CIP-015 documentation: what utilities are missing in INSM programs

TL;DR: NERC CIP-015 compliance depends less on tooling than on documented policy, process and evidence, because auditors will judge what an entity can prove about feed selection, anomaly definition, evaluation and retention, according to Nozomi Networks research. The practical failure mode is sensor-first, paper-last implementation that leaves no defensible chain from detection to action.

Editorial analysis by NHI Mgmt Group, based on content published by Nozomi Networks: “NERC CIP-015 in Practice #9: Writing Your INSM Program”.

Key questions

Q: What breaks when INSM documentation is missing in a regulated utility environment?

A: The monitoring programme can still generate alerts, but it cannot reliably prove why a feed was selected, how anomalies are defined, who evaluated the event or what evidence was retained.

Q: When should utilities prioritise evidence quality over additional telemetry in CIP-015 programmes?

A: When the telemetry already exists but the programme cannot show a clear chain from feed selection to anomaly evaluation and retained records.

Q: What do security teams get wrong about anomaly detection in internal network security monitoring?

A: They often treat anomaly detection as the whole control, when it is only one step in a larger governed process.

Practitioner guidance

• Document the policy, process and evidence chain Write each INSM step so it states the decision, the owner, the trigger and the record it produces.
• Define a risk-based rationale for every monitored segment Record why each network segment is monitored now, later or not at all, using criteria such as consequence, attack-path relevance, observability gaps and implementation feasibility.
• Tie anomaly definitions to detection and retention State exactly what anomalous means, which feed or method detects it, and what retention trigger follows when activity crosses that threshold.

Bottom line: CIP-015 turns internal network security monitoring into a documentation problem as much as a detection problem.

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