

 

For MSPs serving government clients or regulated industries, formal attestation or certification against relevant NIST standards may become a business requirement. Even for MSPs without these requirements, implementing NIST-aligned security practices positions you as a trusted service provider in an increasingly security-conscious marketplace.

How to Make Your IT Managed Service Provider Meet NIST Cybersecurity Expectations

 

Managing your organization's cybersecurity through an IT Managed Service Provider (MSP) introduces unique governance challenges. As your technology partner, MSPs require privileged access to your systems while simultaneously representing a potential attack vector if not properly secured. This guide will help you ensure your MSP adheres to NIST cybersecurity standards, providing you a framework for vendor management that reduces risk while maximizing service value.

 

Understanding NIST's Role in MSP Oversight

 

• The National Institute of Standards and Technology (NIST) develops frameworks and guidelines that represent cybersecurity best practices for organizations of all types.
• NIST does not directly regulate MSPs, but its frameworks provide the foundation for effective MSP security management.
• The NIST Cybersecurity Framework (CSF) and NIST Special Publication 800-171 contain the most relevant controls for MSP oversight.

 

Step 1: Incorporate NIST Requirements into MSP Selection

 

• Include specific NIST alignment requirements in your Request for Proposal (RFP) process when selecting an MSP.
• Request documented evidence that the MSP follows NIST controls in their own operations.
• Ask potential MSPs to provide their score on the NIST CSF if they have conducted a self-assessment.
• Verify they have a documented incident response plan that aligns with NIST SP 800-61.
• Confirm they follow secure development practices aligned with NIST SP 800-218 (Secure Software Development Framework).

 

Step 2: Embed NIST Requirements in Service Level Agreements

 

• Include explicit language in your contract requiring NIST compliance for all services provided.
• Specify required security controls from NIST publications that apply to your industry and data types.
• Include right-to-audit clauses that allow you to verify NIST compliance through assessments or third-party audits.
• Define security reporting requirements that provide visibility into the MSP's security performance.
• Establish security-specific KPIs derived from NIST frameworks to measure MSP security performance.

 

Step 3: Implement Access Control Requirements for Your MSP

 

• Require MSPs to implement role-based access control (RBAC) for their technicians accessing your systems.
• Mandate multi-factor authentication (MFA) for all MSP staff who access your networks or data.
• Establish privileged access management (PAM) policies that limit MSP admin access to only what's necessary.
• Require session recording for all privileged access activities performed by MSP technicians.
• Implement time-limited access tokens that automatically expire after service windows close.

 

Step 4: Require Documented Security Processes from Your MSP

 

• Request written evidence of the MSP's implementation of NIST SP 800-53 controls that apply to your environment.
• Ensure the MSP maintains current system security plans (SSPs) for all systems they manage for you.
• Verify they have documented procedures for patch management aligned with NIST guidance.
• Confirm they follow secure configuration baselines based on NIST standards for all deployed technologies.
• Require documented risk assessment processes that align with NIST SP 800-30.

 

Step 5: Establish Supply Chain Risk Management for Your MSP

 

• Require your MSP to follow NIST SP 800-161 (Supply Chain Risk Management Practices) for their own vendors.
• Ask for disclosure of all subcontractors who may access your data or systems.
• Ensure the MSP conducts regular security assessments of their own third-party providers.
• Verify they have contractual security requirements with their suppliers that match or exceed yours.
• Request transparency around software components used in your environment (a software bill of materials).

 

Step 6: Require Regular Security Testing by Your MSP

 

• Mandate vulnerability scanning of your environment at frequencies aligned with NIST guidance.
• Require annual penetration testing of MSP-managed systems and infrastructure.
• Establish security control assessments on a regular schedule to verify proper implementation.
• Request simulated phishing tests for your staff to protect against social engineering.
• Include tabletop exercises for incident response scenarios involving MSP systems.

 

Step 7: Implement MSP-Specific Incident Response Requirements

 

• Establish clear reporting timelines for security incidents that align with NIST SP 800-61.
• Define specific incident categories with corresponding response procedures for MSP-managed systems.
• Require joint incident response exercises that include both your team and MSP personnel.
• Establish chain-of-custody procedures for digital evidence if a security breach occurs.
• Define communication protocols for various incident severity levels.

 

Step 8: Verify MSP Staff Security Requirements

 

• Require background checks for all MSP personnel who will access your systems.
• Verify the MSP provides security awareness training to their staff per NIST SP 800-50 guidelines.
• Confirm they have security certifications relevant to the services they provide.
• Ensure they have role-specific security training for specialized positions (e.g., cloud administrators).
• Verify they have security onboarding and offboarding procedures to manage access when staff changes occur.

 

Step 9: Establish Ongoing Monitoring of MSP Security

 

• Implement continuous monitoring of MSP activities in your environment.
• Require monthly security metrics reporting that provides visibility into control effectiveness.
• Schedule quarterly security reviews with your MSP to discuss emerging threats and mitigations.
• Implement automated compliance scanning to verify systems meet security baselines.
• Require annual reassessment of the MSP's alignment with current NIST guidelines.

 

Step 10: Develop an MSP Exit Strategy with Security Controls

 

• Create data return procedures that ensure all your information is properly transferred at contract end.
• Establish account deprovisioning requirements to remove MSP access when services terminate.
• Require secure data destruction certification for any of your data retained on MSP systems.
• Develop knowledge transfer protocols to maintain security continuity during provider transitions.
• Include post-termination security obligations in your contract that extend after the service period.

 

Key NIST Publications Relevant to MSP Oversight

 

• NIST Cybersecurity Framework (CSF): Provides a structure for implementing security controls across five core functions: Identify, Protect, Detect, Respond, and Recover.
• NIST SP 800-53: Contains detailed security controls that can be required of your MSP.
• NIST SP 800-171: Particularly important if your MSP handles Controlled Unclassified Information (CUI).
• NIST SP 800-161: Specifically addresses supply chain risk management, which includes MSP relationships.
• NIST SP 800-37: Provides the Risk Management Framework that should guide your MSP security approach.

 

Common MSP Security Gaps to Address

 

• Remote Access Tools: Ensure MSPs use secure, monitored remote access solutions with strong authentication.
• Shared Admin Credentials: Prohibit the use of shared administrative accounts across MSP technicians.
• Software Update Processes: Verify that patch management follows a documented, NIST-aligned methodology.
• Security Monitoring Coverage: Confirm that MSP-managed systems are included in security monitoring solutions.
• Disaster Recovery Testing: Ensure regular testing of backup and recovery procedures for MSP-managed systems.

 

Final Considerations

 

• Remember that you cannot outsource risk - ultimately, your organization remains responsible for security even when using an MSP.
• Develop an MSP management program that treats the provider as an extension of your security team, not a separate entity.
• Consider third-party validation of your MSP's security claims through independent assessments.
• Review your cybersecurity insurance requirements to ensure your MSP relationship meets policy conditions.
• Create a security collaboration model where your internal team works closely with MSP security personnel.

 

By systematically implementing these steps, you'll establish a framework for ensuring your MSP adheres to NIST cybersecurity standards, providing both the protection your organization needs and the documentation required to demonstrate due diligence to regulators, partners, and customers.