Electricity Distributor Engages Advisory Firm to Guide Board Reporting on Cyber Resilience Amid New Regulatory Change

The Challenge

Northern Grid Utilities, a mid-sized electricity distributor serving several Ontario communities, had a solid operational reputation. In early 2025, new cyber-resilience reporting requirements arrived under Canada’s evolving critical-infrastructure oversight regime. The rules required utilities to show operational preparedness and, critically, clear board-level governance of cyber risk.

Northern Grid’s technical controls were mature, but its board reporting framework lagged. Directors received incident summaries without a broader view of resilience, privacy impacts, or supply chain exposure. When regulators announced an upcoming compliance review, internal auditors found gaps between risk documentation and board records. Reports lacked traceability, decisions were not consistently recorded, and metrics did not align with the new language on resilience maturity.

Compounding the pressure, a subcontractor had recently suffered a breach involving customer meter data. The incident was contained, yet it exposed weaknesses in third-party oversight and accountability, both central to the new expectations. Internally, executives disagreed over ownership of cyber risk reporting. Should it sit with IT, operations, or enterprise risk? Silos deepened while deadlines approached. Local media questioned whether utilities could meet the transparency requirements, and staff felt the strain as the compliance team pulled together fragmented evidence.

By the time the regulator requested a preliminary briefing, Northern Grid could not demonstrate a consistent board-level understanding of cyber resilience. Several directors acknowledged limited visibility into operational risk and a reliance on high-level summaries rather than actionable metrics. The gap between technical management and executive accountability had become clear. Without standardized reporting, even strong controls could be judged inadequate.

As the review neared, the utility faced the risk of regulatory criticism, possible penalties for incomplete disclosure, and declining stakeholder confidence. The moment demanded a fundamental reset of reporting culture and the role of governance in protecting the grid within Canadian privacy and security expectations.

Our Solution

Service: Advisory and Executive Consulting, Board Cyber Resilience Reporting Uplift

We designed and implemented a regulator-ready reporting program aligned to PIPEDA, provincial energy directives, and national critical-infrastructure guidance.

1. Regulatory gap assessment: Mapped board packs, minutes, and risk registers to current resilience and privacy obligations, spanning IT, OT, ERM, and privacy functions.
2. Governance realignment: Implemented the three lines model with a formal RACI for cyber, privacy, and third-party risk. Updated board and committee charters to define oversight duties and briefing cadence.
3. Metrics and narrative: Built a scorecard with KRIs and KPIs, such as patch latency, incident severity trends, vendor tier coverage, tabletop outcomes, and privacy indicators, all linked to risk appetite.
4. Evidence and traceability: Standardized decision logs, action trackers, and version-controlled briefing packs to provide audit-ready records.
5. Third-party oversight: Introduced vendor tiering, refreshed due diligence requirements, and added contractual triggers for incident escalation and breach notification.
6. Board education and tabletop: Delivered a director education module and facilitated a cross-functional tabletop on service disruption, data exposure, and disclosure timelines.
7. Mock regulatory briefing: Rehearsed with regulator-style Q&A, captured corrective actions, and finalized the reporting cadence.

The Value

• Faster, clearer reporting: Assembly time for board materials decreased by about 40%, with standardized templates and version control.
  – Traceability and accountability: 100% of board decisions on cyber risk are now tied to owners, due dates, and closure evidence in the action log.
  – Third-party assurance: Tier-1 vendor evidence coverage improved from roughly 50% to over 90%, supported by current attestations and updated breach notification terms.
  – Director readiness: Post-education self-assessed confidence rose from 2/5 to 4/5, reflected in tabletop debrief performance.
  – Regulatory preparedness: Time to produce a regulator-ready briefing dropped from 10 business days to fewer than 48 hours, enabled by a standing evidence bundle aligned to Canadian requirements.

  Metrics were validated through artifact review and stakeholder surveys over the initial 12-week engagement.

Implementation Roadmap

Weeks 0–2: Discover and align
– Confirm scope and regulatory lens (PIPEDA, provincial directives, critical-infrastructure guidance).
– Inventory evidence and interview executives, committee chairs, and internal audit.
– Complete rapid gap assessment and approve the remediation plan.

Weeks 3–4: Governance and education
– Update board and committee charters and finalize the RACI.
– Deliver director education on cyber, privacy, and outage consequences.
– Approve reporting principles and link metrics to risk appetite.

Weeks 5–8: Metrics, artifacts, and third parties
– Build the scorecard with thresholds and trends.
– Implement decision logs, action trackers, and a board-pack template.
– Launch vendor tiering, refresh due diligence, and update contract clauses.

Week 9: Scenario validation
– Run a board-level tabletop on disruption, data exposure, and disclosure timing.
– Capture remediation actions and integrate them into the tracker.

Week 10: Mock regulatory briefing
– Conduct rehearsal with regulator-style Q&A and address residual gaps.
– Freeze version 1 of the reporting pack and evidence bundle.

Weeks 11–12: Operationalize and handover
– Set a quarterly board cadence and an annual external review.
– Confirm ownership for metrics and artifact maintenance.
– Handover playbooks, templates, and a 12-month improvement plan.