kevinferron.comKevin Ferron

SB · Zero trust · A checklist

If you run a small business

Nine plain steps, in order, from the accounts and devices you have to the backups you have tested, and the move to managed cloud services.

The first steps of the maturity model are mostly basics a small firm can do now.

Nine steps, in order, for a business owner and whoever looks after the computers, who may be an outside provider. Each is a plain action, with the CISA goal it comes from, CISA’s own ratings for that goal, and the stage of CISA’s maturity model it moves. Zero trust is not something you buy: in this site’s reading, the first stages of the maturity model are mostly these basics.

How CISA rates a goal

Each goal in CISA’s Cross-Sector Cybersecurity Performance Goals, version 2.0, has three ratings. CISA says these ratings apply mainly to IT infrastructure, not to operational technology or other non-IT systems. The ratings are CISA’s, one set per goal; they are not a quote for your business.

Cost
Low: Less than 5% of the organisation’s annual security budget.
Moderate: Between 5% and 15% of the annual security budget.
High: More than 15% of the annual security budget.
Impact
Low: Prevents limited harm: the organisation can still carry out its mission.
Moderate: Prevents serious harm: the organisation could not carry out some parts of its mission.
High: Prevents severe or catastrophic harm: the organisation could not carry out its mission.
Ease
Simple: Done within a few months with little technical expertise.
Moderate: Takes about 4 to 8 months and moderate technical expertise or management involvement.
Complex: Takes closer to a year or more and needs significant expertise, coordination and management involvement.

The nine steps

In order, the way the first ones help the later ones. Tick a step when it is done and your profile updates: the line below shows it as you go, and the full profile is beside the steps on a wide screen and after them on a phone. Your ticks stay in this browser; nothing is sent anywhere.

0 of 9 ticked · Identity: Traditional · Devices: Traditional · Applications and Workloads: Traditional · Data: Traditional · Visibility and Analytics: Traditional

  1. Write down every device, system and software account that touches company data, and who uses each one. Keep the list current as people and tools come and go.

    CPG 2.0 goal 2.A · Manage organizational assets (CISA, page 15)

    Cost
    Low
    Less than 5% of the organisation’s annual security budget.
    Impact
    High
    Prevents severe or catastrophic harm: the organisation could not carry out its mission.
    Ease
    Moderate
    Takes about 4 to 8 months and moderate technical expertise or management involvement.

    CISA says these ratings apply mainly to IT infrastructure, not to operational technology or other non-IT systems.

    Moves Devices · Asset & Supply Chain Risk Management: Traditional → Initial

    Matches CISA’s cell in part. CISA’s Initial cell also asks for supply chain risk to be managed through policies and baselines; a list of what you have is the first half.

    What CISA’s Initial cell says

    All physical assets and some virtual ones are tracked, and supply chain risk is managed through policies and control baselines drawn from federal recommendations. (Zero Trust Maturity Model, Table 3, page 17; paraphrased, and CISA’s wording says “agency”.)

    Sources for this step
    • CISA Cross-Sector Cybersecurity Performance Goals 2.0: Goal 2.A, page 15: Manage organizational assets
    • CISA Zero Trust Maturity Model: Table 3, page 17: Asset & Supply Chain Risk Management, Initial
  2. Turn on multi-factor sign-in for every account that offers it, starting with administrators and email. Where a service supports passkeys or hardware security keys, use those: they are the only widely available kind that a fake sign-in page cannot relay. Where it does not, use an authenticator app, ideally with number matching, and keep text-message codes as the last resort.

    Why passkeys and security keys: the phishing-resistant MFA tutorial →

    CPG 2.0 goal 3.F · Implement multifactor authentication (MFA) (CISA, page 20)

    Cost
    Moderate
    Between 5% and 15% of the annual security budget.
    Impact
    High
    Prevents severe or catastrophic harm: the organisation could not carry out its mission.
    Ease
    Moderate
    Takes about 4 to 8 months and moderate technical expertise or management involvement.

    CISA says these ratings apply mainly to IT infrastructure, not to operational technology or other non-IT systems.

