The Atlantic Council released a detailed commentary on the White House’s new “Implementation Plan for the 2023 US National Cybersecurity Strategy.” Lots of interesting bits.

So far, at least three trends emerge:

First, the plan contains a (somewhat) more concrete list of actions than its parent strategy, with useful delineation of lead and supporting agencies, as well as timelines aplenty. By assigning each action a designated lead and timeline, and by including a new nominal section (6) focused entirely on assessing effectiveness and continued iteration, the ONCD suggests that this is not so much a standalone text as the framework for an annual, crucially iterative policy process. That many of the milestones are still hazy might be less important than the commitment. the administration has made to revisit this plan annually, allowing the ONCD team to leverage their unique combination of topical depth and budgetary review authority.

Second, there are clear wins. Open-source software (OSS) and support for energy-sector cybersecurity receive considerable focus, and there is a greater budgetary push on both technology modernization and cybersecurity research. But there are missed opportunities as well. Many of the strategy’s most difficult and revolutionary goals—­holding data stewards accountable through privacy legislation, finally implementing a working digital identity solution, patching gaps in regulatory frameworks for cloud risk, and implementing a regime for software cybersecurity liability—­have been pared down or omitted entirely. There is an unnerving absence of “incentive-shifting-focused” actions, one of the most significant overarching objectives from the initial strategy. This backpedaling may be the result of a new appreciation for a deadlocked Congress and the precarious present for the administrative state, but it falls short of the original strategy’s vision and risks making no progress against its most ambitious goals.

Third, many of the implementation plan’s goals have timelines stretching into 2025. The disruption of a transition, be it to a second term for the current administration or the first term of another, will be difficult to manage under the best of circumstances. This leaves still more of the boldest ideas in this plan in jeopardy and raises questions about how best to prioritize, or accelerate, among those listed here.