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Cyber Brief: U.S. Infrastructure Faces Evolving Threats And Federal Policy Uncertainty

This report does not constitute a rating action.

Sovereign-sponsored and politically motivated cyber attacks on critical infrastructure in the U.S. have become more frequent, resulting in a heightened risk of infrastructure failures that could cause significant economic disruptions and loss of life.  U.S. infrastructure providers' preparedness for such attacks, which are often sophisticated compared to more common cyber criminality, is inconsistent due to differing federal regulations and ownership. At the same time, the level of continued federal support for government cyber security institutions is uncertain.

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What's Happening

U.S. security agencies continue to warn of the risk to critical infrastructure from sovereign-sponsored cyber attacks. In 2024, the Cybersecurity and Infrastructure Security Agency (CISA) and the FBI reported that hackers from China, Iran, and Russia had successfully infiltrated energy, water, wastewater, and telecommunications systems. The federal government has responded with sanctions on perpetrators and support for domestic infrastructure owners. These threats come at a time of potential realignment of federal and state support for cyber security, including potentially reassessing staffing levels at CISA and the National Security Agency, and reducing funding to organizations including the Multi-State Information Sharing and Analysis Center (MS-ISAC).

Why It Matters

  • Critical infrastructure sustains life, safety, and economic activity. Damage to utilities, transportation, or healthcare networks can have widespread ramifications, as demonstrated by the estimated $7 billion to $10 billion of economic losses from the 2003 New York City blackout, caused by a transmission line fault.
  • Hybrid warfare, which combines the kinetic attacks of conventional war with cyber attacks, has become common practice in conflicts, often targeting critical infrastructure (see "Cyber Risk Insights: Sovereigns And Their Critical Infrastructure Are Prime Targets," April 29, 2025).
  • Digitalization and AI usage by critical service providers and within infrastructure control systems offer improved reliability and efficiency, but it also increases the potential for damage by a successful cyber attack.

What Comes Next

S&P Global Ratings' assessment of the credit quality of critical infrastructure owners includes consideration of the extent to which management maintains robust, frequently updated cyber security policies, and response and recovery plans. Some U.S. critical infrastructure, including most electric utilities, healthcare, and transportation companies, must adhere to Critical Infrastructure Protection (CIP) regulations. Yet cyber security weaknesses are likely to persist, notably among water utilities, where the operators' size (based on accounts served) often exempts them from regulation. Even where regulations apply, they may not be followed. A September 2024 study by the Environmental Protection Agency found that over 70% of water systems inspected in the prior year violated Safe Drinking Water Act risk and resilience and emergency response regulations (Section 1433). Small systems can also suffer greater financial damage from cyber attacks. For example, IBM, a technology and consulting group, estimates the average cost of a data breach in 2024 was $4.88 million, which could be equivalent to a year's revenues for a small water system.

CISA continues to highlight that successful attacks often take advantage of an organization's poor cyber hygiene  (weak password management, lack of Multi-Factor Authentication, poor patching, and inadequate vendor management). Our research suggests these vulnerabilities are most common in smaller utility systems outside CIP requirements, which are often resource constrained, have limited capacity to maintain investments in technology, and comparatively lower liquidity levels to withstand the financial damage resulting from a successful cyber attack. Cyber Brief: U.S. Infrastructure Faces Evolving Threats And Federal Policy Uncertainty spglobal.com/ratings May 20, 2025 3 S&P Global Ratings. All rights reserved. No reprint or dissemination without S&P Global Ratings permission. See terms of use/disclaimer on last page.

The possibility of diminished federal support for information sharing or cyber preparedness remains uncertain given potential changes at CISA, the NSA, and MS-ISACs.  In general, we view robust information sharing and federal support for cybersecurity as supportive of credit quality, particularly for organizations that operate critical infrastructure and therefore face greater risk of sophisticated attacks.

Related Research

Primary Credit Analysts:Tiffany Tribbitt, New York + 1 (212) 438 8218;
Tiffany.Tribbitt@spglobal.com
Geoffrey E Buswick, Boston + 1 (617) 530 8311;
geoffrey.buswick@spglobal.com
Secondary Contacts:Michelle Keferstein, Frankfurt (49) 69-33-999-104;
michelle.keferstein@spglobal.com
Raam Ratnam, CFA, CPA, London + 44 20 7176 7462;
raam.ratnam@spglobal.com
Patrick Bell, New York (1) 212-438-2082;
patrick.bell@spglobal.com
David N Bodek, New York + 1 (212) 438 7969;
david.bodek@spglobal.com
Trevor J D'Olier-Lees, New York + 1 (212) 438 7985;
trevor.dolier-lees@spglobal.com
Kurt E Forsgren, Boston + 1 (617) 530 8308;
kurt.forsgren@spglobal.com
Gabe Grosberg, New York + 1 (212) 438 6043;
gabe.grosberg@spglobal.com
Jenny Poree, San Francisco + 1 (415) 371 5044;
jenny.poree@spglobal.com
Aneesh Prabhu, CFA, FRM, New York + 1 (212) 438 1285;
aneesh.prabhu@spglobal.com
Nora G Wittstruck, New York + (212) 438-8589;
nora.wittstruck@spglobal.com
Research Contributor:Olyvia Gendron, New York 3322106263;
olyvia.gendron@spglobal.com
Writer:Paul Whitfield, Paris;
paul.whitfield@spglobal.com

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