Compliance  ›  NYDFS Part 500  ·  23 NYCRR 500

NYDFS Part 500 Makes You Certify Your Backups Every Year. Does the Certification Cover ServiceNow?

Section 500.16 requires backups of essential information, protected from alteration or destruction, with the ability to restore from them tested at least annually. Section 500.17(b) has your highest-ranking executive and CISO certify material compliance by April 15. Rezilient Restore gives covered entities a backup control for ServiceNow data that stands behind that signature.

§500.16(e) protected backups§500.16(d)(2) annual restore test§500.17(b) CEO and CISO certification

What Part 500 requires

Backup Is a Certified Control, Not an IT Setting

Part 500 applies to banks, insurers, money transmitters and every other entity licensed by the New York Department of Financial Services. Section 500.16 sets the backup and restore obligations; section 500.17 makes someone sign for them.

§500.16(a)(2)(v)

Back it up

Incident response plans must “include procedures for backing up or copying, with sufficient frequency, information essential to the operations of the covered entity and storing such information offsite”.

§500.16(d)(2)

Test it

Covered entities test their “ability to restore its critical data and information systems from backups” at least annually.

§500.16(e)

Protect it

“Each covered entity shall maintain backups necessary to restore material operations. The backups shall be adequately protected from unauthorized alterations or destruction.”

§500.17(b)(1)

Certify it

An annual written certification “that the covered entity materially complied with the requirements set forth in this Part during the prior calendar year”, signed by the highest-ranking executive and the CISO.

April 15Annual certification of material compliance is due each year.§500.17(b)(1)
72 hoursNotice to the superintendent after determining a cybersecurity incident has occurred, including at a third-party service provider.§500.17(a)(1)
14 daysServiceNow’s native backup window, engineered for platform disaster recovery.ServiceNow platform documentation

What regulators have enforced

Regulators have announced 11 public actions and settlements that cite NYDFS Part 500 against 10 organizations we have confirmed as ServiceNow customers, about $63 million in total (2021 to 2025). These are evidence of regulatory exposure, not a claim that ServiceNow data was involved.

Source: Rezilient review of public regulator records and reputable press, as of 31 October 2026. Each action is traced to its regulator or press source.

Why ServiceNow is in scope

ServiceNow Protects the Platform. You Answer for the Data.

For a covered entity, ServiceNow is usually where incidents are tracked, changes are approved, vendor risk is assessed and customer cases are worked. That is information essential to operations in the plain sense of §500.16(a)(2)(v), and the GRC records inside it are often the evidence that other Part 500 controls operated.

The regulation does not stop at your perimeter. §500.17(a)(1) requires notice of an incident that occurred at a third-party service provider, and the certification covers your program, not your vendors’. A backup managed by the platform, inside the platform, is hard to describe as protected from alteration by the platform’s own administrators.

ServiceNow does its part well. Its native backup is engineered for infrastructure disaster recovery: weekly fulls kept for 14 days, restored at the level of the whole instance. The annual restore test under §500.16(d)(2) is a different exercise: a full-instance rollback is not one most teams will run every year, and a 14-day window cannot reach a clean point before a 40-day intrusion.

How Rezilient Restore helps

Each Requirement, Mapped to a Capability

Rezilient Restore is compliance-grade backup and recovery built for ServiceNow. It runs inside the ServiceNow experience and keeps your data in immutable storage off the platform.

NYDFS requirement
Rezilient Restore capability
§500.16(a)(2)(v)

Back up essential information with sufficient frequency and store it offsite.

Continuous capture, stored off the platform. Every change to protected tables is captured and streamed to immutable storage outside the instance.

§500.16(d)(2)

Test the ability to restore critical data and systems from backups at least annually.

A restore test you can run every year. Record, field or table restore with minimal load, with the result exported as evidence.

§500.16(e)

Backups adequately protected from unauthorized alterations or destruction.

WORM-grade, outside single-admin control. No agent, script or insider can alter or delete the copy from inside ServiceNow.

§500.15(a)

Encryption meeting industry standards for nonpublic information in transit and at rest.

Encrypted in transit and at rest. AES-256 (NIST FIPS 197), with keys held only by you or ServiceNow.

§500.17(a)(1)

Notice within 72 hours of determining an incident occurred, including at a third-party service provider.

Pre-state and post-state for every record. Point-in-time history shows what changed and when, so the notice is built on facts.

§500.17(b)

Annual certification of material compliance signed by the highest-ranking executive and the CISO.

Evidence behind the signature. Signed chain-of-custody exports and a compliance evidence pack for the certification file.

Requirement text is summarized from the primary source; quoted language is verbatim. The cross-framework view, with every regime on one page, is in the white paper.

Four questions an examiner could ask

Put §500.16 Next to the 14-Day Window

Frequency

How often is ServiceNow data backed up, and who set that frequency? A platform default is hard to present as a decision about what is essential.

Restore test

When did you last restore ServiceNow data, and where is the evidence? §500.16(d)(2) asks for the test, not the capability.

Protection

Could an instance administrator, a script or an attacker with admin rights alter or destroy the backup? §500.16(e) says they must not be able to.

Certification

Did the risk assessment behind the April 15 certification examine whether the backup you rely on can restore what §500.16 requires?

How it works

From Connect To Compliance Evidence

Live in under one business day, starting in a non-production instance.

01

Connect

Rezilient is a ServiceNow-native app. Connect your instance, link storage, and go live in a day.

02

Capture

Every change recorded continuously across selected tables, including ITSM, CMDB, HRSD, CSM and GRC.

03

Restore

Surgical recovery at record, field or table level, without rolling back the instance.

04

Prove

Chain-of-custody exports. Audit-ready evidence on demand.

Questions

What Teams Ask Us About NYDFS

Does Rezilient Restore make us Part 500 compliant?

No product does that on its own. Part 500 covers your whole cybersecurity program, from risk assessment and access controls to incident response and training. Rezilient Restore supports the backup, restore testing, encryption and evidence requirements in §500.15, §500.16 and §500.17 for the data in ServiceNow.

Does “offsite” mean outside ServiceNow?

§500.16(a)(2)(v) asks for essential information to be stored offsite, and §500.16(e) asks for backups protected from unauthorized alteration or destruction. A copy held inside the same platform, under the same administrators, is hard to describe as either. Rezilient Restore keeps the copy in immutable storage off the platform.

Isn’t ServiceNow’s native backup enough?

It is the right tool for infrastructure disaster recovery, which is what it was built for. §500.16 also asks for a frequency you set, a restore you test annually, and protection from alteration or destruction. A 14-day, full-instance backup managed by the platform makes those hard to evidence.

Why does the 14-day window matter for ransomware?

Attackers often sit inside a network for weeks before anyone notices. If the dwell time is longer than the backup window, every copy inside the window was taken while the attacker was present. An independent copy with longer retention gives you a clean point to restore to.

Who holds the encryption keys?

You or ServiceNow, never Rezilient. By default the keys sit with ServiceNow; customers who license ServiceNow’s field encryption hold their own. Rezilient can never read your data.

Run a Real Restore Test in 30 Days

The Rezilient Restore trial runs in your non-production instance, with no commitment. You finish with a tested restore and the evidence to show for it.

Back Up Now. Restore Anytime. Always Rezilient.