U.S. Dept. of Energy Seeks Comment on Updated Cybersecurity Capability Maturity Model

Dec 1, 2021

Reading Time : 1 min

DOE first developed C2M2 in 2012 in partnership with the U.S. Department of Homeland Security and in collaboration with industry, private-sector and public-sector experts.1 Version 1.1 came in 2014, with separate versions targeted for the electricity and oil and natural gas subsectors. Version 2.0 is “designed for use across the energy sector, and can be used by other critical infrastructure sectors as well.” It includes “input from the Energy Sector C2M2 Working Group, which comprises 145 energy sector cybersecurity practitioners representing 77 energy sector and cybersecurity organizations.” According to DOE, it “better addresses new technologies like cloud, mobile, and artificial intelligence,” as well as “evolving threats such as ransomware and supply chain risks.” Since July, DOE has been piloting Version 2.0 with energy companies and utilities and now seeks to “obtain the broadest possible input” to “inform the C2M2 Working Group as it develops future model updates.” In particular, DOE seeks input on:

  • “The usefulness of C2M2 practices in evaluating and improving cybersecurity program capabilities.”
  • “The applicability of practice language to the IT and OT environments in use by energy sector organizations.”
  • “The readability of and ability to understand practice language.”
  • “The completeness of cybersecurity domains, objectives, and practices [in] the C2M2.”
  • “The effectiveness of guidance documentation (e.g., model introduction sections, domain introductions, and appendices) in conveying model concepts, architecture, and how to use the model.”
  • “Any other potential improvements to the C2M2 documentation or practices contained therein.”

Interested entities can submit comments to C2M2@hq.doe.gov using the Comment Submission Form available here.


1 See https://www.energy.gov/ceser/cybersecurity-capability-maturity-model-c2m2.

Share This Insight

Previous Entries

Speaking Energy

April 7, 2026

Oil & gas companies are adapting swiftly to the administration’s energy dominance agenda, replacing net zero commitments with strategic opportunities across three emerging revenue streams. The AI-driven data center boom is fueling unprecedented demand for reliable onsite power, with traditional energy companies leveraging their natural gas resources and infrastructure expertise to build dedicated generation facilities and enter construction joint ventures. Major oil producers are simultaneously exploiting their subsurface exploration capabilities to expand into critical mineral supply chains essential for battery technologies, electronics and aerospace applications. 

...

Read More

Speaking Energy

April 3, 2026

Akin is proud to serve as a Gold Sponsor of Infocast’s Tax Credits & Transferability 2026, taking place on May 5-6 in Houston.

...

Read More

Speaking Energy

March 26, 2026

Antitrust enforcement is showing early signs of transformation as new leadership promises more accommodating approaches to oil & gas consolidation. In the United States, Federal Trade Commission chair Andrew Ferguson assumed office in January 2025, signaling a more permissive stance toward merger approvals that oil & gas companies have welcomed enthusiastically. This shift represents a potential departure from the heightened scrutiny that characterized previous years, creating optimism among dealmakers seeking opportunities for strategic combinations. 

...

Read More

Speaking Energy

March 19, 2026

International trade policy has emerged as a dominant force shaping the oil & gas sector, with sweeping tariffs imposed on products from virtually every nation using authorities including IEEPA, Section 232 and Section 301. President Trump's "America First Trade Policy" leverages duties as negotiation tools to secure bilateral deals featuring significant oil & gas purchase commitments, making trade considerations essential for any cross-border transaction. Energy dominance serves as a cornerstone of the administration's economic and national security strategy, placing the industry squarely in the spotlight. 

...

Read More

© 2026 Akin Gump Strauss Hauer & Feld LLP. All rights reserved. Attorney advertising. This document is distributed for informational use only; it does not constitute legal advice and should not be used as such. Prior results do not guarantee a similar outcome. Akin is the practicing name of Akin Gump LLP, a New York limited liability partnership authorized and regulated by the Solicitors Regulation Authority under number 267321. A list of the partners is available for inspection at Eighth Floor, Ten Bishops Square, London E1 6EG. For more information about Akin Gump LLP, Akin Gump Strauss Hauer & Feld LLP and other associated entities under which the Akin Gump network operates worldwide, please see our Legal Notices page.