Beyond the Air Gap: The Evolution of OT Security Risk Assessments in 2026

The days of relying on a static, pre-packed annual risk assessment performed on a clipboard are all but over. The operational landscape has shifted from human-driven ransomware to complex phising campaigns, and regulatory bodies have moved from "suggesting" guidelines to mandating accountability with steep financial penalties.

The threats have changed, the regulations have changed and it is time we take a new look at threat assessment approaches.

If you are an OT security leader, a CISO, or a site manager, here is how your risk assessment methodology must evolve in 2026 to survive the new threat environment.

Before we move forward, don’t forget to check out our previous blog post on Understanding Chinese threat actors, TTPs and operational priorities here.

Risk assessments are now a dynamic exercise

Even a year ago, many enterprises would rely on a pre-fabricated risk management effort that focused on assessing pre-determined parameters. Some of these parameters were either obsolete or were not very essential from a security standpoint. Further, the need to add parameters to make the assessment informed and relevant to the specific OT security threats and environment configurations was never felt earlier, except by some regulators.

The most significant change in 2026 is the demise of the pre-packaged "snapshot" assessment. You can no longer rely on a so called point-in-time risk audit that turns obsolete the moment the auditor leaves the site.

The emerging threat environment: "persistent" adversaries

Risk assessments in 2026 must account for threats that are complex and act out differently. We are no longer just defending against script kiddies or manual hackers; we are defending against trained AI agents. In addition, groups like ScatteredSpider are targeting sectors and countries as a whole. Their campaigns are ongoing and we need to ensure that the threat assessments reflect this reality and the challenge it presents to OT operators.

Here are some of the other cyber threat related aspects that need to be weaved into any assessment framework that you may be considering:

• Autonomous campaigns: AI agents can now autonomously probe, enumerate, and pivot across OT networks with minimal human intervention. Your risk assessment must test for speed of detection (Mean Time to Detect) and response and not just list out the barrier strength (this might give a wrong impression about the actual state of security).

• Hyper-realistic social engineering: Phishing and vishing are no longer about poorly spelled emails. Deepfake voice and video requests from "plant managers" authorizing emergency maintenance are the new norm. Fake requests from threat actors posing to be from the OEMs or even regulators is fairly common now. Assessments must include human-layer "cyber-safety" drills, not just firewall penetration tests. This includes random tests to check if employees fall prey to spoofed calls from service providers.

• Living off the Land (LotL): Attackers are using legitimate admin tools (PowerShell, WMI) to blend in. Assessments must flag "normal" behavior that is actually malicious, requiring a baseline of known-good process states.

Key risk assessment takeaway: Your risk model must assume the perimeter is already breached. The assessment question changes from "Can they get in?" to "How quickly can we eject them before safety systems are compromised?"

Governance: The "Cyber-Safety" Merge

In 2026, OT security is no longer just an IT problem; it is an engineering and safety problem.

• HSE + Cyber Integration: Innovative organizations have merged their Health, Safety, and Environment (HSE) risk assessments with Cyber Risk Assessments. A cyber vulnerability in a safety instrumented system (SIS) is treated with the same gravity as a gas leak.

• The boardroom language: You cannot report "high risk of CVE-2026-1234" to the board. You must report: "A $2.4M potential loss per day due to unmitigated access in the packaging line." 2026 assessments use Cyber Risk Quantification (CRQ) models to translate technical flaws into balance sheet liabilities.

Compliance: Accountability, not just checkboxes

By 2026, the grace periods for major regulations have largely expired, and enforcement is active.

• NIS2 and CRA (Europe): For organizations with EU exposure, the Cyber Resilience Act (CRA) now requires products to be secure by design. Risk assessments must verify the Software Bill of Materials (SBOM) for every device on the plant floor. If you don't know what software is inside your PLC, you are non-compliant.

• Critical Infrastructure Mandates (Global): From the US SEC’s disclosure rules to the UK’s Cyber Assessment Framework (CAF) 4.0, the focus is on personal liability for executives. Assessments must produce defensible evidence of "due care"—proving you did everything reasonably possible to prevent negligence.

The tech stack: AI-driven assessments

You cannot fight AI threats with spreadsheets. 2026 risk assessments leverage technology to scale:

• Digital twin stress-testing: Instead of testing on live production systems (risking downtime), organizations use Digital Twins to simulate ransomware attacks and verify if the segmentation holds.

• Passive asset discovery: You cannot assess what you cannot see. Modern tools passively listen to OT traffic (using spans/taps) to build a real-time inventory. If your assessment starts with "Send me the spreadsheet list of assets," you have already failed.

Summary checklist: Is your 2026 assessment ready?

If you are planning your next assessment, ensure it covers these non-negotiables:

• Technical Baseline First: Do not rely on outdated network diagrams that haven’t been updated in a decade and includes decommissioned assets. Use passive discovery to generate a "ground truth" map.

• Financial translation: Map every technical risk to a specific operational impact (such as "Line 1 Stoppage").

• Insurance impact: How does the audit help in lowering the insurance premiums?  

• SBOM validation: specific audit of supply chain software components within your OT assets.

• Recovery stress test: Don't just test the defense mechanisms; test the incident response and restore process. Can you rebuild the HMI from backups in under 4 hours?

• Safety alignment: Ensure the assessment is reviewed by the plant/site safety manager, not just the CISO.

Talk to a OT security assessment expert from Shieldworkz.