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Is Voice Cloning Voice Phishing? AI Threats and Risks Explained Simply

Voice cloning and voice phishing are not the same, but they often appear together. Voice cloning is a technique for creating a synthetic voice similar to a real person. Voice phishing is a scam conducted by phone, voice message or messenger to steal money, data, passwords, MFA codes or access. AI can make such an attack sound like a real CEO, employee, customer, supplier or family member.

Prepared by: CCyber Editorial Team

Short answer

Voice cloning is not the same as voice phishing, but it can be a tool used in voice phishing. Voice cloning means creating a synthetic voice similar to a real person. Voice phishing, also known as vishing, means deceiving a person through a phone call, voice message or messenger. The goal may be a payment, MFA code, password reset, bank account change, system access or data disclosure. The most important rule for non-technical users is: if someone calls with an urgent request for money, data, password, access or secrecy, do not judge only by voice. Break the pressure and confirm the request through another known channel.

Last updated

July 2026

Who this article is for

  • boards and business owners
  • finance, accounting and administration employees
  • HR, sales, customer service and support teams
  • IT, security, CISO and vCISO teams
  • executive assistants and office managers
  • SMEs that want to explain new AI risks to employees in simple language
  • companies preparing cybersecurity awareness training
  • organizations that want to reduce deepfake, vishing and CEO fraud risk
  • private individuals who want to understand voice cloning and avoid scams

Key takeaways

  1. Voice cloning is a technique. Voice phishing is a scam. An attacker may use a cloned voice to make voice phishing more convincing.
  2. It is not safe to rely only on “the voice sounds familiar”. Voice, phone number and urgent request are not enough to prove identity.
  3. The biggest risks concern payments, bank account changes, MFA codes, password resets, access granting, customer data and confidential documents.
  4. The best protection is a procedure: stop, confirm through a second channel, use a known number, apply two-person approval and report suspicious contact.
  5. Companies should not train employees to “detect AI by voice”, but to respond safely to pressure and unusual requests.

What is voice cloning?

Voice cloning is the use of AI technology to create a synthetic voice that sounds similar to a real person. Such a voice may imitate tone, speaking pace, accent, emotion and characteristic speech patterns.

To create a voice sample, an attacker may use publicly available material, for example:

  • webinar recording
  • conference speech
  • social media video
  • podcast
  • voice message
  • meeting recording
  • company video
  • event recording

Voice cloning itself may have legitimate uses, for example in digital accessibility, voiceovers, content localization or tools supporting people who have lost their voice. The problem begins when someone uses this technology without consent or for fraud.

What is voice phishing?

Voice phishing, often called vishing, is a scam conducted through voice. It may be a phone call, voice message, messenger call, app call or audio recording. The goal is to persuade a person to take an action they normally would not take.

The attacker may try to steal:

  • money
  • personal data
  • customer data
  • password
  • MFA code
  • account reset
  • system access
  • bank account change
  • document transfer
  • approval of an unusual transaction

Voice phishing can work without AI. A fraudster may simply call and pretend to be a bank, supplier, family member, IT employee or CEO. AI makes the attack more convincing because the voice may sound like someone you know.

Is voice cloning voice phishing?

No. These are two different concepts.

Voice cloning

A technology for creating a synthetic voice similar to a real person.

Voice phishing

A fraud method where the attacker uses a conversation or voice message to manipulate the victim.

How do they connect in practice?

An attacker may use voice cloning to conduct voice phishing. Example: a finance employee receives a call from someone who sounds like the CEO. The voice says that an urgent payment must be made and nobody should be told because the matter is confidential. Technically, this is voice phishing, and voice cloning is the tool that increases attack credibility.

Simply put:

Voice cloning is “how the fraudster sounds”. Voice phishing is “why the fraudster is calling”.

What does such an attack look like step by step?

Step 1: choosing the impersonated person

The attacker chooses a person whose voice may create trust or pressure. This may be a CEO, CFO, manager, customer, supplier, IT employee or family member.

Step 2: collecting a voice sample

The attacker searches for online recordings or obtains a short voice sample from another source. The more public speeches, podcasts and videos exist, the easier it is to prepare convincing material.

Step 3: preparing the story

The fraudster prepares a story. It is usually urgent, stressful and unusual. Example: payment, bank account change, outage, confidential transaction, arrest, customer problem or urgent access reset.

Step 4: contacting the victim

Contact may happen by phone, voice message, messenger or as part of a larger attack that starts with email.

Step 5: pressure for quick action

The attacker uses emotion and authority. They may say: “this is urgent”, “do not tell anyone”, “the customer is waiting”, “the board approved this”, “this is confidential”, “do it now”.

Step 6: action is performed

The victim makes a payment, provides an MFA code, changes supplier data, sends a document, resets a password or grants access.

Step 7: hiding traces

The fraudster may ask for secrecy, move to another channel or request deletion of messages. Sometimes, after the first success, they try to force additional actions.

Common company scenarios

1. Call from the “CEO” asking for payment

A finance employee receives a call from a voice that sounds like the CEO. The request concerns an urgent payment, often to a new recipient or foreign account.

2. “CFO” confirms bank account change

The attacker calls after an earlier email about changing supplier bank details. The voice is supposed to confirm that the change is genuine.

3. “IT” asks for an MFA code

The fraudster pretends to be an IT employee and asks for an MFA code, approval of a push notification or password reset.

4. “Customer” asks for documents

A person sounding like a customer asks to send a contract, report, invoice, project data or documentation to a new email address.

5. “Supplier” requests an urgent data change

The attacker impersonates a supplier and asks to change bank account number, contact email or portal login data.

6. “Manager” asks for access

A manager’s voice asks IT to quickly grant access to an employee, consultant or supplier.

7. Deepfake in a video meeting

The attack may combine voice and image. A meeting participant looks and sounds credible, but asks for an unusual decision, payment or process change.

Common private-life scenarios

1. “Son” or “granddaughter” in an emergency

A person receives a call from the voice of a loved one. The story involves an accident, arrest, hospital, debt or immediate financial need.

2. “Police officer” or “lawyer” confirms the story

After the voice of the loved one, another person joins and increases pressure, saying money must be paid quickly.

3. “Bank” asks to confirm a transaction

The fraudster impersonates a bank and asks for a code, login data, app installation or “security transfer”.

4. “Friend” asks for a loan

A voice message or call sounds like a friend. The request involves a quick loan, payment or gift card purchase.

Why does voice deceive so easily?

Voice builds trust

People naturally trust familiar voices. When you hear the speech pattern of someone you know, your brain quickly fills in the rest of the story.

Emotions reduce caution

Fear, shame, pressure, secrecy and authority reduce logical thinking. The fraudster wants the victim to act before checking facts.

The phone number can also mislead

A familiar number or contact name may appear on the screen. This does not always mean the call is genuine, because a number may be spoofed or communication may come through another account.

AI removes old warning signs

In the past, phishing was often exposed by language mistakes, strange accent or artificiality. Today, a scam may be fluent, correct and context-aware.

The most important rule for non-technical users

Do not trust voice alone.

If the request concerns money, data, password, MFA code, access, documents, bank account change or secrecy, always confirm it through a second channel.

A second channel means:

  • call a previously known number
  • write in the known company messenger
  • contact the manager
  • check CRM or the contract
  • confirm with another person on the team
  • apply two-person approval

Do not use the phone number or link given by the caller in the suspicious conversation. Use a channel you already knew.

Red flags

Time pressure

“You must do this now”, “we do not have time”, “the customer is waiting”, “the payment must go out today”.

Request for secrecy

“Do not tell anyone”, “this is confidential”, “the board does not want confusion”.

Unusual channel

The CEO writes from a private messenger, a customer calls from a new number, a supplier asks to communicate outside the normal path.

Request to bypass procedure

“We will do the paperwork later”, “skip approval this time”, “this is an exception”.

Bank account or recipient change

Every urgent change of payment details should be treated as high risk.

MFA code or password

Nobody should ask for an MFA code by phone. Such a request should not be fulfilled.

New email address or new number

If someone asks to send documents to a new address, it must be independently verified.

Refusal to verify

If the caller insists that you must not call back, ask anyone or check, that is a strong warning sign.

How should a company defend itself?

1. Introduce second-channel verification

Every unusual request for money, data, access, password, MFA code, bank account change or procedure bypass should be confirmed through another channel.

2. Use two-person approval

Large payments, new payment recipients, bank account changes, administrator access and sensitive data transfers should require approval by two people.

3. Use known numbers and contacts

Do not call back the number provided in the conversation. Use a number from the contract, CRM, company directory or previously confirmed channel.

4. Never share MFA codes

An MFA code, push notification and password reset link are security controls. Do not share them by phone, messenger or email.

5. Prepare a safety phrase

For high-risk situations, the company can define a safety phrase. It should not be based on information available on social media.

6. Limit public voice samples

It is not always possible to avoid recordings, but public appearances of high-risk people such as board members, finance, PR and decision makers should be managed consciously.

7. Train employees on scenarios

Training should show real situations: call from the “CEO”, payment request, supplier bank account change, MFA code, fake customer and deepfake in a meeting.

8. Prepare fast reporting

An employee should know where to report a suspicious call, voice message or meeting. Reporting should be simple and non-punitive.

How can private individuals defend themselves?

Pause

If the call creates fear and urgency, that may be exactly what the fraudster wants.

Call back using a known number

Hang up and call the person who supposedly contacted you using the number already saved in your contacts.

Ask someone close

If you cannot reach the person, call another family member or friend.

Do not send money under pressure

The fraudster often asks for quick transfer, cryptocurrency, gift cards or money transfer. That is a major red flag.

Set a family safety phrase

A family can agree on a short emergency phrase. It should not be public information or something easy to guess.

Do not share data or codes

Do not share codes, passwords, bank data, document numbers or login details by phone.

What should a company do in the first 30, 60 and 90 days?

First 30 days

  • assign owner for deepfake audio and voice phishing readiness
  • identify high-risk processes: payments, data, access, passwords, suppliers
  • introduce second-channel verification for unusual requests
  • introduce the rule: never share MFA codes by phone
  • prepare red flag list
  • train finance, IT, HR and executive assistants
  • define suspicious call reporting channel
  • review public recordings of high-risk people

Days 31 to 60

  • introduce two-person approval for payments and bank account changes
  • prepare supplier verification procedure
  • prepare safety phrase for critical situations
  • prepare exercise scenarios for teams
  • update password reset procedure
  • update access granting procedure
  • prepare suspicious call playbook
  • prepare fake video meeting playbook

Days 61 to 90

  • run tabletop exercise with board, finance, IT and HR
  • run an urgent payment request simulation
  • check whether employees know where to report suspicious contacts
  • measure response time to a suspicious request
  • prepare board report
  • add voice cloning topic to onboarding
  • schedule recurring training
  • update procedures based on exercise findings

What documents and evidence should be prepared?

Procedures

  • second-channel verification procedure
  • urgent payment approval procedure
  • bank account change procedure
  • password reset procedure
  • access granting procedure
  • suspicious call handling procedure
  • fake video meeting handling procedure

Training materials

  • employee instruction
  • red flag list
  • call scenarios
  • knowledge quiz
  • materials for finance, IT, HR and sales
  • materials for the board

Organizational evidence

  • training participant list
  • knowledge test results
  • tabletop exercise report
  • remediation action list
  • suspicious call register
  • exception register
  • board report

Technical evidence

  • MFA report
  • administrator list
  • unusual password reset report
  • supplier access report
  • phishing and vishing report logs
  • public recording list for high-risk people

How to measure company readiness?

Training metrics

  • number of trained employees
  • number of trained high-risk people
  • knowledge test result
  • number of teams included in exercise
  • number of employees who know the reporting channel

Process metrics

  • number of high-risk payments approved by two people
  • number of bank account changes confirmed through second channel
  • number of password resets outside procedure
  • number of process exceptions
  • time to confirm unusual request

Incident metrics

  • number of reported suspicious calls
  • number of reported voice messages
  • number of MFA code theft attempts
  • number of fake bank account change attempts
  • response time to report

Risk metrics

  • number of public recordings of high-risk people
  • number of processes without two-person approval
  • number of teams without second-channel procedure
  • number of suppliers without confirmed contact details
  • number of accounts without MFA in critical processes

Common mistakes

Mistake 1: “I will know by the voice”

This is not a good security control. The voice may sound familiar, and emotions may reduce caution.

Mistake 2: confirming in the same channel

If the suspicious request came by phone, continuing the same conversation is not verification.

Mistake 3: no procedure for urgent requests

If the company has no procedure, the employee decides alone, under pressure and often without evidence.

Mistake 4: “do not bother anyone” culture

If employees are afraid to interrupt a call or ask a manager, the fraudster has an easier task.

Mistake 5: safety phrase based on public information

Questions about family, school, city or pets may be available online. A safety phrase should not rely on such information.

Mistake 6: no board training

The board’s voice may be used in an attack. The board should clearly communicate that procedures matter more than apparent urgency.

Mistake 7: no reporting of suspicious contacts

A suspicious call may be the first sign of a larger campaign against the company.