    Moves Identity · Authentication: Traditional → Initial, and starts toward Advanced

    Matches CISA’s cell in part. CISA’s Traditional cell already allows MFA; its Initial cell adds checking more than one attribute (such as location or activity), and its Advanced cell is phishing-resistant MFA, which this step reaches only where a service supports it.

    What CISA’s Initial cell says

    Identity is checked with multi-factor authentication (a password may be one factor), and more than one attribute of the person or thing, such as where they are or what they are doing, is validated. (Zero Trust Maturity Model, Table 2, page 13; paraphrased, and CISA’s wording says “agency”.)

    Sources for this step
    • CISA Cross-Sector Cybersecurity Performance Goals 2.0: Goal 3.F, page 20: Implement multifactor authentication (MFA)
    • CISA, Cyber Guidance for Small Businesses: The IT lead’s tasks: mandate MFA with technical controls, administrators first; the CEO’s note that the only widely available phishing-resistant sign-in is FIDO
    • CISA, Implementing Phishing-Resistant MFA: Table 1, page 2: forms of MFA from strongest to weakest; app codes or push with number matching as the best option for small and medium businesses that cannot yet use phishing-resistant MFA; SMS only as a last resort
    • CISA Zero Trust Maturity Model: Table 2, page 13: Authentication, Initial
  3. Give anyone who administers systems a separate account for that work, and take administrator rights off everyday laptops, so that one bad download cannot install itself.

    CPG 2.0 goal 3.G · Administrators maintain separate user and privileged accounts (CISA, page 21)

    Cost
    Low
    Less than 5% of the organisation’s annual security budget.
    Impact
    High
    Prevents severe or catastrophic harm: the organisation could not carry out its mission.
    Ease
    Simple
    Done within a few months with little technical expertise.

    CISA says these ratings apply mainly to IT infrastructure, not to operational technology or other non-IT systems.

    Moves Identity · Access Management: Traditional → Initial

    Matches CISA’s cell in part. CISA’s Initial cell is access that expires and is reviewed automatically; taking everyday accounts off administrator rights is the first move away from permanent privileged access.

    What CISA’s Initial cell says

    Access, including privileged-access requests, that expires and is reviewed automatically. (Zero Trust Maturity Model, Table 2, page 14; paraphrased, and CISA’s wording says “agency”.)

    Sources for this step
    • CISA Cross-Sector Cybersecurity Performance Goals 2.0: Goal 3.G, page 21: Administrators maintain separate user and privileged accounts
    • CISA, Cyber Guidance for Small Businesses: The IT lead’s tasks: remove administrator privileges from user laptops
    • CISA Zero Trust Maturity Model: Table 2, page 14: Access Management, Initial
  4. Use one identity provider so people sign in once to the business apps, and keep a set routine for switching a person off everywhere when they leave.

    CPG 2.0 goal 3.D · Revoke credentials for departing staff (CISA, page 19)

    Cost
    Low
    Less than 5% of the organisation’s annual security budget.
    Impact
    High
    Prevents severe or catastrophic harm: the organisation could not carry out its mission.
    Ease
    Moderate
    Takes about 4 to 8 months and moderate technical expertise or management involvement.

    CISA’s goal 3.D is the leaving routine. Single sign-on comes from the maturity model’s cell, which names it.

    CISA says these ratings apply mainly to IT infrastructure, not to operational technology or other non-IT systems.

    Moves Identity · Identity Stores: Traditional → Initial

    Matches CISA’s cell in part. CISA’s Initial cell is a mix of stores with minimal integration, with single sign-on as its example; one provider for every business app is nearer its Advanced cell, which begins to consolidate stores.

    What CISA’s Initial cell says

    A mix of self-managed and hosted (cloud or other) identity stores with minimal integration between them; the cell gives single sign-on as its example. (Zero Trust Maturity Model, Table 2, page 14; paraphrased, and CISA’s wording says “agency”.)

