Cybersecurity Insights for Credit Unions: NCUA’s 2025 Priorities

Cybersecurity isn’t just a technical issue — it’s a core part of credit union resilience. The National Credit Union Administration (NCUA) 2025 Supervisory Priorities highlight the need for credit unions to strengthen their cybersecurity posture. Compliance alone isn’t enough — credit unions must cultivate awareness at every level of the organization to keep up with cybercriminals’ constantly shifting tactics. This requires ongoing education, best practices, and a commitment to embedding security into daily operations.

Building this mindset takes more than regular training sessions. Cybersecurity must be a shared responsibility, where every employee plays a role in identifying and mitigating risks. By making security a priority, credit unions can meet regulatory expectations while protecting members' data and financial assets.

This article delves into the NCUA's 2025 priorities, spotlighting the cybersecurity measures credit unions must adopt to stay ahead of emerging threats.

1. Financial Resilience and Cybersecurity: A Symbiotic Relationship

The NCUA’s 2025 priorities address financial risks, including credit, liquidity, and market risks. As credit union balance sheets face pressure from rising delinquency rates and higher operating costs, securing digital operations becomes a cornerstone of overall financial health. The integrity of financial data, the availability of systems, and the protection of member information are fundamental to maintaining operational continuity and trust. A breach or data loss could magnify financial risks, making effective cybersecurity practices crucial for overall resilience.

Credit unions must balance financial oversight with robust cybersecurity measures. Securing digital systems and third-party services becomes essential when managing credit risk or liquidity concerns. A strong cybersecurity strategy safeguards member data and supports financial stability by preventing costly breaches, fraud, and reputational damage.

2. Developing Robust Information Security Programs

As the NCUA emphasizes the importance of sound financial management, the same level of diligence should be applied to a credit union’s cybersecurity program. Credit unions must implement and continually refine information security programs that preserve financial assets and sensitive member data. This includes comprehensive risk assessments, establishing and testing security controls, and developing an incident response plan to address potential cyber threats.

The NCUA’s focus on information security involves evaluating how credit unions maintain compliance with regulatory requirements and the effectiveness of their security measures. Credit unions must embed cybersecurity as a core aspect of their organizational culture, ensuring that boards and leadership provide oversight and governance.

Credit unions should follow these key steps:

• Conduct regular risk assessments to understand emerging threats.
• Ensure continuous training and education across all staff levels.
• Develop a board-driven cybersecurity oversight framework to ensure accountability.

3. Cybersecurity Compliance and Vendor Risk Management

The NCUA is committed to helping credit unions address third-party risks, a concern that intersects directly with cybersecurity. As credit unions increasingly rely on vendors for various operational needs, ensuring these third parties meet rigorous cybersecurity standards is paramount. Vendors often represent the weakest link in the security chain, and a cyber incident involving a third party could quickly escalate into a significant security breach.

Credit unions must extend their cybersecurity due diligence to third-party vendors, ensuring they comply with the same cybersecurity regulations and standards that the credit union follows. Whether it’s a software provider, managed service provider, or payment processor, credit unions must assess and monitor the cybersecurity practices of any external entity that handles sensitive member information or plays a critical role in operations.

Credit unions should take the following steps to strengthen vendor risk management:

• Perform cybersecurity assessments on all critical vendors before engagement.
• Ensure that vendors meet regulatory security standards and conduct regular audits.
• Include cybersecurity clauses in vendor contracts to ensure alignment of security expectations.

4. The Role of Incident Response in Cyber Resilience

While information security frameworks lay the groundwork for protecting sensitive data and assets, a well-defined incident response plan is essential for maintaining operational continuity and minimizing financial loss in the event of a cyberattack.

Cybersecurity resilience hinges on the ability to act swiftly and effectively. Credit unions must establish a clear structure for incident response, including predefined roles, communication protocols, and recovery steps. Regularly testing these plans ensures teams react quickly, minimizing operational downtime and reputational harm.

The following best practices can help guide credit unions in incident response:

• Define roles and responsibilities clearly in a cybersecurity response plan.
• Test the plan regularly with realistic, scenario-based exercises.
• Ensure that communication protocols are well-established, both internally and with regulators.

5. Reporting Cyber Incidents and Staying Compliant

Timely reporting of cyber incidents is another essential aspect of the NCUA’s cybersecurity focus. In line with regulatory requirements, credit unions are mandated to report any cyber incident they reasonably believe could have a material impact on operations within 72 hours. This rule applies not just to incidents involving internal systems but also to incidents affecting third-party vendors.

The 72-hour reporting window may seem tight, but it ensures rapid coordination with regulators and swift action in mitigating the incident’s impact. By adhering to these reporting requirements, credit unions can demonstrate compliance and receive timely assistance to address the incident.

To meet cyber incident reporting requirements effectively, credit unions should:

• Develop a streamlined process to quickly assess potential incidents and notify the NCUA within 72 hours.
• Maintain accurate logs and records to support incident investigation and resolution.
• Communicate with regulators and internal stakeholders to ensure timely remediation efforts.

6. Leveraging NCUA’s Cybersecurity Resources

The NCUA offers several valuable resources for credit unions to assess their cybersecurity maturity and stay aligned with regulatory requirements. One such resource is the Automated Cybersecurity Evaluation Toolbox (ACET), which allows credit unions to evaluate their cybersecurity posture and identify vulnerabilities. Additionally, the NCUA’s cybersecurity resources provide up-to-date guidance on regulatory compliance and best practices.

In 2025, leveraging these tools will be essential for credit unions to ensure that their cybersecurity programs are continuously improving.

To maximize the benefits of the NCUA’s cybersecurity resources, credit unions should:

• Regularly use ACET to identify gaps in cybersecurity measures.
• Keep up with the latest regulatory updates and cybersecurity guidelines available through the NCUA’s resources.
• Engage with examiners to understand how cybersecurity practices align with supervisory expectations.

As the NCUA communicated in its 2025 Supervisory Priorities, a focus on cybersecurity has never been more critical. Evolving threats require credit unions to manage financial risk proactively and safeguard member data and digital assets. Credit unions can navigate challenges with resilience and confidence by embedding cybersecurity into organizational culture, strengthening incident response capabilities, and leveraging available tools and resources.