Mistake 8: no exercises

An employee may know the procedure in theory, but under stress will act the way they practiced. That is why exercises matter.

Business example

A finance employee receives a call from someone who sounds like the CFO. The caller says they are in a meeting with an investor and need an immediate transfer to a new supplier. They ask not to involve anyone else because the matter is confidential.

The employee knows the procedure. They do not make the transfer during the call. They end the call, check the CFO’s number in the company directory and contact them through a known channel. It turns out the CFO did not call and did not request the payment.

The company reports the incident to security, blocks the attempted supplier data change, informs the finance team and runs a short exercise for employees. The key outcome: the employee did not need to recognize whether the voice was synthetic. It was enough to follow the procedure.

How can ccyber.io help?

ccyber.io helps companies prepare employees and processes for voice cloning, voice phishing, deepfakes and AI-supported fraud. We do not only teach technology recognition. We help build procedures that work even when the voice sounds credible.

We can support your organization with:

  • voice cloning and voice phishing training
  • AI scams awareness for employees
  • training for finance, IT, HR, sales and board
  • second-channel verification procedure
  • urgent payment procedure
  • bank account change procedure
  • suspicious call playbook
  • fake video meeting playbook
  • tabletop exercise for deepfake audio scenario
  • review of public recordings of high-risk people
  • audit-ready training evidence pack

The best first step is a Voice Phishing and AI Scam Readiness Workshop. In a short workshop, the company can identify the most exposed processes, which procedures must change, who should be trained first and how to prepare simple protection against voice scams.

FAQ

Are voice cloning and voice phishing the same?

No. Voice cloning is a technology for creating a synthetic voice. Voice phishing is a voice-based scam. Voice cloning can be used for voice phishing.

What is vishing?

Vishing is voice phishing. The attacker uses a phone call, voice message or messenger to steal money, data, password, MFA code or access.

Can a cloned voice be recognized by sound?

Sometimes strange elements may be noticed, but this should not be relied on. Second-channel verification is safer.

What should I do if the “CEO” calls with an urgent request?

Do not perform an unusual request during the call. End the contact and confirm through a known channel. If money, data or access are involved, use two-person approval.

Is the phone number on the screen enough evidence?

No. The number may mislead, and contact may come from a compromised account or spoofing. Independent verification matters more.

Does a safety phrase solve the problem?

A safety phrase can help, but it should not replace procedure. It works best with a second channel, two-person approval and exception documentation.

Who should be trained first?

Start with finance, accounting, IT, HR, executive assistants, sales, customer service and people who can approve payments, access or data transfers.

Which actions should be implemented immediately?

Introduce second-channel verification, ban sharing MFA codes, use two-person approval for payments, prepare bank account change procedure and create a simple channel for reporting suspicious calls.

Summary

Voice cloning is a technology, while voice phishing is a scam. The combination is dangerous because the voice may sound like someone you trust, and the conversation may involve urgent money, data, access or password requests.

The best protection is not that an employee recognizes a synthetic voice. The best protection is that they know what to do: stop, do not act under pressure, confirm through a second channel, use two-person approval and report suspicious contact.

In the AI era, voice is no longer sufficient proof of identity. Companies that understand this early will reduce the risk of fake payments, data leaks, account takeover and wrong decisions under pressure.

Sources

Shadow AI: How Employees Use AI Outside Organizational Control

Shadow AI happens when employees use AI tools without the organization’s knowledge, approval or control. They often do it to write emails faster, analyze documents, create presentations, summarize meetings, write code or support customers. The problem is not AI itself, but the lack of rules, tool inventory, data controls, supplier assessment, logs, training and a safe alternative for employees.

Prepared by: CCyber Editorial Team

Short answer

Shadow AI means using AI tools outside organizational control. An employee may use a private ChatGPT, Copilot, Gemini, Claude, Perplexity account, transcription tool, presentation generator, coding assistant or AI browser plug-in without the knowledge of IT, security, legal, compliance or their manager. The biggest risk appears when customer data, contracts, financial documents, HR data, source code, vulnerability information, strategic plans or trade secrets enter such a tool. The answer is not only a ban. The company should understand why employees use AI, prepare approved tools, clear policy, data classification, process for requesting new tools, training, risk-proportionate monitoring and an AI incident response procedure.

Last updated

July 2026

Who this article is for

  • boards
  • business owners
  • CISOs, vCISOs, CTOs and IT directors
  • AI officers, data officers, legal, compliance and DPO teams
  • HR, finance, sales, marketing, customer service and product owners
  • software houses, SaaS companies and digital product manufacturers
  • SMEs seeing employees adopt AI faster than the company defines rules
  • organizations deploying ChatGPT, Copilot, Gemini, Claude, chatbots, RAG or AI agents
  • companies preparing for the AI Act, ISO 42001, ISO 27001, NIS2, SOC 2 or cyber insurance

Key takeaways

  1. Shadow AI is not only an employee problem. It is a signal that the company has not provided safe tools, clear rules or an AI approval process.
  2. The highest risk concerns confidential data, customer data, personal data, source code, secrets, financial documents and vulnerability information.
  3. A complete AI ban often does not work. It may push AI use into private accounts and private devices, even further outside organizational control.
  4. The company should have an AI tool register, AI usage policy, prohibited data list, approved tools, training, exception process and AI incident playbook.
  5. The best approach is controlled adoption: enable employees to use AI where it creates value, but with clear boundaries for data, access, accountability and auditability.

What is Shadow AI?

Shadow AI is the use of artificial intelligence tools without formal approval, knowledge or supervision from the organization. It may be a public tool, private user account, free app, browser plug-in, code editor extension, meeting transcription tool, messaging bot or SaaS application with AI features purchased by a department without IT and security review.

Shadow AI may look harmless. An employee only wants to write an email faster, shorten a report, translate a document, prepare a meeting agenda, improve a proposal or summarize a customer call. The problem appears when data enters a tool that the company did not intend to share with an external provider.

Shadow AI includes, among other things:

  • using a private AI account for work tasks
  • pasting company documents into a public chatbot
  • uploading meeting recordings to unapproved AI transcription
  • using AI browser plug-ins without IT approval
  • using AI coding tools without security rules
  • analyzing customer data in a tool without contract and supplier assessment
  • generating customer replies automatically without human control
  • using AI agents with access to email, files or calendar without organizational approval

Why do employees use AI outside company control?

Most Shadow AI cases do not result from bad intent. Employees use AI because they see immediate value: saving time, easier writing, faster analysis, less routine work and higher productivity.

Most common reasons

  • the company has not provided an approved AI tool
  • tool approval process is too slow
  • the employee does not know the tool is risky
  • AI policy does not exist or is unclear
  • the approved tool is worse than public alternatives
  • the employee wants to avoid long administrative tasks
  • the manager expects faster work but provides no tools
  • a department buys a SaaS tool with AI without consulting IT
  • employees see competitors using AI and do not want to fall behind

This is an important lesson for the board: Shadow AI often reveals a real business need. The company should organize that need, not only punish its existence.

How do employees use AI outside organizational control?

1. Writing emails and documents

Employees paste correspondence, case descriptions, offer drafts, customer documents, complaints, notes and contracts into AI to prepare a reply or summary.

2. Summarizing meetings

AI transcription and note tools may record meetings with customers, candidates, lawyers, suppliers or the board. Risks concern consent, confidentiality, retention and data location.

3. Analyzing documents

AI is used to analyze contracts, reports, specifications, technical documents, CVs, offers, invoices and project documentation. Often without checking whether this data may leave a controlled environment.

4. Translation

Employees translate commercial, legal, HR, technical and financial documents in public AI tools. This may disclose trade secrets or NDA-covered content.

5. Writing code

Developers use AI to generate code, analyze bugs, refactor, write tests and explain repository fragments. Risks concern source code, secrets, vulnerabilities and licenses.

6. Analyzing data

Employees upload spreadsheets, CRM exports, sales data, customer data, financial data and operational data to prepare summaries, forecasts or charts.

7. Customer service

Support and sales teams use AI to draft replies, summarize tickets, translate communication or suggest next actions. Risk increases when output reaches the customer without review.

8. Creating presentations and marketing materials

Marketing uses AI for campaigns, images, product descriptions, posts, slides and market analysis. Risks include content rights, false claims, customer data and brand compliance.

9. Automation with private tools

An employee may connect a private AI tool to mailbox, calendar, files or messenger to automate tasks. This is an especially risky form of Shadow AI.

10. Departmental experiments

A department buys an AI tool for recruitment, sales, analytics, customer service or marketing without legal, security and data protection assessment.

Why is Shadow AI risky?

Risk 1: data leakage

The most obvious risk is sending confidential data to a tool that has not been assessed. This may include customer data, personal data, contracts, code, strategies, prices, proposals and technical information.

Risk 2: no retention control

The company may not know how long the tool stores prompts, outputs, files, transcripts and conversation history. It may also not know whether the user can delete data and whether the company administrator has control.

Risk 3: use of data for training or service improvement

Some tools may use user data to improve the service if proper settings or contracts are not in place. For confidential data, this is a serious problem.

Risk 4: no contract and supplier assessment

An employee’s public account usually gives the company no control over data processing terms, subprocessors, data location, audit, incidents and data deletion.

Risk 5: false or unverified results

AI may generate a response that sounds credible but is wrong. If it reaches a customer, offer, legal analysis or business decision, the problem is not only technical.

Risk 6: breach of GDPR, NDA or customer contract

Personal data, customer data and confidential information may be subject to contractual or legal limitations. Shadow AI may cause the company to violate these limitations without board awareness.

Risk 7: code and secret leakage

Pasting code, logs, API keys, tokens, passwords or vulnerability information into an AI tool may create real risk for the product and infrastructure.

Risk 8: prompt injection and manipulation

If an employee uses AI to analyze external documents, emails or websites, a malicious instruction hidden in the content may manipulate AI output.

Risk 9: no auditability

The company may not know who used the tool, which data was entered, what output was produced and whether the result was used in a decision or customer communication.

Risk 10: decisions outside process control

If AI affects recruitment, employee assessment, commercial offers, complaint handling, financial recommendations or customer communication, the company must have process oversight and accountability.

Why is a simple AI ban often not enough?

A ban may be necessary for high-risk data and unassessed tools, but a ban alone rarely solves the problem. Employees use AI because they have real needs. If the company provides no safe alternative, some usage will move to private accounts, private devices and informal processes.

A better approach combines several elements:

  • clear rules
  • approved tools
  • prohibited data list
  • practical training
  • fast process for requesting new tools
  • risk monitoring
  • consequences for intentional policy violations
  • support for teams that want to use AI legally and safely

Shadow AI should be treated as a governance and work design problem, not only as a disciplinary problem.

How to prepare the company for Shadow AI step by step?

Step 1: create an AI tool register

The company should know which AI tools are already used. This is not about hunting employees, but about understanding the scale and type of risk.

The register should include:

  • tool name
  • team using the tool
  • purpose
  • business owner
  • data type
  • whether the tool is approved
  • whether there is a supplier contract
  • whether a company or private account is used
  • whether the tool has logs
  • risk level

Evidence to prepare: AI tool register, including approved, pilot and informally detected tools.

Step 2: identify the most common use cases

Not every AI use has the same risk. Drafting an internal note without confidential data is different from analyzing a customer contract or source code.

Divide use cases into:

  • low risk
  • medium risk
  • high risk
  • prohibited without additional approval

Evidence to prepare: AI use case list with risk rating.

Step 3: prepare AI usage policy

The AI policy should be short, understandable and practical. After reading it, an employee should know what is allowed, what is prohibited and where to ask for approval.

The policy should include:

  • approved AI tools
  • allowed use cases
  • prohibited use cases
  • customer data rules
  • personal data rules
  • confidential data rules
  • source code rules
  • AI use in customer communication
  • new tool request process
  • AI incident reporting process

Evidence to prepare: AI usage policy and employee acknowledgment.

Step 4: define prohibited data

Employees need concrete examples. A generic “do not paste confidential data” statement is often not enough.

Data that must not be entered into unapproved AI tools

  • customer data
  • personal data
  • HR and payroll data
  • contracts
  • financial data
  • trade secrets
  • source code
  • API keys, tokens, passwords and secrets
  • vulnerability information
  • non-public strategic plans
  • NDA-covered data

Evidence to prepare: prohibited data list and department-specific examples.

Step 5: give employees a safe alternative

If the company bans public tools but provides no approved solution, employees will find a workaround. A safe alternative reduces pressure for Shadow AI.

An approved tool should have:

  • company account
  • SSO
  • MFA
  • administrator control
  • retention settings
  • clear data rules
  • supplier contract
  • ability to revoke access
  • usage logs where needed and lawful

Evidence to prepare: approved AI tool list and security configuration.

Step 6: prepare a fast approval process for new tools

The approval process cannot take months if teams need AI for work. A slow process increases Shadow AI.

The process should answer:

  • who requests the tool?
  • which data will be used?
  • who is the business owner?
  • does the tool have a contract and supplier assessment?
  • is DPO assessment needed?
  • is security assessment needed?
  • can a pilot be run?
  • who approves use?

Evidence to prepare: AI tool request form and approval path.