    Sources for this step
    • CISA Cross-Sector Cybersecurity Performance Goals 2.0: Goal 3.D, page 19: Revoke credentials for departing staff
    • CISA Zero Trust Maturity Model: Table 2, page 14: Identity Stores, Initial
  5. Switch on automatic updates and disk encryption for every laptop and phone, keep them managed so you can see their state, and let only managed devices reach the sensitive apps.

    CPG 2.0 goal 2.B · Mitigate known vulnerabilities (CISA, page 15)

    Cost
    High
    More than 15% of the annual security budget.
    Impact
    High
    Prevents severe or catastrophic harm: the organisation could not carry out its mission.
    Ease
    Complex
    Takes closer to a year or more and needs significant expertise, coordination and management involvement.

    CPG 2.0 goal 3.R · Prohibit connection of unauthorized devices (CISA, page 26)

    Cost
    Moderate
    Between 5% and 15% of the annual security budget.
    Impact
    High
    Prevents severe or catastrophic harm: the organisation could not carry out its mission.
    Ease
    Complex
    Takes closer to a year or more and needs significant expertise, coordination and management involvement.

    CISA’s goal 3.R is about keeping unauthorised media and hardware, such as USB drives, off your systems. Letting only managed devices reach sensitive apps is this site’s reading, from the maturity model’s Resource Access row.

    CISA says these ratings apply mainly to IT infrastructure, not to operational technology or other non-IT systems.

    Moves Devices · Policy Enforcement & Compliance Monitoring: Traditional → Initial

    Matches CISA’s cell closely.

    What CISA’s Initial cell says

    Devices report their own characteristics, with limited enforcement; a basic process approves software and pushes updates and configuration changes to devices. (Zero Trust Maturity Model, Table 3, page 17; paraphrased, and CISA’s wording says “agency”.)

    Moves Devices · Resource Access: Traditional → Initial

    Matches CISA’s cell closely.

    What CISA’s Initial cell says

    Some devices are required to report their characteristics, and that information is used to approve access to resources. (Zero Trust Maturity Model, Table 3, page 17; paraphrased, and CISA’s wording says “agency”.)

    Sources for this step
    • CISA Cross-Sector Cybersecurity Performance Goals 2.0: Goal 2.B, page 15: Mitigate known vulnerabilities
    • CISA Cross-Sector Cybersecurity Performance Goals 2.0: Goal 3.R, page 26: Prohibit connection of unauthorized devices
    • CISA, Cyber Guidance for Small Businesses: The IT lead’s tasks: patch and prioritise the Known Exploited Vulnerabilities catalogue, turn on auto-update, enable disk encryption on laptops
    • CISA Zero Trust Maturity Model: Table 3, page 17: Policy Enforcement & Compliance Monitoring, Initial
    • CISA Zero Trust Maturity Model: Table 3, page 17: Resource Access, Initial
  6. Give each person only the access their job needs, and review who can reach what every quarter, taking away what is no longer needed.

    CPG 2.0 goal 3.H · Implement the principles of least privilege (CISA, page 21)

    Cost
    Low
    Less than 5% of the organisation’s annual security budget.
    Impact
    High
    Prevents severe or catastrophic harm: the organisation could not carry out its mission.
    Ease
    Simple
    Done within a few months with little technical expertise.

    CISA says these ratings apply mainly to IT infrastructure, not to operational technology or other non-IT systems.

    Moves Identity · Access Management: Traditional → Initial, and starts toward Advanced

    Matches CISA’s cell in part. Giving each person only what the job needs points at CISA’s Advanced cell (need-based access), but that cell is also session-based, and a quarterly review is not automated.

    What CISA’s Initial cell says

    Access, including privileged-access requests, that expires and is reviewed automatically. (Zero Trust Maturity Model, Table 2, page 14; paraphrased, and CISA’s wording says “agency”.)

    Sources for this step
    • CISA Cross-Sector Cybersecurity Performance Goals 2.0: Goal 3.H, page 21: Implement the principles of least privilege
    • CISA Zero Trust Maturity Model: Table 2, page 14: Access Management, Initial
  7. Keep the logs of sign-ins and administrator actions somewhere an attacker cannot edit them, and have a named person who looks at them.

