Survival of the Fittest: Using CISA and CISM to Navigate Malaysia’s Cyber Security Act 2024

Survival of the Fittest: Using CISA and CISM to Navigate Malaysia’s Cyber Security Act 2024

Categories: Cyber Security|Published On: December 1, 2025|4.3 min read|
About the Author

Kevin Boey

Kevin is the Head of Marketing & IT for Trainocate with over 20 years of working experience with Malaysia's largest EdTech provider specializing in Information Technology & Human Development Competency solutions.
Survival of the Fittest: Using CISA and CISM to Navigate Malaysia’s Cyber Security Act 2024

Executive Summary

The “grace period” for Malaysian organizations is over. With the full enforcement of the Cyber Security Act 2024 (Act 854), compliance is no longer a voluntary exercise in best practices—it is a statutory obligation. The Act specifically targets National Critical Information Infrastructure (NCII) entities, holding them legally accountable for the resilience of their digital assets.

In this high-stakes environment, the role of certified professionals has shifted from operational support to regulatory necessity. Regulators like the National Cyber Security Agency (NACSA) and the Securities Commission (SC) are demanding verified competency.

For a complete roadmap of the 2026 certification landscape, refer to: ISACA Certifications in 2026: The Definitive Guide to Digital Trust and Compliance in Malaysia.

While our previous article, How the CCOA Certification Bridges the Skills Gap in Malaysian SOCs focused on the tactical needs of Security Operations Center, this guide addresses the strategic imperatives for compliance officers, risk managers, and security leaders.

What Defines the “Era of Statutory Liability” in 2026?

The Cyber Security Act 2024 has fundamentally altered the risk equation for Malaysian businesses. It moves cybersecurity out of the IT department and into the boardroom.

Who is affected?

The Act applies to organizations designated as NCII Entities. These are sectors where a cyber disruption would devastate the nation’s economy or security, including:

Banking & Finance

Government

Energy

Healthcare

Transportation

Information, Communication, and Digital

What are the penalties?

Non-compliance is costly. Penalties for failing to conduct risk assessments or audits can reach
RM 500,000, imprisonment for up to 10 years, or both. Furthermore, the Act empowers NACSA to appoint “Sector Leads” who can issue specific directives that carry the force of law.

CISA: Certified Information Systems Auditor

Why Is CISA the “Auditor’s Shield” Against Liability?

Under the Act, NCII entities must conduct regular cyber security risk assessments and audits. Specifically, Section 22 mandates a risk assessment annually and an audit at least once every two years (or more frequently if directed).

How does CISA ensure legal defensibility?

The Certified Information Systems Auditor (CISA) credential is the global standard for validating that an audit was conducted with due professional care.

  • Domain 1 (Information Systems Auditing Process): Ensures that the audit methodology aligns with the strict reporting standards required by NACSA. An audit report signed off by a CISA holder carries significantly more weight with regulators than one from an uncertified practitioner.
  • Domain 4 (Information Systems Operations and Business Resilience): The Act requires organizations to prove they can recover from an attack. CISA auditors are trained to stress-test these Business Continuity Plans (BCP) to ensure they are not just paper tigers.

The “Third-Party” Risk Factor

The Securities Commission’s Guidelines on Technology Risk Management (GTRM) places heavy emphasis on managing third-party service providers. With “Digital Provenance” becoming a key 2026 trend4, CISA holders are essential for auditing the software supply chain to ensure vendors are not introducing hidden vulnerabilities.

CISM: Certified Information Security Manager

Why Is CISM Essential for the “Designated Person”?

The Act requires NCII entities to appoint a specific person responsible for cyber security management. This “Designated Person” is the primary liaison with NACSA and can be held personally accountable for failures.

The “Incident Management” Mandate

One of the most critical requirements of the Act is the mandatory incident reporting timeline—often within 6 hours of detection.

  • The CISM Advantage: The Certified Information Security Manager (CISM) certification dedicates an entire domain to Incident Management. It trains leaders not just to fix the technical issue, but to manage the crisis communication and regulatory reporting that must happen simultaneously.
  • Competency Framework: NACSA and Bank Negara Malaysia (BNM) often use CISM as a benchmark for the “competency” required of a Chief Information Security Officer (CISO).
CRISC: Certified in Risk and Information Systems Control

Where Does CRISC Fit in the Supply Chain?

While CISA audits and CISM manages, the Certified in Risk and Information Systems Control (CRISC) predicts.

Proactive Risk vs. Reactive Compliance

The Cyber Security Act 2024 mandates that entities identify risks before they become incidents. CRISC holders are trained to map technical threats (like AI-driven ransomware) to business impacts (like regulatory fines).

  • Vendor Risk Management: With the rise of SaaS and cloud dependencies, the “supply chain” is the new perimeter. CRISC provides the framework for assessing the security posture of vendors before a contract is signed, a key requirement of the SC Guidelines.

Actionable Advice: How to Prepare Your Organization

For HR Directors and Compliance Heads, the path to 2026 compliance involves three strategic steps:

1. Conduct a “Competency Gap Analysis”

Map your current security team against the requirements of the NCII Sector Lead directives. Do your internal auditors hold CISA? Does your CISO hold CISM? If not, you may be non-compliant with the “competency” clauses of the regulations.

2. Leverage HRD Corp for “Defense Line” Training

Training for CISA, CISM, and CRISC is HRD Corp claimable through authorized providers like Trainocate Malaysia. Use your levy to certify your key personnel, effectively subsidizing your regulatory compliance costs.

3. Adopt the “Three Lines of Defense” Model

  • First Line (Operational): SOC Analysts certified with CCOA to detect threats.
  • Second Line (Risk/Compliance): Risk Managers certified with CRISC and CISM to oversee policy.
  • Third Line (Audit): Internal Audit certified with CISA and AAIA to validate controls.

Conclusion

In 2026, a cyber breach is no longer just a bad day at the office—it is a potential crime. The Cyber Security Act 2024 has raised the bar, and ISACA certifications are the ladder organizations need to clear it. By investing in CISA and CISM, you are not just training your staff; you are buying insurance against regulatory liability.

In our final article, Malaysia Salary Guide 2026: The Real Value of ISACA Certifications, we will break down the numbers and explore the salary trends for 2026 and the financial ROI of these certifications.

About the Author

Kevin Boey

Kevin is the Head of Marketing & IT for Trainocate with over 20 years of working experience with Malaysia's largest EdTech provider specializing in Information Technology & Human Development Competency solutions.

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