Step 7: assess AI suppliers

An AI supplier should undergo basic assessment, especially if the tool will be used with company, customer or personal data.

Check:

  • data processing terms
  • data location
  • data retention
  • whether data is used to train models
  • subprocessors
  • encryption
  • SSO and MFA
  • logs
  • incident handling
  • data deletion capability
  • security certifications and documents

Evidence to prepare: AI supplier assessment and risk acceptance decision.

Step 8: deliver practical training

Shadow AI training should be concrete and team-specific. Employees should see examples from their own work, not only a general AI presentation.

Training should cover:

  • what Shadow AI is
  • which data is prohibited
  • how to use approved tools
  • how to verify AI outputs
  • what prompt injection is
  • how to use AI in customer communication
  • how to use AI in code
  • how to request new tools
  • how to report an AI incident or error

Evidence to prepare: training materials, participant list and knowledge test result.

Step 9: monitor risk proportionately

Shadow AI monitoring should be lawful, proportionate and transparent to employees. The goal is not to monitor every conversation, but to detect risky tools, data flows and policy violations.

Possible information sources:

  • surveys and voluntary reporting
  • departmental tool register
  • SaaS expense review
  • proxy or CASB log analysis where used by the company
  • DLP for high-risk data
  • browser plug-in review
  • manager reports
  • incidents and near misses

Evidence to prepare: Shadow AI risk review report without excessive intrusion into employee privacy.

Step 10: prepare an AI incident playbook

The company should know what to do if an employee pasted customer data into an unapproved tool, an AI tool disclosed data, a supplier reported an incident or AI generated harmful customer output.

The playbook should cover:

  • who receives the report
  • how to preserve evidence
  • how to determine which data entered the tool
  • how to contact the supplier
  • how to delete data where possible
  • how to assess personal data and customer impact
  • who decides on communication
  • how to block the tool or integration
  • how to update policy and training after the incident

Evidence to prepare: AI incident response playbook and tabletop exercise report.

Shadow AI across departments

HR

HR may use AI to analyze CVs, write job ads, summarize interviews, create HR documents and communicate with employees. Risks involve personal data, bias, incorrect candidate assessment and confidential employee information.

Finance

Finance may use AI to analyze invoices, reports, forecasts, cash flow, contracts and supplier data. Risks involve financial data, contractor data, payments, wrong analysis and confidential commercial terms.

Sales

Sales may use AI for offers, emails, customer analysis, meeting summaries and inquiry responses. Risks involve customer data, pricing, margins, contract terms and communication inconsistent with the offer.

Marketing

Marketing may use AI for content, graphics, campaigns, market analysis and presentations. Risks include copyright, false claims, customer data, deepfake and brand compliance.

IT and security

IT may use AI for scripts, configuration, log analysis, documentation and troubleshooting. Risks involve disclosure of architecture, production logs, vulnerabilities, secrets and configuration details.

Development

Developers may use AI to write code, tests, refactor and analyze bugs. Risks involve source code, secrets, licensing, code quality and vulnerabilities in generated fragments.

Customer service

Support may use AI for replies, ticket summaries and customer history analysis. Risks involve customer data, wrong answers, disclosure of internal information and automation without human control.

How to detect Shadow AI without creating a culture of fear?

The best companies do not start with accusations. They start with conversation and a safe reporting channel. Employees should be able to say they use an AI tool without immediate fear of punishment.

Good methods

  • anonymous survey on AI use
  • department workshops
  • open tool request process
  • approved tool list
  • safe pilot
  • education instead of fear
  • SaaS expense analysis
  • review of risky plug-ins and apps

What to avoid

  • publicly shaming employees
  • banning without an alternative
  • unclear rules
  • monitoring without transparency
  • treating every experiment as an incident
  • ignoring business needs of teams

The goal is to move AI out of the shadows into a controlled process.

Minimum Shadow AI control checklist

Governance

  • does the company have an AI usage policy?
  • does an AI tool register exist?
  • does every tool have an owner?
  • is there an approval process for new tools?
  • does the board know the top AI risks?

Data

  • is there a prohibited data list?
  • do employees know what must not be pasted into AI?
  • is customer data treated as high risk?
  • are personal data rules clear?
  • are code and secrets covered by separate rules?

Suppliers

  • are AI suppliers assessed before use?
  • is it known whether data is used to train models?
  • is retention understood?
  • are subprocessors known?
  • can data be deleted after use ends?

Access

  • do approved tools have SSO?
  • is MFA enabled?
  • is access removed during offboarding?
  • are administrator roles defined?
  • are private accounts prohibited for company data?

Process

  • are AI outputs verified before sending to customers?
  • can AI take action without a human?
  • are there rules for AI use in code?
  • does an AI incident playbook exist?
  • do employees know how to report risky AI use?

How to prepare a Shadow AI policy?

1. Plain language

The policy should be understandable for employees outside IT. The more legalistic the language, the less likely employees will use it in practice.

2. Approved tool list

The employee should know which tool they can use and for which tasks.

3. Prohibited data list

Give concrete examples: contracts, customer data, code, API keys, HR data, financial documents, vulnerability information.

4. Examples of allowed use

Show that AI is not prohibited everywhere. For example, AI may be used to edit a neutral text if it contains no confidential data.

5. Exception process

If a department wants to use a new tool, it should have a clear request path and fast response.

6. Accountability rules

AI output must be checked by a human. The employee remains responsible for content they send, publish or use in a decision.

7. Incident reporting rules

If someone pasted confidential data into an unapproved tool, they should know where to report it. The company should encourage quick reporting, not hiding mistakes.

30, 60 and 90-day action plan

First 30 days

  • assign Shadow AI owner
  • prepare a short survey on AI use in the company
  • create an initial AI tool register
  • identify teams using AI most often
  • define data prohibited in unapproved tools
  • prepare a short AI policy
  • choose an approved tool or pilot
  • block the riskiest use cases without alternative only where risk is critical

Days 31 to 60

  • assess suppliers of the most commonly used tools
  • configure SSO, MFA, roles and retention in the approved tool
  • launch new AI tool request process
  • train high-risk departments
  • prepare AI rules for code and customer documents
  • define how Shadow AI risk will be monitored
  • prepare AI incident response procedure
  • prepare AI risk dashboard for the board

Days 61 to 90

  • expand approved AI use to additional teams
  • close or replace high-risk unapproved tools
  • run a knowledge test and collect employee questions
  • update policy based on real use cases
  • test a Shadow AI incident scenario
  • prepare board report
  • define quarterly AI tool review
  • prepare 12-month AI governance and AI security roadmap

What documents and evidence should be prepared?

Governance documents

  • AI usage policy
  • AI tool register
  • AI use case register
  • accountability matrix
  • new AI tool approval process
  • exception and risk acceptance register
  • board report

Data documents

  • data classification
  • data prohibited in AI list
  • customer data usage rules
  • personal data usage rules
  • source code usage rules
  • meeting transcription rules

Supplier and tool evidence

  • AI supplier assessment
  • contract or terms of use
  • retention settings
  • model training information
  • administrator list
  • SSO and MFA report
  • usage log report

Training evidence

  • training agenda
  • training materials
  • participant list
  • knowledge test results
  • AI policy acknowledgment
  • employee questions and concerns report

Incident response evidence

  • AI incident response playbook
  • AI incident reporting form
  • log preservation procedure
  • AI supplier contact procedure
  • tabletop scenario
  • exercise report
  • remediation action list

How to measure Shadow AI risk?

Adoption metrics

  • number of AI tools in the register
  • number of approved AI tools
  • number of unapproved AI tools
  • number of active users of approved tools
  • number of teams covered by AI policy

Data metrics

  • number of use cases with customer data
  • number of use cases with personal data
  • number of prohibited data list violations
  • number of reports of confidential data pasted into AI
  • number of tools without clear retention

Governance metrics

  • number of tools without owner
  • new tool approval time
  • number of policy exceptions
  • number of AI supplier assessments
  • number of board decisions related to AI

Training metrics

  • number of trained employees
  • knowledge test result
  • number of questions after training
  • number of new tool requests after training
  • number of reported incidents or near misses

Technical metrics

  • number of approved tools with SSO
  • number of approved tools with MFA
  • number of tools with usage logs
  • number of tools with configured retention
  • number of detected risky plug-ins or applications

Common company mistakes

Mistake 1: pretending employees do not use AI

No reports does not mean no usage. It often means employees do not know where to report tools or fear consequences.

Mistake 2: full ban without an alternative

A ban may reduce visible use, but increase private and uncontrolled use of AI tools.

Mistake 3: policy without examples

Employees need concrete examples: what must not be pasted, which tools are approved and when approval is needed.

Mistake 4: no supplier assessment

An AI tool used with company data should be assessed for retention, model training, data location, subprocessors and incident handling.

Mistake 5: no tool owners

If nobody owns the tool, nobody is accountable for data, access, configuration, costs and risk.

Mistake 6: no team-specific training

HR, finance, sales, IT, development and marketing use AI differently. Training should reflect real scenarios for each team.

Mistake 7: no exception process

If an employee has nowhere to request a new tool, they will likely use it outside the process.

Mistake 8: no AI incident response

When data enters an unapproved tool, the company must know how to assess scope, preserve evidence, contact the supplier and decide on communication.

Business example

A consulting company with 120 employees has no official AI tool. Employees privately use different chatbots for email writing, translation and document summarization. One consultant pastes a customer contract excerpt into a public tool to prepare a summary for the team.

After the case is reported, it turns out there are more similar situations. HR uses AI for document drafting, sales for offers, marketing for presentations and developers for code analysis. The company has no policy, tool list, supplier assessment or data rules.

The board decides not to introduce a blind ban. The company launches a controlled AI programme. It creates a tool register, approves one company solution, enables SSO and MFA, configures retention, prepares a prohibited data list, trains teams and launches a new tool request process.

After 90 days, the company still uses AI, but most use has moved to the approved tool. Employees know what must not be pasted, and the board has an AI risk dashboard and a plan for further AI governance development.

How can ccyber.io help?

ccyber.io helps companies move Shadow AI from uncontrolled usage into a safe, measurable and managed AI programme. We do not start from a ban. We start by understanding how employees really use AI, which data is at risk and which tools should be approved.

We can support your organization with:

  • Shadow AI discovery
  • AI tool register
  • AI usage policy
  • data classification for AI
  • prohibited data list for AI
  • AI supplier assessment
  • new AI tool approval process
  • AI security awareness training
  • Prompt Injection awareness
  • AI incident response playbook
  • AI risk dashboard for the board
  • 30, 60, 90-day and 12-month AI governance and AI security roadmap

The best first step is a Shadow AI Readiness Workshop. In a short workshop, the company can determine which AI tools are used, which teams are most exposed, which data must be protected, which uses can be approved and which must be limited immediately.

FAQ

What is Shadow AI?

Shadow AI is the use of AI tools without organizational knowledge, approval or control. It may include private AI accounts, unapproved apps, plug-ins, transcription tools, content generators and AI agents.

Is Shadow AI always bad?

Not always. AI use often shows a real business need. The problem is lack of control over data, supplier, retention, outputs, accountability and auditability.

Should the company ban AI completely?

Not always. In many cases, providing an approved tool, clear rules, training and a process for new requests is better. A ban without an alternative may increase hidden AI use.

Which data is highest risk?

Customer data, personal data, contracts, HR data, financial data, source code, secrets, vulnerability information, strategies, offers and NDA-covered data.

How can Shadow AI be detected?

Start with surveys, workshops, tool register, SaaS expense review and conversations with teams. Technical monitoring can help, but should be proportionate, transparent and lawful.

What should we do if an employee pasted confidential data into public AI?

Quickly determine what data was shared, which tool was used, whether deletion is possible, what the legal and business impact is, and whether the customer, DPO, supplier or regulator must be contacted.

Is an AI policy enough?

No. A policy is necessary, but it must be combined with approved tools, training, reporting process, supplier assessment, data controls and an AI incident playbook.

Where should we start?

Start with an AI tool register, short policy, prohibited data list, team survey, approved safe alternative and training for high-risk employees.

Summary

Shadow AI will not disappear by itself. Employees use AI because the tools genuinely help them write, analyze, translate, code and support customers. The problem starts when the company does not know which tools are used, which data enters them and who owns the risk.

The best approach is not a blind ban. It is moving AI from the shadows into a controlled process: tool register, AI policy, approved solutions, prohibited data list, supplier assessment, training, risk monitoring and AI incident procedure.

A company that manages Shadow AI well does not block innovation. It gives employees a safe way to use AI while protecting customer data, confidentiality, reputation, compliance and business accountability.

Sources

AI Security for Companies: What to Secure Before Deploying Generative AI Tools

Before deploying generative AI tools, a company should secure data, accounts, access, integrations, prompt injection, RAG, AI agents, logs, suppliers, usage rules, human oversight and incident response. The biggest mistake is treating AI like a normal SaaS application. Generative AI may process confidential data, generate wrong outputs, perform actions and affect customers, employees and business decisions.

