Are You Prepared to Meet BEAD Cybersecurity Requirements?

By: Gregory Wald

Posted on: November 10, 2025

As BEAD funding accelerates broadband expansion across America, awardees face a critical requirement: meeting the stringent federal and state cybersecurity requirements prescribed by the funding stream. This isn’t just paperwork—it’s the key to unlocking transformative federal funding.

Compliance Requirements

Awardees are required to align their projects to fulfill these standards. The first step is understanding the many layers of compliance.

1. Cybersecurity Risk Management Plan

Awardees (subgrantees) must develop and implement a plan aligned with the National Institute of Standards and Technology (NIST) Cybersecurity Framework (CSF) and Executive Order 14028. This plan must include:

Regional threat landscape analysis
Risk assessment methodologies
Mitigation strategies for current and emerging threats
Incident response and recovery protocols

2. Cybersecurity Supply Chain Risk Management (C-SCRM) Plan

This plan must follow guidance from:

NIST Interagency or Internal Reports (NISTIR) 8276
NIST Special Publications (NISTSP) 800-161

It should include:

Assessment of external vendors and service providers
Vetting and monitoring protocols
Response procedures for supply chain threats

3. Operational Readiness

Both plans must be fully operational before funding is awarded. States must review and approve these plans, and the National Telecommunications and Information Administration (NTIA) may request them at any time.

Enforcement Mechanisms

State and federal agencies are positioned to provide oversight and enforcement services to BEAD projects in a variety of ways.

1. State-Level Oversight

States and territories (Eligible Entities) are responsible for:

Reviewing cybersecurity plans
Monitoring subgrantee performance
Conducting audits, site visits, and desk reviews

2. Compliance Clauses in Subgrant Agreements

Subgrant agreements often include:

Fund recovery clauses (to reclaim funds if requirements are not met)
Performance bonds or letters of credit (to ensure financial accountability)
“Make whole” or liquidated damages clauses (to remedy nonperformance)

3. Federal Oversight

NTIA retains the right to:

Review cybersecurity plans
Enforce compliance through funding conditions
Require corrective actions for deficiencies

Expertise to Help You Navigate Compliance

Cybersecurity compliance for BEAD-funded projects is a crucial step in an awardee’s success. CNE’s cyber experts are ready to help awardees navigate with Certified Virtual Chief Information Security Officer (CvCISO) services that can be integrated into your project at the level that makes sense for you.

Contact us today to talk about how your project can effectively navigate cybersecurity compliance.