    CPG 2.0 goal 3.Q · Maintain log collection and storage (CISA, page 26)

    Cost
    Moderate
    Between 5% and 15% of the annual security budget.
    Impact
    High
    Prevents severe or catastrophic harm: the organisation could not carry out its mission.
    Ease
    Moderate
    Takes about 4 to 8 months and moderate technical expertise or management involvement.

    CISA’s small-business page does not mention logs. This step comes from the performance goal alone.

    CISA says these ratings apply mainly to IT infrastructure, not to operational technology or other non-IT systems.

    Moves Visibility and Analytics (cross-cutting) · Visibility and Analytics: Traditional → Initial

    Matches CISA’s cell in part. CISA’s Initial cell asks for automated collection and analysis of logs and for regularly assessing gaps in visibility; keeping logs where they cannot be edited, and looking at them, is the start of that.

    What CISA’s Initial cell says

    Collection and analysis of logs and events begin to be automated for mission-critical functions, and the processes are regularly checked for gaps in visibility. (Zero Trust Maturity Model, Table 7, page 29; paraphrased, and CISA’s wording says “agency”.)

    Sources for this step
    • CISA Cross-Sector Cybersecurity Performance Goals 2.0: Goal 3.Q, page 26: Maintain log collection and storage
    • CISA Zero Trust Maturity Model: Table 7, page 29: Visibility and Analytics, Initial
  8. Back up what the business cannot run without, keep a copy offsite and offline, and practise restoring it, a part and then the whole, before you need to.

    CPG 2.0 goal 3.O · Maintain system backups and restoration ability (CISA, page 25)

    Cost
    High
    More than 15% of the annual security budget.
    Impact
    High
    Prevents severe or catastrophic harm: the organisation could not carry out its mission.
    Ease
    Moderate
    Takes about 4 to 8 months and moderate technical expertise or management involvement.

    CISA says these ratings apply mainly to IT infrastructure, not to operational technology or other non-IT systems.

    Moves Data · Data Availability: Traditional → Initial

    Matches CISA’s cell in part. CISA’s Initial cell is about off-site backups and some data served from redundant, highly available stores; testing a restore comes from CISA’s backup goal and its small-business page, not from the cell.

    What CISA’s Initial cell says

    Some data is served from redundant, highly available stores (cloud is the example), and off-site backups are kept for data held on the premises. (Zero Trust Maturity Model, Table 6, page 27; paraphrased, and CISA’s wording says “agency”.)

    Sources for this step
    • CISA Cross-Sector Cybersecurity Performance Goals 2.0: Goal 3.O, page 25: Maintain system backups and restoration ability
    • CISA, Cyber Guidance for Small Businesses: The IT lead’s tasks: perform backups and regularly test partial and full restores, and write a restoration plan
    • CISA Zero Trust Maturity Model: Table 6, page 27: Data Availability, Initial
  9. If you still run your own mail or file server in the office, move them to a managed cloud service. CISA treats this as a bigger change than the rest, for the highest security posture, because few small businesses can keep such servers patched and watched.

    No CPG 2.0 goal: this comes from CISA’s small-business page, under achieving the highest security posture, so there are no ratings to show.

    Moves Applications and Workloads · Accessible Applications: Traditional → Initial

    Matches CISA’s cell in part. CISA’s Initial cell is applications reachable over public networks by authorised users through brokered connections; moving mail and files to managed cloud services is this site’s reading of that.

    What CISA’s Initial cell says

    Some mission-critical applications are reachable over open public networks by authorised users with a need, through brokered connections. (Zero Trust Maturity Model, Table 5, page 24; paraphrased, and CISA’s wording says “agency”.)

    Sources for this step
    • CISA, Cyber Guidance for Small Businesses: Achieving the Highest Security Posture, on premises versus cloud: move mail and file storage hosted in your offices to managed cloud versions
    • CISA Zero Trust Maturity Model: Table 5, page 24: Accessible Applications, Initial

Who does what

CISA’s small-business page splits the work across three people. In a very small firm one person may wear two hats, and the IT lead may be an outside provider.

