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BETTESWORTHConstruction

How to Manage Cyber Risk Across Major Infrastructure Projects

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Cybersecurity belongs in infrastructure project delivery from planning through commissioning and handover—not just in the IT department. Owners should define who is accountable, assess the systems and suppliers that could affect safety or service, and make proportionate requirements visible in procurement and delivery. Contractors and integrators should document the technology and services they introduce and follow the owner’s access and operational-safety rules. The exact obligations depend on the project, the entities involved, the sector, and the jurisdiction.

Why is cybersecurity a project-delivery issue?

A project can create cyber exposure before an asset begins operating. Design records, collaboration systems, software, connected equipment, contractor accounts, and integration work all affect what information is accessible and who can reach systems. Those risks are not interchangeable: a compromised project workspace may expose information or disrupt coordination, while a compromised operational technology (OT) system may affect a physical process.

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The distinction matters because project delivery decisions can shape the security and operability of the finished asset. Equipment and software are selected, configured, connected, and handed over by different organizations over time. If responsibilities are unclear at those transitions, an owner may inherit systems, dependencies, or access arrangements that were not fully understood during design and construction.

Cybersecurity is therefore a delivery-governance and operational-resilience concern, not simply a request for the IT team to install tools. The owner needs to establish the project boundary and accountability; contractors and integrators need to make their contributions and dependencies visible; and people responsible for operations need to review decisions that could affect safety, reliability, availability, or continuity of service.

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Not every construction project is critical infrastructure, and no single rule applies to every owner or contractor. CISA’s 2024 playbook addresses federal agencies and recipients of federal grants funding critical-infrastructure projects. NIST publications offer guidance rather than project-specific legal advice. Regulatory duties must be checked against the actual entity, sector, and jurisdiction.

What cyber risks arise during infrastructure project delivery?

The central risk is losing control of information, access, technology, or dependencies in a way that affects delivery or the future asset. The relevant exposure changes as the project moves from planning into procurement, integration, commissioning, and operations.

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  • Project information and collaboration: Project systems may hold design and delivery information and enable coordination among organizations. Owners should decide what information is in scope, who needs access, and who is responsible for managing that access. These information risks should not be confused with direct control of a physical process.
  • OT and industrial control systems: OT includes programmable systems and devices that monitor or cause changes in physical processes. A security change that might be routine in an office environment can have different consequences when it affects an operational process. Performance, reliability, availability, and safety constraints must inform control choices.
  • Products and services in the supply chain: Equipment, software, and services may introduce risks at different lifecycle stages. NIST’s supply-chain risk management guidance treats this as an organizational and system-lifecycle issue, not solely a procurement check.
  • Contractor and integrator involvement: Multiple parties may provide, configure, or integrate technology. Their responsibilities, dependencies, and access need to be visible to the owner and aligned with the rules for the systems involved. CISA and the FBI publish specific guidance for critical-infrastructure operators working with third-party ICS integrators.
  • Lifecycle handoffs: Security decisions made during design or installation can affect commissioning and later operation. The project should establish who retains responsibility for relevant systems and supplier relationships after construction work ends.

These are areas to assess, not a claim that every project has the same exposure or that every listed system is present. Start with the project’s actual design, connected systems, suppliers, access arrangements, and operational consequences.

Why does OT need a different security approach?

OT interacts with the physical environment, so security measures must be judged against operational requirements as well as information-security goals. NIST’s 2023 Guide to Operational Technology (OT) Security describes OT systems as programmable systems and devices that monitor or cause changes in physical processes, and emphasizes performance, reliability, and safety constraints.

That does not mean OT should be left unsecured. It means proposed controls or changes need the right engineering and operational review before they are selected or deployed. A project team should identify which systems sense, monitor, or control a physical process, understand which party owns the relevant decision, and consider the potential effect on safe and reliable operation. Do not assume that an IT control can be transferred directly to an OT environment without review.

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For connected IT and OT, the assessment should make the relationship between systems and responsibilities clear enough for the owner and delivery partners to evaluate the operational impact of decisions. The available data does not establish a universal technical design or a one-size-fits-all control set; the appropriate choices depend on the system and its operating constraints.

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How should owners set project cybersecurity responsibilities?

Owners should make cybersecurity part of project governance early, particularly when project technology could affect critical-infrastructure safety, reliability, or operability. CISA’s 2024 critical-infrastructure grant playbook calls for a project cyber risk assessment and a project cybersecurity plan within its stated scope.