Prepared by: CCyber Editorial Team

Short answer

Before deploying generative AI tools, a company should secure not only the AI tool itself, but the full process in which AI will be used. The most important areas are: input data, output data, user permissions, supplier access, system integrations, logs, data retention, prompt injection, RAG, AI agents, output validation, human oversight, employee training and incident response. Generative AI should not be deployed by “turn it on and see what happens”. First define the purpose, owners, allowed data, prohibited use cases, risk level, security controls and evidence showing the deployment is controlled.

Last updated

July 2026

Who this article is for

  • boards
  • business owners
  • CISOs, vCISOs, CTOs and IT directors
  • AI officers, data officers, legal, compliance and DPO teams
  • HR, finance, sales, marketing, customer service and product owners
  • software houses, SaaS companies and digital product manufacturers
  • SMEs deploying ChatGPT, Copilot, Gemini, Claude, chatbots, RAG or AI agents
  • companies that want to use AI without data leakage, chaos and audit risk
  • organizations preparing for the AI Act, ISO 42001, ISO 27001, NIS2, SOC 2 or cyber insurance

Key takeaways

  1. AI security starts before buying the tool. First define purpose, data, risks, owners and prohibited uses.
  2. The biggest generative AI risks are data leakage, prompt injection, wrong outputs, excessive permissions, lack of human oversight, shadow AI and uncontrolled integrations.
  3. A company should have an AI usage policy, AI tool register, data classification, access rules, logs, tool approval process and AI incident playbook.
  4. AI should not have more access than it needs. Be especially careful with integrations into email, files, CRM, ERP, code repositories, APIs and customer data.
  5. The best generative AI deployment does not block innovation. It safely gives employees clear rules, approved tools and controlled processes.

What does AI security before deployment mean?

AI security before deployment means preparing the company so that a generative tool can be used without uncontrolled risk to data, customers, employees, reputation, systems and business decisions.

This is not only about settings in an admin panel. It is about the full AI usage context:

  • who will use the tool
  • for which tasks
  • with which data
  • whether AI will be integrated with company systems
  • whether AI will only suggest or also execute actions
  • whether AI output will reach customers
  • who will approve the output
  • whether the company will have logs and evidence
  • what the company will do if AI discloses data, generates an error or is manipulated

Simply put: AI security combines governance, data protection, cybersecurity, access control, human oversight, testing, training and incident response.

Why does generative AI require a different approach than normal SaaS?

A generative tool does not only store or process data according to predictable rules. It can generate new content, summarize documents, interpret instructions, search a knowledge base, write code, respond to customers, perform tasks and integrate with other systems.

This creates new questions:

  • can employees paste customer data into AI?
  • can AI analyze confidential documents?
  • does the AI provider use data to train models?
  • can AI output contain false information?
  • can AI disclose data from another department?
  • can AI be manipulated through prompt injection?
  • can AI call an API or perform an action?
  • can the company reconstruct who used AI and with which data?

That is why generative AI should not be deployed only as another application. It should be treated as a new risk layer in business processes.

What must be secured before deploying generative tools?

1. AI use purpose

First, the company should define why it is deploying a generative tool. Without a clear purpose, AI quickly becomes a chaotic tool used for everything, without control and without metrics.

Define:

  • which problems AI should solve
  • which teams will use AI
  • which use cases are allowed
  • which use cases are prohibited
  • whether AI will be used internally or with customers
  • whether AI will support decisions or automate them
  • how deployment impact will be measured

Evidence to prepare: AI use case card with purpose, owner, data, risk and scope.

2. Input data

Input data is everything a user or system sends to AI: prompt, document, email, file, transcript, code, customer data, HR data, ticket, attachment or CRM record.

Before deployment, define which data may be entered into AI.

Especially sensitive data

  • personal data
  • customer data
  • financial data
  • HR and payroll data
  • contracts
  • trade secrets
  • source code
  • API keys, passwords and secrets
  • vulnerability information
  • medical or sector-specific data
  • NDA-covered data

Evidence to prepare: data classification and list of data prohibited in AI tools.

3. Output data

AI output should not automatically be considered true, safe and ready to use. AI may generate errors, invent sources, miss context, disclose data or create content that violates company policy.

Secure output through:

  • mandatory human review for external content
  • source checking
  • fact validation
  • confidential data checks in outputs
  • no automatic customer sending without approval
  • AI-generated content labeling where required
  • tone and communication policy checks

Evidence to prepare: AI output validation procedure before business use.

4. Identity and access

The AI tool should be integrated with company identity management where possible. The worst model is separate accounts, private logins, no MFA and no ability to remove access after employee departure.

Check:

  • whether the tool supports SSO
  • whether MFA is required
  • whether roles can be assigned
  • whether access can be limited by department
  • whether access is removed during offboarding
  • whether administrator accounts exist
  • whether service accounts exist
  • whether usage logs can be exported

Evidence to prepare: AI tool access report and administrator list.

5. Shadow AI

Shadow AI means using AI tools without the company’s approval, knowledge or control. It is one of the biggest risks because employees may paste confidential data into tools nobody assessed.

Reduce shadow AI through:

  • approved AI tool list
  • clear AI usage policy
  • safe alternative for employees
  • process for requesting new tools
  • practical training
  • usage monitoring where proportionate and legally appropriate
  • regular review of departmental tools

Evidence to prepare: register of approved and unapproved AI tools.

6. AI supplier

The AI supplier may process company data, provide the model, maintain infrastructure, store conversation history, use subprocessors or offer integrations with other systems. It must be assessed before deployment.

Check:

  • where data is processed
  • whether data is used to train models
  • how retention works
  • whether history can be disabled or storage limited
  • whether the supplier has security certifications
  • how the supplier handles incidents
  • whether logs can be exported
  • whether subprocessors are used
  • how data is deleted after contract termination
  • whether the contract covers confidentiality, personal data, audit and liability

Evidence to prepare: AI supplier assessment and risk acceptance decision.

7. Privacy and retention settings

Before launching the tool, check data storage, history, use of data for service improvement, export, deletion, logs and administrator access settings.

In practice, check:

  • whether use of company data for model training can be disabled
  • how long prompts and responses are stored
  • whether the user can export history
  • whether the administrator can delete data
  • whether retention can be configured
  • whether data is encrypted
  • whether data is processed outside the EEA where relevant
  • whether the tool provides usage auditability

Evidence to prepare: AI tool privacy and retention configuration card.

8. Prompt Injection

Prompt Injection is an attack where a malicious instruction hidden in a prompt, document, email, website, ticket, knowledge base or file manipulates AI behavior. This is especially important for tools that analyze external content.

Controls before deployment:

  • treat external content as untrusted
  • separate system instructions from user data
  • do not allow external content to change AI operating rules
  • validate input and output
  • require human approval for high-risk actions
  • test prompt injection scenarios
  • log suspicious manipulation attempts

Evidence to prepare: Prompt Injection test report and remediation action list.

9. RAG and company knowledge base

RAG allows AI to answer based on company documents. It is useful, but risky if the knowledge base contains outdated, confidential, poisoned or poorly labeled documents.

Secure RAG through:

  • source approval
  • document owners
  • confidentiality classification
  • separation of public, internal and confidential documents
  • control over who can add documents
  • knowledge base change monitoring
  • removal of outdated documents
  • RAG poisoning tests
  • source citation in answers

Evidence to prepare: AI knowledge base management procedure and RAG source register.

10. AI agents and automatic actions

An AI agent is riskier than a chatbot because it can perform actions: send email, change a CRM record, create a ticket, retrieve a file, call an API, run a script or update a document.

Before deploying AI agents, define:

  • which tools the agent can call
  • whether it has read-only or write access
  • whether it can act without a human
  • which actions require approval
  • what action limits exist
  • how emergency stop works
  • whether every action is logged
  • whether permissions are minimal

Evidence to prepare: AI agent permissions card and list of actions requiring human approval.

11. Integrations with company systems

The highest risk appears when AI is connected to email, CRM, ERP, code repositories, drives, messengers, HR systems, ticketing, APIs or databases.

Before integration, check:

  • which data AI can access
  • whether access is limited to the user’s role
  • whether AI can read data from other departments
  • whether AI can modify data
  • whether the integration uses a service account
  • whether tokens are stored securely
  • whether the integration can be disabled quickly
  • whether actions are logged

Evidence to prepare: AI integration, access scope and token register.

12. Code and secrets protection

Developers often use AI to write, analyze and improve code. This can accelerate work, but may also leak code, keys, secrets, vulnerabilities or architecture information.

Define rules:

  • whether source code may be pasted into AI
  • whether vulnerabilities may be analyzed in a public tool
  • whether production logs may be sent
  • how to detect secrets before sending data to AI
  • whether AI-generated code requires code review
  • whether AI-generated code passes SAST, SCA and tests
  • how AI use in development is documented

Evidence to prepare: safe AI use rules for developers.

13. Logs and monitoring

The company should know who uses AI, for what purpose, with which data and which actions were performed. Without logs, incident analysis, audit response and policy improvement are difficult.

Logs should include, where technically and legally possible:

  • user
  • time of use
  • use case
  • data type
  • called integrations
  • actions performed by agent
  • blocks and alerts
  • approval decisions
  • configuration version

It is not always useful or lawful to log full prompt content. Balance security, privacy and trade secrets.

Evidence to prepare: AI usage logging policy and available log report.

14. Human oversight

Generative AI should support employees, but it should not make high-risk decisions without control. The greater the impact on customers, employees, money, access or reputation, the stronger human oversight should be.

Human oversight should be required for:

  • sending responses to customers
  • publishing external content
  • HR decisions
  • legal analyses
  • financial recommendations
  • data changes in systems
  • access granting
  • API calls that modify data
  • customer communication automation

Evidence to prepare: list of AI decisions and actions requiring human approval.

15. AI usage policy

Employees need simple rules. An AI policy should not be a legal document nobody reads. It should clearly say what is allowed, what is prohibited, which data is forbidden and where to report doubts.

The policy should include:

  • approved AI tools
  • allowed use cases
  • prohibited use cases
  • confidential data rules
  • personal data rules
  • code usage rules
  • output verification rules
  • AI use in customer communication
  • new tool request process
  • incident reporting process

Evidence to prepare: AI usage policy and employee acknowledgment.

16. Employee training

Without training, the policy will not work. Employees must know which data they can enter, what is prohibited, how to verify outputs, how to recognize risky situations and when to report a problem.

Training should include:

  • safe use of generative tools
  • prohibited data
  • prompt injection
  • wrong outputs and hallucinations
  • source verification
  • customer data protection
  • safe AI use in code
  • incident reporting
  • examples for HR, finance, sales, IT, marketing and customer service

Evidence to prepare: training materials, participant list and knowledge test.

17. AI incident response

The company should have a plan for cases where AI discloses data, generates harmful content, is manipulated by prompt injection, performs a wrong action or the AI provider reports an incident.

An AI incident playbook should include:

  • who receives the report
  • how to block the tool or integration
  • how to preserve logs
  • how to determine data scope
  • how to assess customer and personal data impact
  • who contacts the AI provider
  • who decides on communication
  • who approves returning the tool to use

Evidence to prepare: AI incident response playbook and tabletop exercise report.

Minimum checklist before deploying a generative tool

Governance

  • does the tool have a business owner?
  • does the tool have a technical owner?
  • are use cases approved?
  • are prohibited uses defined?
  • has risk assessment been performed?
  • does the board understand risks and decisions?

Data

  • is it known which data will be used?
  • is data classified?
  • is confidential data prohibited or controlled?
  • do personal data have legal basis and limits?
  • is retention configured?
  • does the supplier avoid using company data for training without consent?

Access

  • does SSO work?
  • is MFA required?
  • are roles and administrators defined?
  • is access removed during offboarding?
  • do integrations have minimal permissions?
  • do service accounts have owners?

Technical security

  • has AI security assessment been performed?
  • has prompt injection been tested?
  • has RAG been secured?
  • do AI agents have action limits?
  • are logs available?
  • can the tool or integration be disabled quickly?

People and process

  • is there an AI usage policy?
  • were employees trained?
  • is there a process for requesting new AI tools?
  • is there a process for reporting AI incidents?
  • are AI outputs verified by humans?
  • is audit evidence available?

How to prepare AI deployment for different teams?

Board

The board should approve AI usage strategy, risk appetite, AI policy, budget, data scope and reporting rules. It does not need to decide on every tool, but it should approve the framework.

IT and security

IT and security should assess the supplier, access, integrations, logs, configuration, testing, monitoring, incident response and ability to disable the tool.

Legal, compliance and DPO

Legal, compliance and DPO should assess personal data, contracts, processing basis, data transfers, information duties, retention, supplier responsibility and AI Act requirements where applicable.

HR

HR should be especially careful with AI use in recruitment, employee assessment, personal data analysis, HR document creation and internal communication.

Finance

Finance should secure AI use in invoices, analysis, payments, forecasts, reports and supplier data. AI should not independently approve transfers or bank account changes.

Sales and customer service

These teams need clear rules on when AI can prepare a draft and when a human must approve the response. Customer data, confidentiality and alignment with offers are especially important.

Marketing

Marketing should check content rights, AI content labeling, brand consistency, information sources, deepfake risk and the risk of publishing false claims.