  • CEO

    Owns the culture; security is not left to IT alone.

    • Talk about security with the whole business, and put security goals in the quarterly goals.
    • Choose and back a security program manager, who need not be an IT expert.
    • Review and approve the incident response plan.
    • Take part in the tabletop exercises.
    • Take on the efforts that need every member of staff, such as announcing MFA yourself and following up with anyone who has not turned it on.

    CISA, Cyber Guidance for Small Businesses: Role of the CEO

  • Security program manager

    Drives the program and reports on it; does not need to be a security expert.

    • Train all staff in what is expected of them: MFA, updates, spotting phishing and how to escalate.
    • Write and maintain the incident response plan, with roles and an address book for when the network is down.
    • Host the tabletop exercises.
    • Check MFA compliance regularly, with the IT lead.
    • Report progress and roadblocks to the CEO at least monthly, more often at first.

    CISA, Cyber Guidance for Small Businesses: Role of the Security Program Manager (and, under the CEO’s tasks, the monthly report)

  • IT lead

    Makes the technical changes, and checks that they stuck. May be an outside provider.

    • Enforce MFA with technical controls, and hunt for gaps among new hires and people on new phones.
    • Turn on MFA for every administrator account.
    • Patch, starting with the vulnerabilities attackers are known to use, and switch on auto-update.
    • Back up, and regularly test partial and full restores.
    • Remove administrator rights from laptops, and turn on disk encryption.

    CISA, Cyber Guidance for Small Businesses: Role for the IT Lead

The cadence

At least monthly
The program manager reports progress and roadblocks to the CEO.
Every quarter
The program manager reviews the incident response plan, and hosts a tabletop exercise that the leaders join.
After any incident or near miss
The incident response plan is reviewed again. CISA says to invoke the plan even on a suspected false alarm.

CISA, Cyber Guidance for Small Businesses: The Security Program Manager’s tasks: review the incident response plan quarterly and after every incident or near miss; host quarterly tabletop exercises; report at least monthly

The ratings on each card are CISA’s, not this site’s, and there is one set per goal. Cost is a share of an organisation’s annual security budget, Impact is how serious the harm the goal prevents would be, and Ease is how much time and expertise the goal takes. CISA says they apply mainly to IT systems. They are not a quote for your business, and this page gives no prices: CISA gives none.

The profile is this site’s own device for seeing where the steps land. CISA’s Zero Trust Maturity Model puts each function of each pillar on one of four stages, Traditional, Initial, Advanced and Optimal, and says each pillar can progress at its own pace. Its tables give a stage for each function, not a score, so this page makes no score either. Each pillar shows the lowest stage among the functions these nine steps touch in it, so a pillar is never shown further along than its weakest part. That rule is this site’s choice. A step moves a function to the stage on its card, and several steps can touch one function; a pillar none of the steps touches shows nothing.

The maturity model is written for federal agencies, so its cells say “agency”; the cards paraphrase them for a business. Some steps match a cell closely and some only in part, and the card says which and what is missing. Treat the ticks as a way to see what a step is for, not as a rating of your security: CISA is plain that following its advice is no guarantee you will never have an incident.

What is left out is deliberate. There are no breach statistics, no small-business attack rates and no dollar figures here, because none had a primary source that could be opened. There are no product names either: the steps are described by category, so that nothing on this page is an endorsement.

Sources

  1. CISA Cross-Sector Cybersecurity Performance Goals 2.0 Cross-Sector Cybersecurity Performance Goals, Version 2.0 (CISA). Read: the Cost, Impact and Ease definitions (pages 10 and 11) and goals 2.A, 2.B, 3.D, 3.F, 3.G, 3.H, 3.O, 3.Q and 3.R with their ratings. CISA says the ratings apply mainly to IT, not OT. Dec 2025; read 2026-10-23, against the page layout (pages are the document’s printed numbers).