  1. Set the scope. Identify the project systems, services, and technology relevant to delivery and future operations. Distinguish information systems, OT, and connected IT/OT where applicable. Record the boundaries and assumptions the assessment uses.
  2. Name accountable parties. Decide who owns the assessment and plan, who supplies information about products and services, who reviews OT-related decisions, and who is responsible for receiving the systems at handover. Make responsibilities clear across the owner, contractors, and integrators.
  3. Assess risk in project context. Consider the lifecycle stage, system type, supplier or integrator involvement, access and visibility, and the consequences for safety, reliability, availability, and service continuity. The assessment should inform decisions, not exist as a detached document.
  4. Translate decisions into delivery requirements. Where appropriate, reflect responsibilities and evidence expectations in procurement and project governance. Requirements should be proportionate to the systems and risks involved and understandable to the parties expected to meet them.
  5. Revisit the assessment at material transitions. Review relevant decisions as systems are selected, integrated, and prepared for commissioning. Changes to the design, connections, suppliers, or jurisdictional context can change what needs review.
  6. Plan for operational ownership. Before handover, clarify which party is responsible for the systems and supplier relationships going forward and ensure the relevant project decisions and dependencies are visible to that party.

CISA’s playbook is not a universal mandate for all construction work. For a project outside its federal-agency and federal-grant critical-infrastructure scope, its call for project-level assessment and planning can still inform governance, but it should not be represented as a legal requirement that applies automatically.

How should owners manage contractors, integrators, and suppliers?

Supplier risk should be treated as a lifecycle issue, not a one-time questionnaire completed at contract award. NIST’s 2022 supply-chain guidance, updated in 2024, describes a multilevel approach to identifying, assessing, and mitigating cybersecurity risks associated with acquired products and services. ENISA’s 2025 guidance recommends a supply-chain policy and supplier selection and contracting criteria that include cybersecurity practices and secure development procedures.

Owners can turn that guidance into a practical procurement and oversight approach:

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  • State the scope and expectations. Explain which systems, products, services, and supplier practices are relevant to the project and why. Use requirements that reflect the risk and can be understood and implemented by the supplier.
  • Ask for evidence relevant to the work. Specify what information the supplier should provide about the technology or services it introduces and its relevant cybersecurity practices. ENISA’s guidance supports including cybersecurity practices and secure development procedures in supplier selection and contracting criteria; the precise evidence requested should fit the project.
  • Make responsibilities visible. Document which party supplies, integrates, or supports the technology and who is accountable for the related project decisions. Contractors and integrators should disclose relevant dependencies and work within the owner’s access and OT safety rules. These are practical recommendations, not universal legal duties imposed on every contractor.
  • Review through the relationship. Reassess relevant supplier information at project transitions and when the design, services, or dependencies change. A selection-stage review alone may not reflect the system that is ultimately integrated and handed over.
  • Include the integrator in governance. For critical-infrastructure operators working with third-party ICS integrators, consult the CISA/FBI fact sheet directly for its detailed recommendations. The available source basis supports treating integrator access and responsibilities as governance concerns, but does not support reproducing a detailed control checklist here.

ENISA reported that 86% of surveyed organisations had implemented ICT/OT supply-chain cybersecurity policies. That figure is based on a 2022 study published in 2023. It describes surveyed organisations—not infrastructure projects—and is not proof that the policies were effective or a current universal adoption rate.

How should cybersecurity fit into each project stage?

Cybersecurity decisions should follow the project lifecycle because the systems and parties involved change over time. A stage-based review helps an owner find gaps before the next delivery handoff.

Project stage Questions to resolve
Planning and governance Could project technology affect infrastructure safety, reliability, or operability? What is in scope, who is accountable, and is a project cyber risk assessment and plan appropriate?
Design Which systems monitor or affect physical processes? What IT/OT connections, dependencies, and operating constraints should inform later procurement and integration decisions?
Procurement Do supplier selection and contract criteria address relevant cybersecurity practices and secure development procedures? What information or evidence is proportionate to the product or service?
Integration Which contractor or integrator is introducing or connecting each system? Are responsibilities, dependencies, access, and OT safety rules clear to the owner and delivery team?
Commissioning and handover Do the delivered systems and dependencies match the project’s assumptions? Is the operating party clear about ownership, relevant supplier relationships, and decisions that affect safe operation?
Operations and maintenance Have the project’s cyber assumptions, suppliers, systems, or jurisdictional obligations changed enough to require reassessment?

This is a governance aid, not a technical commissioning procedure. The assessment should remain tied to the actual project design and operational impact. The most useful review points are those where system scope, supplier involvement, access, or lifecycle responsibility changes.

What should contractors and integrators do?