Development and product

Developers should have rules for using AI with code, tests, documentation, vulnerability analysis and repository work. AI-generated code should pass normal tests and reviews.

30, 60 and 90-day action plan

First 30 days

  • assign AI security programme owner
  • prepare register of AI tools used in the company
  • identify shadow AI
  • define allowed and prohibited data
  • prepare a short AI usage policy
  • assess the biggest risks to customer data and confidentiality
  • block use of AI tools with confidential data without approval
  • choose a low-risk pilot

Days 31 to 60

  • perform AI supplier assessment
  • configure SSO, MFA, roles and administrators
  • configure retention and privacy rules
  • prepare approval procedure for new AI tools
  • prepare RAG and integration rules
  • test prompt injection for the pilot
  • prepare employee training
  • define logs and monitoring

Days 61 to 90

  • launch approved AI tool for selected teams
  • deliver team-specific training
  • prepare AI incident playbook
  • run AI incident tabletop exercise
  • start recurring AI tool review
  • prepare AI risk dashboard for the board
  • close pilot gaps
  • prepare 12-month AI security roadmap

What documents and evidence should be prepared?

Governance documents

  • AI usage policy
  • AI tool register
  • AI use case cards
  • accountability matrix
  • new AI tool approval process
  • exception and risk acceptance register
  • board report

Data documents

  • data classification
  • list of data prohibited in AI
  • data impact assessment where needed
  • retention rules
  • data transfer assessment
  • customer data usage rules
  • source code usage rules

Technical evidence

  • AI configuration report
  • SSO and MFA report
  • administrator list
  • integration register
  • AI agent permission list
  • Prompt Injection test report
  • RAG security report
  • logs and monitoring report

Training evidence

  • training agenda
  • training materials
  • participant list
  • knowledge test results
  • AI policy acknowledgment
  • training effectiveness report

Incident response evidence

  • AI incident response playbook
  • emergency contact list
  • AI integration shutdown procedure
  • log preservation procedure
  • tabletop scenario
  • exercise report
  • remediation action list

Common company mistakes

Mistake 1: no AI policy

Employees use different tools because the company did not explain what is allowed, what is forbidden and which tool is approved.

Mistake 2: using confidential data in public tools

Pasting contracts, customer data, code, technical documentation or HR data without supplier assessment and privacy settings may create serious risk.

Mistake 3: treating AI output as fact

AI may generate answers that are convincing but wrong. Outputs used for decisions and external communication require verification.

Mistake 4: no access control

An AI tool without SSO, MFA, roles, offboarding and logs creates a risk similar to other SaaS applications, but with greater impact on data.

Mistake 5: overly broad integrations

AI connected to email, files, CRM and APIs without minimum permissions may disclose or modify data in ways that are hard to control.

Mistake 6: no Prompt Injection testing

The company deploys a chatbot, RAG or AI agent but does not check whether external content can manipulate system outputs or actions.

Mistake 7: no logs

After an incident, the company does not know who used AI, which data was entered, what was generated and whether the response reached a customer.

Mistake 8: no human in the process

Automation without human approval for high-risk actions may lead to wrong decisions, data leakage or customer harm.

Mistake 9: no supplier assessment

The company accepts tool terms without checking retention, model training, data location, subprocessors, incidents and data deletion options.

Mistake 10: no AI incident playbook

When AI discloses data or performs a wrong action, the company only then decides who blocks the tool, contacts the supplier and informs customers.

How to measure readiness for secure AI deployment?

Governance metrics

  • number of AI tools in the register
  • number of AI tools without owner
  • number of approved use cases
  • number of AI policy exceptions
  • number of tools after risk assessment

Data metrics

  • number of use cases with confidential data
  • number of use cases with personal data
  • number of AI data policy violations
  • number of approved RAG sources
  • number of documents without owner in the knowledge base

Technical metrics

  • number of AI tools with MFA
  • number of AI tools with SSO
  • number of AI integrations with company systems
  • number of AI agents with tool access
  • number of AI systems with usage logs

Security metrics

  • number of Prompt Injection tests performed
  • number of gaps found in AI tests
  • time to close gaps
  • number of blocked AI actions
  • number of alerts related to suspicious AI use

Training metrics

  • number of trained employees
  • number of trained teams
  • knowledge test result
  • number of shadow AI reports after training
  • number of questions submitted to the AI approval process

Business example

A services company wants to deploy generative AI for sales, customer service and marketing. Initially, the plan is simple: buy licenses and encourage employees to use the tool. After a short review, it turns out that teams want to paste customer inquiries, contracts, correspondence history, CRM data and offer drafts into AI.

The company pauses the fast rollout and prepares a controlled pilot. It creates an AI policy, prohibited data list, tool register, supplier assessment, SSO and MFA configuration, retention rules, user training and output validation process. AI may prepare draft responses, but a human must approve content before sending it to customers.

In the next stage, the company tests prompt injection, reviews RAG and decides that the knowledge base may contain only approved documents with owners. CRM integration initially works in read-only mode. The AI agent cannot independently change customer data or send messages.

The result: the company does not block AI. It deploys it faster and more safely because employees have clear rules, an approved tool, training, data controls and an incident response process.

How can ccyber.io help?

ccyber.io helps companies securely prepare for generative AI deployment. We do not start from tool selection. We start from data, processes, risks, access, integrations and accountability.

We can support your organization with:

  • AI security readiness assessment
  • AI tool register and shadow AI discovery
  • AI usage policy
  • data classification for AI
  • AI supplier assessment
  • AI risk assessment
  • Prompt Injection testing
  • RAG security review
  • AI agent integration and permission review
  • AI incident response playbook
  • AI security training for employees and board
  • AI risk dashboard for the board
  • 30, 60, 90-day and 12-month AI security roadmap

The best first step is a Generative AI Security Readiness Workshop. In a short workshop, the company can determine which AI tools are already used, which data is at risk, which use cases are safe to start with, what must be blocked, which settings must be configured and how to prepare for controlled deployment.

FAQ

Should a company block all generative tools?

Not always. It is better to provide approved tools, clear rules and training. A full ban may increase shadow AI if employees continue using tools privately.

Where should AI security start?

Start with an AI tool register, AI usage policy, data classification, supplier assessment, SSO, MFA, logs, training and a low-risk pilot.

Can employees paste customer data into AI?

Only if the company has assessed the tool, legal basis, contract, retention, privacy settings, risk and usage purpose. By default, customer data should be treated as high risk.

Can generative AI write customer responses?

It can prepare drafts, but external responses should be approved by a human, especially if they involve contracts, pricing, complaints, customer data, legal matters or security.

What is Prompt Injection?

It is an attack where a malicious instruction manipulates AI behavior. It may be entered directly by a user or hidden in a document, email, website, ticket or knowledge base.

Is RAG secure?

RAG can be secure if the company controls sources, document owners, data classification, access, freshness, source citations and tests against poisoned documents.

Can an AI agent perform actions in company systems?

Yes, but only with minimal permissions, logs, limits, human approval for high-risk actions and the ability to shut it down quickly.

Which documents matter most before deployment?

AI usage policy, AI tool register, risk assessment, supplier assessment, data classification, integration list, logging rules, training plan and AI incident playbook.

Summary

AI security for companies is not one setting in an admin panel. Before deploying generative tools, secure data, access, supplier, integrations, RAG, AI agents, prompt injection, logs, human oversight, policies, training and incident response.

The biggest risk appears when a company deploys AI quickly, without owners, data rules, supplier assessment and integration control. In that case, AI may become a channel for data leakage, wrong decisions and uncontrolled automation.

The best approach is a controlled pilot, clear policy, approved tools, training, minimal permissions, output validation and measurable evidence. This helps the company use generative AI faster without losing control over data and processes.

Sources

IEC 62443 in Practice: Zones, Conduits and OT Network Segmentation

IEC 62443 helps organize OT security by dividing the environment into zones and communication conduits. A zone groups assets with similar risk and security requirements, while a conduit describes controlled communication between zones. In practice, this is not only about VLANs and firewalls, but about understanding processes, dependencies, risk, remote access, data flows, accountability and secure IT/OT communication rules.

Prepared by: CCyber Editorial Team

Short answer

IEC 62443 in practice helps design OT security by dividing a plant, lines, systems and connections into zones and communication conduits. A zone is a group of assets with similar function, risk and security requirements, for example a production line, SCADA system, engineering workstations, process safety network or industrial DMZ. A conduit is a controlled communication path between zones, for example MES to SCADA, historian to DMZ, remote vendor to jump server or SCADA to PLC. OT network segmentation is not only about VLANs. It is a business and technical process: asset inventory, communication mapping, risk analysis, boundary definition, traffic limitation, monitoring, change management and testing.

Last updated

July 2026

Who this article is for

  • manufacturing boards
  • plant managers and operations directors
  • production, maintenance and quality managers
  • CISOs, vCISOs, CTOs, IT directors and OT security managers
  • automation engineers, OT engineers, integrators and SCADA, PLC, DCS, MES teams
  • manufacturing, energy, transport, water, chemical, food, pharmaceutical and automotive companies
  • critical infrastructure operators and organizations affected by NIS2 or KSC requirements
  • organizations preparing for IEC 62443, ISO 27001, cyber insurance or customer audits
  • companies that want to organize IT/OT segmentation and supplier remote access

Key takeaways

  1. IEC 62443 does not start with a firewall. It starts with understanding processes, assets, risk, communication and the consequences of failure in OT.
  2. A zone groups assets with similar security requirements, while a conduit describes controlled communication between zones.
  3. OT segmentation should limit incident impact, lateral movement, uncontrolled supplier access and accidental connections between IT and control systems.
  4. A VLAN is not full segmentation. Traffic rules, firewalls, allowlists, monitoring, logs, zone owners and change procedures are needed.
  5. A strong segmentation project ends with documents and evidence: zone map, conduit matrix, flow list, firewall rules, exceptions, tests and maintenance plan.

What is IEC 62443?

IEC 62443 is a series of standards for cybersecurity of industrial automation and control systems. In practice, it is used to organize security of OT, ICS, SCADA, PLC, DCS, HMI, MES, engineering workstations, historians, industrial networks and supplier remote access.

IEC 62443 is especially useful because it does not treat OT like a normal office network. It considers:

  • human safety
  • process continuity
  • line availability
  • control reliability
  • physical safety
  • legacy system limitations
  • suppliers and integrators
  • industrial system lifecycle
  • different roles: asset owner, integrator, service provider and component manufacturer

For this article, the key practical concepts are: zones, conduits, security levels, risk and segmentation.

What is a zone in IEC 62443?

A zone is a group of assets with similar function, risk and security requirements. A zone may be a physical part of the plant, a logical network area, a system group or a process function.

Examples of zones:

  • enterprise IT network
  • industrial DMZ
  • MES system
  • SCADA system
  • engineering workstations
  • packaging line
  • critical production line
  • PLC for a specific process
  • process safety network
  • historian system
  • supplier remote access
  • OT test laboratory

The key rule: zones are not defined only by IP addressing. A zone should follow risk, process function, criticality, ownership, trust level and incident impact.

What is a conduit in IEC 62443?

A conduit is a controlled communication path between zones. It describes which systems can communicate, using which protocol, in which direction, for what purpose, through which control point and under which conditions.

Examples of conduits:

  • ERP to MES
  • MES to SCADA
  • SCADA to PLC
  • historian to industrial DMZ
  • engineering workstation to PLC
  • remote supplier to jump server
  • update server to OT workstation
  • backup system to OT server
  • monitoring system to TAP or SPAN
  • quality system to production data

A conduit should have an owner and rules. Without that, the company does not know whether a given traffic flow is needed, safe and aligned with the process.

Zone, conduit and segmentation: simple distinction

Zone

Answers the question: which assets have similar security requirements and should be treated together?

Conduit

Answers the question: which communication between zones is needed and how do we control it?

Segmentation

Answers the question: how do we technically and organizationally separate zones and enforce communication rules?

Example: the SCADA network is a zone, SCADA to historian is a conduit, and segmentation is the firewall, allowlist, monitoring and rule that the historian cannot initiate traffic to PLCs.

Why is OT segmentation so important?

In OT, one uncontrolled access path can have greater consequences than in classic IT. An attacker may start from a normal office computer, move through an administrator account, reach an engineering workstation and then affect control, quality, availability or process safety.

Segmentation helps limit:

  • lateral movement from IT to OT
  • ransomware spread
  • uncontrolled supplier access
  • accidental scanning of OT networks
  • unauthorized connections to PLCs
  • office workstation access to control systems
  • infected service laptop risk
  • lack of visibility over data flows
  • uncontrolled cloud and IT integrations
  • outages caused by incorrect network changes

Segmentation does not guarantee complete security, but it strongly reduces the impact of errors, incidents or compromise of one account.

Why is a VLAN not enough?

A VLAN can be part of segmentation, but a VLAN alone is not enough. If there is no traffic control, monitoring, rules, owners and change process between VLANs, segmentation is only a logical network split, not a real security control.

