The U.S. Coast Guard’s enforcement of 33 CFR Part 101, Subpart F draws a clear line in the water for ports and terminals. Cybersecurity is no longer advisory or optional. It is now a regulated security requirement under the Maritime Transportation Security Act (MTSA).
For port authority CISOs, this fundamentally changes the conversation. Cyber risk is now treated the same way as physical security risk, and it is subject to inspection, documentation, and enforcement.
Why the Coast Guard Is Acting Now
Cyber incidents have already demonstrated their ability to disrupt port operations. From ransomware attacks impacting U.S. and international ports to nation-state activity targeting maritime and naval systems, the operational and economic consequences are well documented.
At the same time, ports have become deeply digitized. Terminal operating systems, cranes, gates, surveillance systems, access controls, power infrastructure, and industrial control systems are now interconnected and often remotely accessible. Many of these systems were never designed with cybersecurity in mind. Recent concerns over the use of federally banned Chinese-manufactured devices, which have been known to carry backdoored firmware, have only heightened awareness of all connected devices, including IT, IoT, and OT.
The Coast Guard has been explicit. Increased connectivity without corresponding security controls represents unacceptable risk to the Marine Transportation System and, by extension, national security.
Subpart F formalizes this reality by moving cybersecurity into the same enforceable framework as physical port security.
A Critical Requirement Ports Can No Longer Ignore:
Default Passwords
Under the Coast Guard’s 2025 maritime cybersecurity regulations, there is now an explicit and enforceable requirement that has immediate implications for port operations:
Default passwords must be changed on all IT, OT, and IoT systems before they are put into use.
This requirement took effect on July 16, 2025 and applies to every port facility, vessel, and offshore platform regulated under MTSA.
If changing a default password is technically infeasible, operators are required to implement equivalent compensating security controls. Doing nothing is no longer acceptable.
This requirement exists for a reason. Unchanged default credentials on networked and IoT equipment have been one of the most consistently exploited attack vectors in maritime and industrial cyber incidents. From cameras and access control panels to PLCs and terminal equipment, default credentials remain a common entry point for attackers.
For inspectors, this is a binary finding. Either default credentials are eliminated or adequately mitigated, or they are not.
What Ports Must Do in Practice to Satisfy Inspectors
For ports, compliance now hinges on a few non-negotiable capabilities.
1. Know Every Connected Device on the Port Network
Ports must be able to answer, immediately and defensibly:
What devices are connected across terminals, yards, gates, and facilities
Which devices are IT versus operational technology
Who owns them and why they are connected
Whether they are end-of-life, vulnerable, or unsupported
This includes devices often overlooked by IT teams, such as IP cameras, PLCs, access control panels, environmental sensors, and building automation controllers.
An incomplete inventory is an automatic compliance risk.
2. Reduce the Attack Surface at the Device Level
For port environments, segmentation alone is not enough. Inspectors increasingly expect device-level risk reduction, including:
Identifying and eliminating default and shared passwords on all connected devices
Identifying and addressing outdated or vulnerable firmware
Detecting and disabling banned or prohibited devices embedded in port infrastructure
Managing expired or self-signed certificates on surveillance and control systems
Disabling unnecessary services such as Telnet, FTP, or legacy protocols
Ports that rely solely on firewalls or passive monitoring will struggle to demonstrate adequate control under inspection.
3. Continuously Monitor for Drift and Unauthorized Changes
Ports are dynamic environments. Equipment is replaced, contractors connect devices, and configurations change.
Subpart F requires that cybersecurity controls persist over time, not just at audit checkpoints. This means:
Detecting when devices revert to default credentials
Identifying firmware changes or rollbacks
Monitoring for unauthorized devices appearing on the network
Maintaining audit trails for inspectors to review
How Phosphorus Helps Ports Comply
Phosphorus helps port operators move from regulatory intent to operational control.
Comprehensive IoT and OT Discovery for Port Environments
Phosphorus Intelligent Active Discovery safely identifies every connected device across port networks, including OT, IoT, and legacy systems. It delivers high-fidelity device identification, model-level accuracy, and deep metadata without disrupting operations.
Phosphorus also performs deep risk assessment across OT and IoT devices, including identifying default credentials (only Phosphorus has risk intelligence for millions of factory-default device credentials), vulnerability exposure, firmware risk, and identification of prohibited Chinese-manufactured devices under NDAA Section 889.
Ports gain an authoritative inventory suitable for Coast Guard inspection and risk assessment.
From Visibility to Action
Phosphorus does not stop at detection. The platform enables ports to:
- Automated Credential Hardening (Meets § 101.650(a)): The regulation explicitly requires changing default passwords and maintaining password strength. Phosphorus automates the discovery of default credentials and the rotation of passwords across millions of xIoT and OT devices, ensuring compliance without manual intervention.
- Accurate Asset Inventory (Meets § 101.650(b)): Compliance requires a documented inventory of network-connected systems. Phosphorus utilizes its patented Intelligent Active Discovery to create a high-fidelity, real-time inventory of all OT and IoT assets safely and precisely, including make, model, and firmware version, thereby satisfying the requirement for accurate documentation.
- Vulnerability Management & Patching (Meets § 101.650(e)): The rule mandates patching known exploited vulnerabilities (KEVs) without delay. Phosphorus identifies outdated firmware and vulnerabilities (CVEs), including KEVs on devices, and provides an automated platform to safely deploy firmware updates and patches at scale, which is critical for meeting the “routine system maintenance” requirement.
- Risk Assessment & Configuration Management (Meets § 101.650(e) & (b)): Phosphorus performs automated risk assessments to identify insecure configurations, risky device postures, as well as Chinese-manufactured devices that are prohibited under NDAA Section 889. It helps ensure devices are configured correctly (e.g., disabling risky services and disabling banned devices) as required by the device security measures.
- Device Lifecycle Management (Meets § 101.650(f)): For supply chain security, Phosphorus assesses the security posture of new devices before they are fully deployed, ensuring they meet the organization’s procurement and installation criteria. Additionally, Phosphorus continuously monitors devices for end-of-life status and configuration changes that can impact device security.
This directly supports these requirements for risk mitigation, documentation, and ongoing readiness.
Continuous Monitoring and Compliance Readiness
Phosphorus continuously monitors port environments for device changes, configuration drift, and emerging risk. This ensures cybersecurity programs remain inspectable, defensible, and operational, not static policy artifacts.
The Bottom Line for Port CISOs
The Coast Guard is no longer asking ports to consider cybersecurity. It is enforcing it.
Default passwords are no longer a technical debt issue. They are a regulatory violation.
Ports that treat these requirements as a paperwork exercise risk findings, operational disruption, and exposure to preventable incidents. Ports that operationalize cybersecurity as part of their security posture will be far better positioned to pass inspections and withstand real-world attacks.
Phosphorus helps port authorities move quickly and confidently, turning regulatory pressure into sustained operational resilience.
Learn more at https://phosphorus.io