    • Pages 10 and 11: the Cost, Impact and Ease of Implementation definitions, and the note that they apply mainly to IT infrastructure
    • Goal 2.A, page 15: Manage organizational assets
    • Goal 3.F, page 20: Implement multifactor authentication (MFA)
    • Goal 3.G, page 21: Administrators maintain separate user and privileged accounts
    • Goal 3.D, page 19: Revoke credentials for departing staff
    • Goal 2.B, page 15: Mitigate known vulnerabilities
    • Goal 3.R, page 26: Prohibit connection of unauthorized devices
    • Goal 3.H, page 21: Implement the principles of least privilege
    • Goal 3.Q, page 26: Maintain log collection and storage
    • Goal 3.O, page 25: Maintain system backups and restoration ability
  2. CISA Zero Trust Maturity Model Zero Trust Maturity Model, Version 2.0. Apr 2023 (the cover date); read 2026-10-22; Tables 2, 3, 5, 6 and 7 read again 2026-10-23 for the small-business page.

    • Pages 7 to 9: each pillar can progress at its own pace; the four stages and their guiding criteria (page 9); a stage for each function in Tables 2 to 7
    • Tables 2, 3, 5, 6 and 7: the cells are written for agencies
    • Table 3, page 17: Asset & Supply Chain Risk Management, Initial
    • Table 2, page 13: Authentication, Initial
    • Table 2, page 14: Access Management, Initial
    • Table 2, page 14: Identity Stores, Initial
    • Table 3, page 17: Policy Enforcement & Compliance Monitoring, Initial
    • Table 3, page 17: Resource Access, Initial
    • Table 7, page 29: Visibility and Analytics, Initial
    • Table 6, page 27: Data Availability, Initial
    • Table 5, page 24: Accessible Applications, Initial
  3. CISA, Cyber Guidance for Small Businesses Cyber Guidance for Small Businesses (CISA). Read in full: the CEO, security program manager and IT lead actions, the quarterly review and tabletop exercise, the “highest security posture” section on on-premises services. It does not mention zero trust or logging. page updated Apr 2024; read 2026-10-23.

    • The introduction: the action plan lays the groundwork and is not a guarantee against an incident
    • The IT lead’s tasks: mandate MFA with technical controls, administrators first; the CEO’s note that the only widely available phishing-resistant sign-in is FIDO
    • The IT lead’s tasks: remove administrator privileges from user laptops
    • The IT lead’s tasks: patch and prioritise the Known Exploited Vulnerabilities catalogue, turn on auto-update, enable disk encryption on laptops
    • The IT lead’s tasks: perform backups and regularly test partial and full restores, and write a restoration plan
    • Achieving the Highest Security Posture, on premises versus cloud: move mail and file storage hosted in your offices to managed cloud versions
    • Role of the CEO
    • Role of the Security Program Manager (and, under the CEO’s tasks, the monthly report)
    • Role for the IT Lead
    • The Security Program Manager’s tasks: review the incident response plan quarterly and after every incident or near miss; host quarterly tabletop exercises; report at least monthly
  4. CISA, Implementing Phishing-Resistant MFA Implementing Phishing-Resistant MFA (fact sheet). Oct 2022; read 2026-10-22; read again 2026-10-23.

    • Table 1, page 2: forms of MFA from strongest to weakest; app codes or push with number matching as the best option for small and medium businesses that cannot yet use phishing-resistant MFA; SMS only as a last resort

Everything here is paraphrased from the sources, not quoted at length, and every claim is attributed to one. The NSA’s own zero trust sheets could not be opened, so they are not cited; the CISA alert about them is. Anything illustrative is labelled as such. Where a source is silent or could not be read, the page leaves the fact out.

If you’d rather not do this alone

Most of these steps need someone who knows your systems. I help small businesses with the same list: taking stock of devices and accounts, setting up sign-in protections and single sign-on, managing laptops and phones, backups with restore tests, and the quarterly routine.

Tell me what you have, and I’ll tell you which of these steps I’d start with.

Tell me what you have →