A VLAN helps

  • separate traffic logically
  • reduce broadcast domain
  • organize addressing
  • simplify network management

A VLAN is not enough if

  • inter-VLAN traffic is open
  • there is no list of allowed connections
  • there is no firewall or boundary control
  • nobody knows who owns the zone
  • there are no logs
  • suppliers have standing access
  • engineering workstations can connect everywhere
  • changes are made without risk review

In practice, OT segmentation means combining architecture, traffic rules, access control, monitoring, procedures and accountability.

How to design zones and conduits step by step?

Step 1: inventory OT assets

You cannot design zones without knowing which assets exist. Inventory should include not only servers and computers, but also controllers, network devices, visualization systems, engineering workstations and remote access.

List:

  • PLC
  • DCS
  • SCADA
  • HMI
  • engineering workstations
  • historian servers
  • MES
  • WMS and warehouse systems
  • quality systems
  • network devices
  • firewalls
  • remote access points
  • service laptops
  • process safety systems
  • OT backup systems

Evidence to prepare: OT asset register with owner, location, function and criticality.

Step 2: understand the physical process

Segmentation cannot be designed only from the network perspective. You must know what happens in the physical process if communication is blocked, delayed or manipulated.

Ask:

  • which lines are critical?
  • which systems must operate in real time?
  • which data is needed for quality?
  • which connections are needed for safe shutdown?
  • which systems can operate offline?
  • which connections are convenient but not critical?
  • which systems affect human or environmental safety?

Evidence to prepare: map of processes, lines and operational dependencies.

Step 3: map communication flows

The most important segmentation document is the communication map. It shows who talks to whom, using which protocol, in which direction and for what purpose.

For every flow, record:

  • source system
  • destination system
  • protocol
  • port
  • direction
  • frequency
  • business or operational purpose
  • owner
  • criticality
  • whether the flow is required continuously, temporarily or only for service

Evidence to prepare: IT/OT communication flow matrix.

Step 4: group assets into zones

Group assets by function, risk and security requirements. Do not mix systems with completely different criticality in one zone only because they are in the same cabinet or subnet.

Zone design criteria

  • process function
  • production criticality
  • impact on human safety
  • asset type
  • availability requirements
  • trust level
  • patchability
  • system owner
  • supplier access need
  • impact of compromise

Evidence to prepare: zone list with justification and owners.

Step 5: define conduits between zones

After defining zones, specify which communication between them is allowed. The default rule should be: block everything that is not required and documented.

For each conduit, define:

  • which zones it connects
  • which traffic is allowed
  • which traffic is forbidden
  • who initiates the connection
  • whether traffic is one-way or two-way
  • whether authentication is required
  • whether time-bound approval is required
  • where traffic is logged
  • who owns the conduit

Evidence to prepare: conduit matrix between zones.

Step 6: assign security requirements

Zones should have security requirements based on risk. Not every zone needs the same level of protection. A process safety zone, engineering workstations and critical production controllers will usually need stronger controls than a reporting zone.

Requirements may include:

  • access control
  • authentication
  • account management
  • logging
  • monitoring
  • malware protection
  • configuration backup
  • change control
  • protocol restriction
  • remote access only through controlled path

Evidence to prepare: security requirements card for every zone.

Step 7: design technical segmentation

Only now is it time for technology. First process, assets, zones and conduits. Then firewalls, VLANs, routing, jump servers and monitoring.

Technical controls may include:

  • firewalls between zones
  • industrial DMZ
  • traffic allowlists
  • VLANs and subnets
  • ACLs on network devices
  • jump servers
  • VPN with MFA for suppliers
  • data diode or one-way communication where appropriate
  • passive IDS for OT
  • central logs
  • separation of test and production environments

Evidence to prepare: OT segmentation architecture design.

Step 8: test rules before deployment

In OT, a wrong firewall rule may stop a line or break communication with a critical system. Testing is mandatory.

The test should verify:

  • whether allowed traffic works
  • whether forbidden traffic is blocked
  • whether there is no delay affecting the process
  • whether alarm systems work
  • whether historian still collects data
  • whether the engineering workstation works only within allowed scope
  • whether supplier access works only through the approved path
  • whether logs are collected

Evidence to prepare: segmentation test report and exception list.

Step 9: implement change process

OT segmentation becomes outdated quickly if every outage, project or new line adds exceptions without control. Every conduit change should follow a process.

The process should include:

  • change request
  • business justification
  • risk assessment
  • zone owner
  • change validity period
  • test after change
  • documentation update
  • exception review

Evidence to prepare: change management procedure for OT zones and conduits.

Step 10: monitor and maintain segmentation

Segmentation is not a one-time project. Traffic must be monitored, rules reviewed, exceptions removed, maps updated and real traffic compared with documentation.

Minimum maintenance:

  • firewall rule review
  • conduit review
  • supplier access review
  • comparison of real traffic with communication matrix
  • new device monitoring
  • alerts for unusual communication
  • network map update
  • report for OT owners and the board

Evidence to prepare: recurring OT segmentation maintenance report.

Example zone model for a manufacturing plant

Zone 1: enterprise IT network

Includes email, office computers, user systems, internet, corporate applications and typical IT services. It should not have direct access to control systems.

Zone 2: industrial DMZ

A buffer between IT and OT. It can host data exchange systems, transfer servers, historian proxy, patch repository, jump server, monitoring and controlled integration points.

Zone 3: operations management

May include MES, production planning, reporting, quality systems and production integrations. This is often a boundary area between IT and OT.

Zone 4: supervisory control

Includes SCADA, HMI, OT application servers, internal historian and process supervision systems.

Zone 5: basic control

Includes PLCs, RTUs, controllers, industrial communication devices and systems directly involved in control.

Zone 6: safety and protection

Includes process safety systems, machine safety, SIS, ESD or other systems whose compromise may affect people, environment or installation. This zone requires especially careful separation.

Zone 7: vendor remote access

Includes controlled supplier access through MFA, VPN, jump server, session recording, time-bound approval and logging.

Zone 8: engineering and maintenance

Includes engineering workstations, PLC programming tools, SCADA configurations, project backups and maintenance environments. This is one of the riskiest zones because it enables changes in control systems.

Which conduits matter most?

ERP to MES conduit

Purpose: production plan, orders, materials, statuses.

Risk: ransomware or IT error may affect production planning.

Control: industrial DMZ, restricted protocols, data validation, no direct ERP connection to PLCs.

MES to SCADA conduit

Purpose: orders, production parameters, process status.

Risk: incorrect data may affect process or quality.

Control: flow allowlist, validation, logs, direction limitation.

SCADA to PLC conduit

Purpose: supervision, commands, status reading.

Risk: unauthorized commands or operating mode changes.

Control: zone separation, industrial protocol monitoring, limiting communication sources.

Historian to DMZ conduit

Purpose: transferring production data to reporting.

Risk: uncontrolled traffic from IT to OT.

Control: preferred direction from OT to DMZ, no initiation from IT to control systems, monitoring.

Supplier to service station conduit

Purpose: service, diagnostics, supplier support.

Risk: external access to OT environment.

Control: MFA, time-bound approval, jump server, session recording, no standing access.

Engineering workstation to PLC conduit

Purpose: programming, diagnostics, configuration changes.

Risk: program change, incorrect configuration, malware on workstation.

Control: dedicated workstation, change control, project backup, logging, access only for authorized people.

Which rules should apply at zone boundaries?

Default deny

Traffic between zones should be blocked unless it is explicitly allowed and justified.

Least communication privilege

Allow only the necessary source, destination, protocol, port and direction.

No owner, no traffic

Every conduit should have a business or technical owner.

Separate operational and service traffic

Remote access, updates, backup and engineering work should not mix with control traffic.

Limit IT to OT traffic

If data must pass between IT and OT, use DMZ, broker, intermediate server or another controlled mechanism.

Log boundary communication

Zone boundaries are natural monitoring points. Unusual traffic between zones should be visible.

Test every change

A rule change can stop a process. In OT, testing and maintenance windows are more important than fast emergency changes.

What documents and evidence should be prepared?

Architecture documents

  • IT/OT network map
  • zone list
  • conduit matrix
  • data flow diagram
  • zone boundary list
  • firewall and control point list
  • remote access list
  • IT/OT integration list

Risk documents

  • OT risk assessment
  • critical asset list
  • process impact analysis
  • incident scenarios
  • security requirements mapped to zones
  • exception and risk acceptance list

Technical evidence

  • firewall configurations
  • inter-zone rule list
  • zone boundary logs
  • segmentation test report
  • real traffic discovery report
  • supplier access report
  • network configuration backup report

Operational documents

  • firewall rule change procedure
  • supplier remote access procedure
  • IT/OT isolation procedure
  • emergency OT access procedure
  • zone owner list
  • emergency contact list

Common OT segmentation mistakes

Mistake 1: the project starts with VLANs

Addressing and VLANs matter, but they do not replace process, risk, zone and conduit analysis.

Mistake 2: one large production network

Many plants have one large OT network where SCADA, HMI, PLCs, engineering workstations and suppliers see too much. This increases incident impact.

Mistake 3: direct IT to OT connection

Direct connections from ERP, office laptops or reporting systems to OT create an easy attack path.

Mistake 4: no industrial DMZ

A DMZ is often the best place for controlled data exchange between IT and OT. Without it, integrations become random and hard to control.

Mistake 5: standing supplier access

A supplier should have access only when needed, through a controlled path and with logging.

Mistake 6: no communication matrix

If the company does not know which traffic is required, it cannot safely close unnecessary connections.

Mistake 7: no testing after changes

In OT, a rule change may have production impact. Every change must be tested and documented.

Mistake 8: no zone owners

If nobody owns a zone, nobody makes decisions about risk, changes and exceptions.

Mistake 9: segmentation without monitoring

Segmentation blocks some traffic, but monitoring shows whether someone is trying to cross zone boundaries and whether rules work.

Mistake 10: no documentation update

OT networks change with every project, modernization and service action. Documentation must live with the change process.

How to measure OT segmentation effectiveness?

Architecture metrics

  • number of defined zones
  • number of defined conduits
  • percentage of OT assets assigned to zones
  • number of conduits without owner
  • number of IT/OT connections without DMZ or control

Traffic metrics

  • number of allowed flows
  • number of detected undocumented flows
  • number of blocked communication attempts
  • number of high-risk protocols
  • number of expired temporary exceptions

Access metrics

  • number of active supplier accesses
  • number of accesses without MFA
  • number of standing remote accesses
  • number of engineering workstations with access to multiple zones
  • number of OT administrator accounts

Operational metrics

  • number of firewall rule changes per month
  • number of changes without full documentation
  • number of segmentation incidents
  • change approval time
  • date of latest IT/OT isolation test

30, 60 and 90-day action plan

First 30 days

  • assign owner for the zones and conduits project
  • identify critical systems and processes
  • prepare initial OT asset inventory
  • check existing IT/OT connections
  • check supplier remote access
  • collect existing network diagrams
  • identify the most important communication flows
  • define first high-risk zones

Days 31 to 60

  • prepare a more complete zone map
  • prepare conduit matrix
  • mark required, optional and suspicious flows
  • define zone boundaries
  • define security requirements for critical zones
  • prepare industrial DMZ design if missing
  • prepare supplier remote access rules
  • identify quick risk reduction actions

Days 61 to 90

  • implement first segmentation rules for high-risk zones
  • test rules with production and OT
  • enable monitoring at zone boundaries
  • prepare conduit change procedure
  • remove unused connections
  • reduce standing supplier access
  • prepare report for the board
  • plan full 12-month IEC 62443 roadmap

Business example

A manufacturing plant has one large OT network. SCADA, HMI, engineering workstations, historians, several production lines and supplier remote access operate in the same address space. IT connects to MES and reporting. Documentation is outdated and some system traffic has no owner.

During the first review, the company discovers that a supplier can connect to more than one line, an engineering workstation has access to many PLCs, the historian communicates directly with the office network and the reporting system queries OT sources without a DMZ.

The company does not start by replacing the whole network. First, it creates a map of assets, flows, zones and conduits. It separates the SCADA zone, engineering workstation zone, production line zones, industrial DMZ and supplier access zone. Then it defines conduits, limits traffic, introduces a jump server for suppliers, removes unused connections and logs boundary traffic.

After 90 days, the plant still has a lot of work, but the biggest risks are visible. Instead of one flat network, it has the beginning of a zones and conduits architecture, documentation, owners and a further segmentation plan.

How can ccyber.io help?

ccyber.io helps industrial companies translate IEC 62443 into a practical zones, conduits and OT segmentation project. We do not start from buying a firewall. We start from processes, assets, flows, risk and production dependencies.

We can support your organization with:

  • IEC 62443 gap analysis
  • OT risk assessment
  • OT asset inventory
  • zone and conduit mapping
  • IT/OT communication matrix
  • industrial DMZ design
  • supplier remote access review
  • OT network segmentation
  • IT/OT isolation procedure
  • monitoring at zone boundaries
  • plant ransomware tabletop
  • 30, 60, 90-day and 12-month OT security roadmap

The best first step is an IEC 62443 Zones and Conduits Workshop. In a short workshop, the company can determine which zones exist today, which conduits are critical, where the biggest risks are, which connections should be restricted and how to prepare a realistic segmentation roadmap without stopping production.

