Why the NIST Cybersecurity Framework Cannot Be Operationalized Without A Corresponding Management System®
Rick Lemieux – Co-Founder and Chief Product Officer of the DVMS Institute
Introduction
Despite its widespread endorsement as the “gold standard” for cybersecurity governance and risk management, the NIST Cybersecurity Framework (CSF) presents a fundamental challenge for organizations seeking to “implement” it as though it were a plug-and-play solution. As articulated throughout the DVMS Institute’s body of work—including A Practitioner’s Guide to Adapting the NIST Cybersecurity Framework—the notion of implementing the NIST-CSF is misguided and potentially counterproductive.
The NIST-CSF is not a framework in the conventional sense of prescriptive steps, nor is it designed to be implemented as a one-size-fits-all solution. It is, instead, a reference model—a conceptual guide meant to support strategic cybersecurity thinking and adaptable risk management, not a deployable system. This critical distinction is often misunderstood, and organizations that treat the CSF as an implementation blueprint risk wasting resources and missing the framework’s actual value.
The NIST-CSF Describes the What and Why and Not the How
As a framework, NIST-CSF outlines the high-level Functions (Govern, Identify, Protect, Detect, Respond, Recover) and associated categories and subcategories. Still, it does not prescribe how to apply these in the complex reality of enterprise environments.
The framework is intentionally abstract, offering no direct guidance on integrating cybersecurity responsibilities across business units, assessing organizational capabilities, or ensuring the alignment of security objectives with broader strategic goals. This leads to a critical misconception: that the CSF can be “implemented” in the same way as a technical control, process standard, or software solution. The framework is only a lens through which you analyze and improve existing capabilities.
Further complicating matters, the phrase “implementing the NIST-CSF” sets unrealistic expectations and implies a level of granularity and instruction that the framework does not support. Enterprises often treat the CSF as a standalone cybersecurity control checklist, divorced from business operations, governance structures, and strategy.
This siloed approach is not only ineffective but antithetical to the very spirit of the framework. The CSF assumes that organizations will adapt the guidance to fit their specific needs and environments—but it does not help them figure out how to do that. The CSF is a map, not a GPS. It points the way but does not show the path. Enterprises that attempt to “implement” it as if it were a set of instructions are destined to stumble.
As pointed out in the DVMS training, enterprises often treat the CSF as a standalone cybersecurity control checklist, divorced from business operations, governance structures, and strategy. This siloed approach is ineffective and antithetical to the framework’s very spirit.
The NIST-CSF Does Not Define Start or Endpoints.
Another critical issue is the lack of a defined starting point or endpoint. The NIST-CSF deliberately avoids prescribing maturity levels or sequential steps, adding flexibility and ambiguity. As a result, organizations frequently struggle with where to begin. Should they first assess their current posture? Should they jump into Protect controls? How do they know when they’re “done”?
Without a built-in implementation roadmap, enterprises are forced to interpret the framework in a vacuum, often leading to misalignment between cybersecurity efforts and the organization’s capabilities and goals. This is where most enterprises fail: they seek to implement a framework that was never designed to be implemented.
To bridge this gap, the DVMS Institute proposes the Digital Value Management System™ (DVMS) as a solution—not to replace the CSF, but to operationalize it.
Moreover, implementing the CSF also implies a finite project with a defined timeline and deliverables. This is incompatible with the nature of cybersecurity, which is dynamic, evolving, and context-specific.
Cyber threats change, technology changes, regulations change, and organizational priorities shift. Attempting to “implement” a static version of the CSF means freezing a moving target. Instead, the CSF must be continually adapted and revisited as part of a broader organizational capability to manage digital business risk.
That’s why the DVMS model emphasizes adaptability, continuous improvement, and the feedback loops of its CPD Model as essential to making the CSF useful.
Adding to the confusion is that many training and consulting organizations sell “CSF implementation services,” giving the impression that such a thing is possible and desirable. They perpetuate the myth that cybersecurity maturity can be bought or installed rather than built and nurtured over time. This commercial packaging of the CSF undermines its purpose. It also sets organizations up for disappointment when they realize that after six months of assessments, documentation, and control mapping, their cyber resilience has not materially improved because they have not addressed the underlying systemic and cultural issues.
The DVMS Institute explicitly rejects the notion that you “implement” the NIST-CSF. Instead, it advocates adapting it to your organization using a systems-based overlay incorporating business realities, cultural awareness, and strategy-risk integration.
Final Thoughts
The NIST Cybersecurity Framework is not something that can—or should—be “implemented” in the traditional sense. It is a conceptual reference model meant to inform, guide, and influence decision-making across an enterprise.
Without an operationalization overlay like DVMS, any attempt to implement the CSF will fall short, leading to fragmented controls, compliance-driven thinking, and limited business alignment.
Enterprises must instead focus on adapting the CSF using models that integrate people, processes, governance, and culture, making cybersecurity not a department but a discipline embedded into the organization’s DNA. The NIST-CSF is a compass, not a manual, and it is only through thoughtful adaptation that its true value can be realized.
By viewing cybersecurity through this systems-thinking lens, organizations are encouraged to treat it as a shared organizational responsibility, not a task delegated to IT or a security team.
The problem with attempting to “implement” the CSF is that it reinforces a technical-only view of cybersecurity. Protecting digital value requires cultural transformation, cross-functional collaboration, and continuous learning—all of which lie outside the scope of the NIST-CSF intended to address.
Without a capability-based model like DVMS, organizations risk applying CSF controls in isolation, thus undermining the very resilience they seek to build.
About the Author
Rick Lemieux
Co-Founder and Chief Product Officer of the DVMS Institute
DVMS Institute is a renowned provider of accredited (APMG International), Assured (NCSC-GCHQ-UK), and Recognized (DHS-CISA-NICCS-USA) NIST Cybersecurity Framework, Digital Value Management System® body of knowledge publications, certification trainings, assessment platforms and real-life desktop simulation trainings.
The Institute’s NIST Cybersecurity Framework Digital Value Management System® certified training programs teach businesses of any size, scale, or complexity the skills to build a Performance Driven Overlay System for Cyber Resilience capable of anticipating and mitigating the systemic risk digital businesses face today.
By embedding systemic risk management into strategic decision-making and aligning it with employee cultural values, organizations can build resilience—a dynamic capability to withstand digital business disruption and comply with any cybersecurity regulation (SEC, UK, DORA, NIS2, SAMA, SOCI, IMO, etc.) or maturity model mandates (HITRUST, CMMC, C2M2 etc.).
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