Contractors and integrators should make the technology and services they introduce understandable to the owner and work within the project’s agreed rules. Their precise legal obligations depend on the contract, applicable regulation, and jurisdiction, so the following are implementation recommendations rather than universal statutory requirements.

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  • Document the systems, products, software, and services they introduce or integrate, at a level relevant to the project.
  • Disclose relevant dependencies and identify where their work relies on another supplier or integrator.
  • Clarify responsibilities with the owner, including who reviews decisions that could affect OT operation or safety.
  • Follow the owner’s access arrangements and OT safety rules for the systems in scope.
  • Raise material changes to the design, services, connections, or supplier involvement so the project can determine whether its assessment and plan need review.
  • Support a clear handoff by making relevant project decisions and dependencies available to the party taking operational responsibility.

These actions help owners evaluate the delivery chain without assuming that a contractor can independently determine the operational risk of an asset it does not own or operate.

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How do you determine which rules apply?

Start by identifying the entity responsible, the sector, the jurisdiction, and the specific activity or service in question. Do not infer that a project is covered simply because it is large, involves construction, or includes connected technology.

NIS2 includes supply-chain security and the security of acquisition, development, and maintenance among its cybersecurity risk-management measures. Whether a particular entity or project is covered depends on the entity, sector, and national implementation. A project team should therefore map potential obligations to the actual organizations and jurisdictions involved rather than treating a directive or guidance document as a blanket rule for every participant.

NIST’s OT and supply-chain publications are guidance, not project-specific legal advice. CISA’s grant playbook has a defined federal-agency and federal-grant context. Owners should use those sources to inform risk and governance decisions while separately confirming applicable legal and contractual requirements for their project.

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What is a useful owner’s checklist?

Before procurement, integration, and commissioning, an owner can use these questions to check whether cyber risk is connected to project decisions:

  • Have we identified the project technology that could affect safety, reliability, operability, or service continuity?
  • Have we distinguished systems that manage project information from OT systems that monitor or affect physical processes?
  • Is there a named owner for the project cyber risk assessment and plan where those are appropriate?
  • Can each contractor or integrator explain the technology, services, and relevant dependencies it introduces?
  • Do supplier selection and contract criteria address relevant cybersecurity practices, including secure development where applicable?
  • Are OT decisions reviewed with the operational and safety constraints in view rather than copied from an IT-only approach?
  • Will the operating party receive the information needed to understand relevant systems, suppliers, dependencies, and project decisions?
  • Have we checked legal applicability against the actual entity, sector, and jurisdiction rather than assuming universal coverage?

A “no” does not automatically mean a project is noncompliant or unsafe. It signals that the owner should clarify scope, responsibility, evidence, or the decision path before relying on an assumption.

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How can teams compare proposed security measures?

There is no source-backed basis here for ranking specific products or vendors. Compare measures by whether they fit the project and can be owned through the lifecycle.

  • Lifecycle coverage: Does the measure address the relevant design, procurement, integration, commissioning, operational, or maintenance stage?
  • System context: Is it intended for IT, OT, or connected IT/OT, and have the applicable operating constraints been considered?
  • Operational consequences: What could the measure change about safety, reliability, availability, or service continuity?
  • Third-party visibility: Does it account for supplier, contractor, or integrator responsibilities and access?
  • Ownership: Can the project team and eventual operator implement and maintain it, and is the responsible party clear?
  • Obligations: Does it help address requirements applicable to the actual entity and jurisdiction?

A measure that looks comprehensive on paper may not be useful if no one can maintain it after handover or if it has not been reviewed against OT safety and reliability requirements. Conversely, a focused measure may be a better fit when it addresses the project’s material risk and has a clear owner.

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Frequently Asked Questions

Does every infrastructure construction project need a cybersecurity plan?

No universal requirement for every construction project is established here. CISA’s playbook specifically addresses federal agencies and recipients of federal grants funding critical-infrastructure projects; other owners should determine the appropriate approach from their project scope, applicable rules, and operational risk.

Is cybersecurity the contractor’s responsibility or the owner’s?

A contract can allocate particular duties, but it does not remove the need for clear project-wide accountability. The owner should make sure that relevant supplier and integrator responsibilities connect to the decisions and operational ownership of the asset.

Does the ENISA 86% figure mean most infrastructure projects have supply-chain policies?

No. It refers to surveyed organisations in a study based on 2022 findings and published in 2023, not to infrastructure projects. It also does not establish whether those policies were effective.

Does NIS2 automatically apply to every contractor on a covered project?

The material here does not support that conclusion. Applicability depends on the entity, sector, and national implementation, so organizations should check their own status and obligations rather than infer coverage from a project relationship alone.

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