FAQ

What is a zone in IEC 62443?

A zone is a group of OT or IT/OT assets with similar function, risk and security requirements. It may include a line, SCADA system, engineering workstations, DMZ or process safety systems.

What is a conduit in IEC 62443?

A conduit is controlled communication between zones. It defines who can communicate with whom, using which protocol, in which direction, for what purpose and under which conditions.

Is a VLAN enough for OT segmentation?

No. A VLAN can be part of segmentation, but traffic rules, firewalls, owners, monitoring, documentation, testing and change process are also needed.

Where should a zones and conduits project start?

Start with OT asset inventory, process map, communication flows, supplier remote access and IT/OT connections.

Is an industrial DMZ always needed?

Not always in the same form, but in many plants it is a very good way to control data exchange between IT and OT without direct access to control systems.

Who should own a zone?

Ideally the process or system owner, such as production, maintenance, OT, quality or IT. Security supports, but the owner must understand process impact.

How often should communication conduits be reviewed?

At least annually and after every major change, modernization, new line, new supplier, incident or architecture change.

Does IEC 62443 require certification?

Not every project needs to end with certification. Many companies start with practical gap analysis, zones, conduits, risk management and roadmap, then decide whether formal assessment or certification is needed.

Summary

IEC 62443 helps organize OT security through a risk-based approach, zones and communication conduits. A zone answers which assets have similar security requirements. A conduit answers which communication between zones is needed and how it should be controlled.

In practice, OT segmentation is not only a network project. It is a joint project for production, OT, IT, security, maintenance, quality and suppliers. It must consider the physical process, availability, human safety, remote access, legacy systems, backup, monitoring and change management.

The best first step is not buying another firewall, but creating a map: assets, zones, conduits, flows, owners, risks and quick actions that reduce the biggest risk. Only then does technology support a real OT security architecture.

Sources

How to Prepare the Scope and Budget of a Cybersecurity Project for a Grant Application?

A strong cybersecurity project scope and budget for a grant application should be based on risk, gaps, business requirements, regulations and measurable outcomes. A list of tools or a generic “cybersecurity improvement” statement is not enough. You need work packages, actions, costs, schedule, suppliers, own contribution, eligibility, evidence and impact: lower risk, stronger resilience, safer product or audit readiness.

Prepared by: CCyber Editorial Team

Short answer

The scope and budget of a cybersecurity project for a funding application should be prepared so that the evaluator, board and finance team immediately see the project logic: problem, risk, actions, costs, outcomes and evidence. The most common mistake is adding a random list of tools, training and audits without showing why they are needed and what they will change. A strong project starts with an assessment, gap map, risk register and priorities. It is then divided into work packages such as MFA, backup, monitoring, incident response, secure SDLC, SBOM, training, documentation and testing. Every cost should have an owner, justification, result, timeline, pricing basis and acceptance evidence.

Last updated

July 2026

Who this article is for

  • business owners
  • boards
  • CFOs, COOs and budget owners
  • CISOs, vCISOs, CTOs and IT directors
  • compliance, risk, legal and internal audit teams
  • SMEs preparing a cybersecurity funding application
  • software houses and SaaS companies
  • software, hardware, IoT and digital product manufacturers
  • manufacturing plants and companies with OT environments
  • companies preparing for NIS2, KSC, CRA, ISO 27001, SOC 2, cyber insurance or customer audits

Key takeaways

  1. The project scope should come from risk and gaps, not from a list of tools someone wants to buy.
  2. The budget must be linked to work packages, outcomes, schedule and acceptance evidence.
  3. Every cost should have a business, technical and project justification: why it is needed, what it changes and how the effect will be measured.
  4. Before submitting the application, check cost eligibility, VAT, own contribution, expenditure period, supplier selection rules and required documents.
  5. The best cyber project scope is not “audit plus tools”, but a coherent capability-building programme: risk management, protection, detection, response, recovery, training and evidence.

What does cybersecurity project scope mean?

Project scope answers: what exactly the company will do, what the project does not include, which problems it solves, which results will be produced and who is responsible for them. In cybersecurity, scope should not be too general. “Improving company security” is not enough because it does not show which specific risk will be reduced.

A good scope should identify:

  • business problem
  • cyber risks
  • systems and processes in scope
  • actions to be performed
  • work packages
  • results
  • metrics
  • evidence
  • schedule
  • owners
  • costs
  • limitations and assumptions

Simply put: scope explains what will change in the company after the project. If, after completion, the company does not have a new capability, process, control, documentation, skill or evidence, the scope is too weak.

What does cybersecurity project budget mean?

The project budget is not only a sum of costs. It is a logical justification of how much it costs to achieve the project outcomes. The budget should show which costs are necessary, optional, potentially eligible, require own contribution and must be maintained after project completion.

A good budget should include:

  • work package
  • cost item
  • cost description
  • quantity
  • unit
  • unit net price
  • net value
  • VAT where applicable
  • gross value
  • cost eligibility
  • own contribution
  • pricing source
  • planned supplier or supplier type
  • planned expenditure date
  • acceptance evidence

The key rule: every budget item should answer “what will be created because of this cost?”.

The most common mistake: starting from budget instead of risk

Many companies start with: “how much funding can we get and what can we buy?”. This is the wrong approach. It leads to an artificial project that looks like a shopping list. A better process starts with risks and gaps.

Wrong order

  1. find a call
  2. check maximum amount
  3. add tools to the budget
  4. write justification at the end

Right order

  1. define company risks and needs
  2. perform gap analysis
  3. choose actions that actually reduce risk
  4. divide the project into work packages
  5. estimate costs
  6. check eligibility in the call
  7. align the project description with the programme objective
  8. prepare evidence and schedule

The grant should fund a sensible project. The project should not pretend to be sensible only because a call appeared.

How to prepare the project scope step by step?

Step 1: define the business problem

A cybersecurity project should begin with a business problem, not technology. The evaluation committee and board must understand why the project matters.

Example problems:

  • the company is not ready for enterprise customer requirements
  • a digital product needs CRA readiness
  • the company may be subject to NIS2 or KSC
  • there is no incident response process
  • ransomware may stop business operations
  • access control and MFA are missing
  • backup has not been tested
  • secure SDLC and vulnerability management are missing
  • customers require security evidence
  • the company wants cyber insurance but lacks required controls

Evidence to prepare: short business note: problem, impact, risk and urgency.

Step 2: define which requirements the project addresses

The project may follow from regulations, contracts, customer audits, cyber insurance, board strategy or a real incident. This should be named because requirements help justify scope.

Check whether the project concerns:

  • NIS2
  • KSC
  • Cyber Resilience Act
  • DORA
  • GDPR
  • ISO 27001
  • SOC 2
  • IEC 62443
  • cyber insurance
  • enterprise customer requirements
  • supplier or partner requirements

Evidence to prepare: map of requirements and business pressure sources.

Step 3: perform gap analysis

Gap analysis shows the difference between the current state and target state. Without it, the project may be too broad or random.

Gap analysis should identify:

  • missing controls
  • missing processes
  • missing documents
  • missing tools
  • missing skills
  • missing evidence
  • missing tests
  • high-priority risks
  • dependencies between actions

Evidence to prepare: gap table with priority, risk, action and cost.

Step 4: choose minimum scope and extended scope

Not every project can be funded in full. It is useful to prepare two scope levels: minimum and extended.

Minimum scope

These are actions that must be done regardless of the grant because they reduce the most urgent risk.

Examples:

  • MFA for critical accounts
  • backup recovery test
  • incident response plan
  • administrator review
  • board training
  • basic risk register
  • secure SDLC gap analysis

Extended scope

These actions build stronger capability and may be a good funded project scope.

Examples:

  • SAST, DAST and SCA tool implementation
  • full SBOM process
  • EDR or MDR implementation
  • SIEM or log centralization
  • PAM
  • full training programme
  • audit evidence automation
  • product security testing
  • tabletop exercises and recovery tests

Evidence to prepare: project variants: minimum, extension and actions outside the project.

Step 5: divide the project into work packages

Work packages organize scope and budget. They prevent the project from looking like a random cost list.

Example work packages

  • Package 1: diagnosis, risk and roadmap
  • Package 2: identity, access and baseline controls
  • Package 3: backup, recovery and business continuity
  • Package 4: incident response and exercises
  • Package 5: secure SDLC, SBOM and product security
  • Package 6: monitoring, logs and vulnerability management
  • Package 7: training and skills
  • Package 8: documentation, evidence and reporting

Evidence to prepare: work package structure with objectives, results and costs.

Step 6: describe the results of each package

Every package should end with a specific result. If a package has no result, its cost will be hard to justify.

Example results

  • gap analysis report
  • cyber risk register
  • MFA implemented
  • access review report
  • backup test report
  • incident response plan
  • tabletop exercise report
  • secure SDLC implemented
  • SBOM for key product
  • security test report
  • trained employees
  • audit evidence pack

Evidence to prepare: result list and acceptance method.

Step 7: define success metrics

The application should show how the company will measure impact. Metrics do not need to be complicated, but they must be concrete.

Example metrics:

  • percentage of accounts with MFA
  • number of systems covered by backup
  • date of latest recovery test
  • number of high-risk gaps closed after testing
  • number of products with SBOM
  • time to respond to vulnerability
  • number of trained employees
  • number of critical suppliers assessed
  • number of log sources in monitoring
  • time to prepare customer or audit report

Evidence to prepare: baseline and target indicator table.

How to prepare the budget step by step?

Step 1: split actions into cost items

Do not enter one “cybersecurity” item. Split the cost into concrete actions and results.

Example:

  • cybersecurity assessment
  • board workshops
  • MFA implementation
  • MFA or IAM licenses
  • backup test
  • incident response plan
  • tabletop exercise
  • penetration test
  • SCA tool
  • developer training
  • product technical documentation

Step 2: assign costs to work packages

Every cost should belong to the project structure. If a cost does not fit any package, it likely needs to be removed or the scope must be adjusted.

Example: an SCA tool should be in the secure SDLC and product security package, not in generic IT cost.

Step 3: choose cost category

Different programmes treat cost types differently. First divide costs into categories.

  • advisory services
  • implementation services
  • licenses and subscriptions
  • hardware
  • cloud infrastructure
  • testing and audits
  • training
  • staff costs
  • project management
  • documentation and reporting

Then check whether the category is eligible in the specific call.

Step 4: prepare pricing basis

The budget should be credible. Offers, market research, price lists, specifications or benchmarks are useful.

For each item, prepare:

  • scope description
  • number of days or hours for services
  • number of users, systems or products
  • license duration
  • implementation scope
  • pricing assumptions
  • pricing source
  • market research evidence if required

Step 5: separate one-time and recurring costs

In cybersecurity, many costs repeat after the project ends. They should be shown even when they are not funded.

One-time costs

  • assessment
  • implementation
  • penetration test
  • tabletop exercise
  • procedure preparation
  • initial tool configuration

Recurring costs

  • licenses
  • monitoring
  • MDR
  • vulnerability scanning
  • backup maintenance
  • recurring training
  • periodic tests
  • annual audit

Evidence to prepare: project budget and post-project maintenance budget.

Step 6: check VAT, own contribution and state aid

The application must be financially consistent. Before submission, check with accounting or a grant advisor how VAT should be treated, what own contribution is required, whether state aid or de minimis applies and which limits are relevant.

Check:

  • whether the budget should be net or gross
  • whether VAT may be eligible
  • co-financing level
  • required own contribution
  • whether the company can finance project cash flow
  • whether liquidity must be demonstrated
  • whether the cost fits programme limits

Step 7: prepare cost schedule

The budget must match the schedule. Some costs may be incurred only after eligibility starts, after signing the agreement or after supplier selection is completed.

The cost schedule should show:

  • when the work package starts
  • when the work package ends
  • when the supplier will be selected
  • when the result will be created
  • when acceptance will happen
  • when the invoice will be issued
  • when the cost will be reported

Step 8: plan acceptance evidence

Every cost should have evidence that it was incurred and the result was produced. This matters for reporting, audit and the board.

Example evidence:

  • assessment report
  • implementation acceptance protocol
  • configuration report
  • test report
  • training participant list
  • knowledge test results
  • tabletop exercise report
  • access review report
  • backup recovery test report
  • license activation confirmation

Project scope table template

The structure below helps organize the project before preparing the application.

Table fields

  • work package
  • package objective
  • action
  • risk or gap
  • requirement: NIS2, CRA, ISO, customer, cyber insurance
  • system or product in scope
  • business owner
  • technical owner
  • result
  • success metric
  • acceptance evidence
  • deadline
  • cost

Example entry

Work package: Incident response and business continuity.

Action: incident response plan preparation and ransomware tabletop exercise.

Risk: the company has not exercised ransomware response and does not know how quickly systems can be recovered.

Result: response plan, ransomware playbook, emergency contact list, exercise report and remediation action list.

Evidence: documents, participant list, exercise scenario, report and board decisions.

Budget table template

Budget table fields

  • item number
  • work package
  • cost name
  • cost description
  • cost category
  • quantity
  • unit
  • unit net price
  • net value
  • VAT
  • gross value
  • eligibility: yes, no, to be verified
  • co-financing level
  • own contribution
  • pricing source
  • planned date
  • acceptance evidence
  • notes

Example budget item

Cost name: Web application and API security test.

Description: test of SaaS application and API covering authentication, authorization, access control, application vulnerabilities and recommendation report.

Result: test report, vulnerability list, priorities, retest after fixes.

Acceptance evidence: test report, acceptance protocol, retest report.

Justification: action supports product security, B2B customer requirements, secure SDLC and readiness for CRA or audit.

How to describe a cost?

The cost description should be concrete. Avoid generic names that do not say what will actually be done.

Weak

“Cybersecurity services”.

Better

“Cybersecurity audit”.

Best

“Cybersecurity gap analysis covering Microsoft 365, backup, access control, incident response, suppliers and evidence documentation, ending with a gap report, priorities and 12-month action roadmap”.

Weak

“Scanner purchase”.

Better

“Purchase of a vulnerability scanning tool”.

Best

“Implementation of a vulnerability management process with a tool, scan configuration, ticketing integration, triage rules, board reporting and process effectiveness test”.

In the budget, you do not sell a tool. You show the capability the company will build through the project.

How to prepare the budget for different project types?

Baseline cybersecurity project for SMEs

Good scope:

  • assessment
  • MFA
  • Microsoft 365 or Google Workspace hardening
  • backup and recovery test
  • access review
  • phishing training
  • incident response plan
  • basic logs and alerts

Typical results:

  • gap report
  • MFA report
  • backup test report
  • account takeover playbook
  • trained employees
  • evidence pack for customer or insurer

CRA product security project

Good scope:

  • CRA scope analysis
  • product cybersecurity risk assessment
  • secure SDLC
  • threat modeling
  • SAST, DAST, SCA
  • SBOM
  • vulnerability handling
  • security update policy
  • technical documentation

Typical results:

  • product classification
  • security requirements register
  • SBOM
  • test report
  • vulnerability procedure
  • technical documentation pack

NIS2 and cyber resilience project

Good scope:

  • NIS2 applicability analysis
  • risk management
  • incident response
  • business continuity
  • supplier management
  • monitoring and logs
  • board training
  • compliance evidence

Typical results:

  • risk register
  • risk treatment plan
  • response plan
  • tabletop report
  • supplier register
  • board dashboard

OT and manufacturing project

Good scope:

  • OT risk assessment
  • OT asset inventory
  • IT/OT map
  • supplier remote access review
  • OT configuration backup
  • IT/OT isolation procedure
  • plant ransomware tabletop
  • minimum production capability plan

Typical results:

  • OT asset list
  • connection map
  • risk report
  • isolation procedure
  • recovery test report
  • production downtime plan

AI security project

Good scope:

  • AI tool register
  • AI risk assessment
  • AI usage policy
  • control of data used in AI
  • Prompt Injection testing
  • RAG testing
  • AI usage monitoring
  • AI incident playbook
  • AI security training

Typical results:

  • AI register
  • risk report
  • Prompt Injection test report
  • AI incident response procedure
  • trained users
  • AI risk dashboard

How to check cost eligibility?

Cost eligibility must be checked for the specific call. General knowledge that “a similar cost was funded before” is not enough.

Eligibility checklist

  • does the cost match the call objective?
  • is the cost listed as eligible?
  • is the cost not excluded?
  • is the cost necessary to achieve the result?
  • is the cost reasonable and market-based?
  • will the cost be incurred in the eligible period?
  • will the supplier be selected according to the rules?
  • does the cost have acceptance evidence?
  • is the cost not an ordinary operating cost?
  • is VAT eligible?
  • is the cost not funded from another source?

If the answer is unclear, mark the cost as “to be verified” and do not build the whole project around that item.

How to prepare the project schedule?

The schedule should be realistic. Cyber projects often require a sequence: diagnosis, design, tool selection, implementation, testing, training and evidence.

Example 12-month schedule

Months 1-2: diagnosis and design

  • gap analysis
  • risk register
  • technical scope
  • priority selection
  • procurement specifications

Months 3-5: baseline implementations

  • MFA
  • access review
  • backup
  • Microsoft 365 or Google Workspace hardening
  • basic logs

Months 6-8: advanced processes and tools

  • vulnerability management
  • EDR or monitoring
  • secure SDLC
  • SBOM
  • supplier management

Months 9-10: testing and validation

  • penetration tests
  • backup test
  • incident response test
  • fix retest

Months 11-12: training, documentation and acceptance

  • employee training
  • board training
  • tabletop exercise
  • evidence pack
  • final report

How to describe business impact?

Cybersecurity should not be described only in technical language. The application should show what the project gives the business.

Examples of business impact

  • reduced ransomware downtime risk
  • stronger readiness for B2B customer audits
  • shorter security questionnaire response time
  • higher trust from enterprise customers
  • safer digital product
  • better readiness for NIS2, KSC or CRA
  • stronger position in cyber insurance discussions
  • fewer high-risk accounts
  • faster incident detection
  • stronger recovery capability

A good description connects technology with risk and business outcome. Example: “backup implementation” is a technical action. “Tested ability to recover the sales system within a time acceptable to the business” is a business result.

Which documents should be prepared before submission?

Strategic documents

  • project business justification
  • problem description
  • risk map
  • gap analysis
  • action roadmap
  • board decision on priorities

Technical documents

  • systems in scope list
  • digital products in scope list
  • critical data list
  • critical supplier list
  • current security controls description
  • target state description
  • implementation scope

Budget documents

  • budget table
  • supplier offers
  • pricing sources
  • financial model if required
  • own contribution analysis
  • post-project maintenance budget
  • payment plan

Project documents

  • work package description
  • schedule
  • result list
  • indicator list
  • project team
  • project risk analysis
  • evidence collection plan

How to prepare the evidence collection plan?

Evidence must be planned before the project starts. If the company starts collecting it only during reporting, it will be too late.

Evidence for advisory services

  • final report
  • workshop list
  • agenda
  • participant list
  • presentations
  • acceptance protocol

Evidence for implementations

  • configuration report
  • settings screenshots where safe to store
  • go-live confirmation
  • covered system list
  • functionality test
  • acceptance protocol

Evidence for tools

  • contract or order
  • license
  • invoice
  • activation confirmation
  • usage report
  • description of which work package the tool supports

Evidence for training

  • agenda
  • materials
  • participant list
  • knowledge test
  • certificates
  • surveys
  • effectiveness report

Evidence for testing

  • test scope
  • methodology
  • results report
  • vulnerability list
  • priorities
  • retest
  • gap closure confirmation

How to prepare project risks?

The application should show that the company understands delivery risks. This increases project credibility.

Typical risks

  • supplier selection delay
  • lack of availability of key people
  • integration delay
  • project scope too broad
  • maintenance costs underestimated
  • call rules changed
  • some costs not eligible
  • difficulty obtaining offers
  • employee resistance to change
  • dependency on technology supplier

Good mitigation actions

  • minimum and extended scope variants
  • early market research
  • clear work package owners
  • reserved time for key people
  • schedule buffer where rules allow it
  • plan B for critical actions
  • evidence collection system from the beginning
  • regular board reviews

What should the board approve?

Before submission, the board should approve not only the amount, but also the project logic. Otherwise, after receiving funding, the company may struggle with delivery.

The board should approve

  • project objective
  • minimum scope
  • extended scope
  • budget
  • own contribution
  • post-project maintenance budget
  • risk priorities
  • work package owners
  • plan B without grant
  • status reporting rules

The most important board question is: which actions will we perform even if we do not receive funding?

Common scope and budget mistakes

Mistake 1: scope too generic

“Cybersecurity improvement” is not enough. Specific systems, processes, actions and results must be identified.

Mistake 2: budget as shopping list

Tools must be linked to process, users, implementation, training, metrics and evidence.

Mistake 3: no link between cost and result

If the result of a cost cannot be shown, the budget item is weak.

Mistake 4: no distinction between eligible and ineligible costs

Not every necessary cost can be funded. The budget should mark what needs verification.

Mistake 5: maintenance costs ignored

Licenses, monitoring, scanning, backup, testing and training must continue after the project. The board must understand those costs.

Mistake 6: no offers or pricing basis

A budget without pricing evidence looks less credible and may be hard to defend.

Mistake 7: schedule too ambitious

Cyber projects require decisions, access, integrations, testing and acceptance. The schedule must be realistic.

Mistake 8: no business owner

A cyber project cannot sit only with IT. If it affects product, manufacturing, sales, customers or board risk, business owners must be involved.

30, 60 and 90-day action plan

First 30 days

  • assign owner for scope and budget preparation
  • define the business problem
  • identify requirements: NIS2, CRA, customer, audit, cyber insurance
  • perform quick gap analysis
  • prepare risk and gap list
  • choose actions that actually reduce risk
  • divide the project into initial work packages
  • prepare the first high-level budget

Days 31 to 60

  • define results for every work package
  • prepare success metrics
  • collect offers and pricing basis
  • check cost eligibility in call rules
  • mark costs as eligible, ineligible or to be verified
  • prepare schedule
  • prepare evidence acceptance plan
  • prepare project version for the board

Days 61 to 90

  • finalize the full scope table
  • finalize the full budget table
  • approve own contribution
  • prepare post-project maintenance plan
  • prepare project risks and mitigation actions
  • prepare application documentation
  • define evidence collection system
  • define plan B for critical actions

Business example

A SaaS company wants to submit an application for cybersecurity funding. The first budget version has five items: vulnerability scanner, EDR, phishing training, penetration test and consulting. The project looks like a shopping list and it is hard to assess what exactly will change after delivery.

After scope cleanup, the company starts with risk. Enterprise customers require security evidence, the product will need CRA readiness, and the current development process has no SBOM, SCA or formal vulnerability management. The company also has no exercised incident response plan.

The new project scope has four packages: secure SDLC and SBOM, vulnerability management, incident response and customer evidence. The budget is linked to results: product SBOM, implemented SCA, API test report, vulnerability handling procedure, tabletop exercise, developer training and customer evidence pack.

The result: the project is no longer a tool purchase. It becomes a product security and B2B sales readiness programme. This scope is easier to justify to the board, customers and funding institution.

How can ccyber.io help?

ccyber.io helps companies prepare the scope and budget of cybersecurity projects for funding applications, board decisions or investor discussions. We combine risk, technology, regulation, product, finance and audit evidence perspectives.

We can support your organization with:

  • cybersecurity project scoping workshop
  • gap analysis for funded project
  • risk and gap map
  • division into work packages
  • cybersecurity project budget
  • cost and result descriptions
  • mapping costs to NIS2, CRA, ISO 27001, SOC 2 or customer requirements
  • secure SDLC, SBOM and vulnerability management scope
  • incident response and business continuity scope
  • audit and reporting evidence plan
  • workshop for board, CFO, IT and process owners

The best first step is a Cybersecurity Project Scope and Budget Workshop. In a short workshop, the company can define what should enter the project, what should stay outside, which costs are critical, which results must be shown and how to prepare a budget that is credible from both business and technical perspectives.

FAQ

Should the cybersecurity project scope start from tools?

No. First define risks, gaps and results. Tools should follow from the scope, not be the starting point.

How detailed should the budget be?

Detailed enough to assess cost reasonableness, eligibility, result and acceptance evidence. One item named “cybersecurity” is too general.

Should maintenance costs after the project be included?

Yes, even if they will not be funded. The board and funding institution should see that the company understands project sustainability and post-funding costs.

What is better: one large project or several smaller ones?

It depends on the call and company readiness. Often, one coherent programme with work packages works well, but some actions such as training may have a separate funding path.

Can an application be submitted without gap analysis?

Yes, but it increases the risk of weak scope and poor budgeting. Gap analysis helps show why the project is needed and which actions are priorities.

How should a cybersecurity tool purchase be justified?

Do not justify the purchase alone. Justify the process the tool enables: vulnerability detection, monitoring, access control, backup, incident response or audit evidence.

Which costs are most often forgotten?

Implementation, configuration, team training, integrations, testing, license maintenance, log retention, acceptance, documentation and remediation actions after tests.

Where should preparation start?

Start with a short assessment, risk list, minimum scope, work packages and high-level budget. Then check the specific call and cost eligibility.

Summary

A strong cybersecurity project scope and budget for a funding application must show the logic: problem, risk, gap, action, cost, result, metric and evidence. Without this, the project looks like a shopping list or compliance formality.

The best cyber projects are divided into work packages and build real company capability: better access control, more effective backup, faster incident response, safer product, secure development, vulnerability management, monitoring, training and audit evidence.

The key rule is: the budget should follow the scope, the scope should follow risk, and risk should follow the company’s real business. Then the project is easier to defend to the board, funding institution, auditor and customer.

Sources

We write about regulations such as NIS2, DORA, CRA and ISO 27001, cybersecurity for SMEs and critical infrastructure, as well as cyber hygiene, emerging threats and building security awareness within organisations.

Every article delivers practical knowledge - no jargon, just concrete steps you can act on to effectively protect your data, people and business continuity.