Bubble has no public position on 23 NYCRR Part 500. If you're a vendor to a NY-licensed financial firm, that silence becomes your problem under §500.11 — covered entities must flow down minimum cybersecurity requirements to third parties. Universal MFA on every system has been mandatory since November 1, 2025. Bubble's platform-level controls don't deliver the MFA-everywhere, asset-inventory, and 72-hour incident-reporting posture vendor due-diligence teams check. Vendor-rebuilds usually take 10–20 weeks on AWS or Azure.
The honest verdict
Not officially. Not the way you’d ship NY DFS 500 in production.
Bubble has no public stance. The platform's architecture makes a real audit hard. There is no mention of 23 NYCRR 500 anywhere on bubble.io. That silence means none of the standard's specific requirements — universal MFA enforcement, immutable audit trails, 72-hour incident reporting, dual-signature certification — are addressed by Bubble at platform level. Vendor due-diligence teams reading §500.11 against a Bubble-hosted vendor will flag every gap.
Reviewed by
Greg· Founder, bubbletocode.com — has migrated 30+ Bubble apps to code
Bubble's stance
Silent
No DFS-specific position published
Worst-case penalty
$40M precedent
Block Inc. settlement (NYDFS 2025) + license action risk
Industries impacted
Banking · Insurance · Mortgage · Money transmitters · Virtual currency
Compliant rebuild
$50k–$150k · 10–20 weeks
AWS or Azure with MFA-everywhere + IR SLA
What NY DFS 500 actually requires
23 NYCRR Part 500 is the New York Department of Financial Services cybersecurity rule. It applies to NYDFS-licensed banks, insurers, mortgage lenders, money transmitters, and virtual-currency firms — and flows down through §500.11 to their third-party service providers. NYDFS enforces with monetary penalties and license actions; multi-million-dollar settlements are routine.
Maintain a written cybersecurity program and policy based on a documented risk assessment, approved by a senior officer or the board (23 NYCRR 500.2 / 500.3).
Designate a qualified Chief Information Security Officer who reports in writing to the senior governing body at least annually (23 NYCRR 500.4).
Implement multi-factor authentication for every individual accessing any information system — universal MFA effective November 1, 2025 (23 NYCRR 500.12).
Maintain a written asset inventory and conduct annual penetration testing plus automated vulnerability scanning (23 NYCRR 500.5 / 500.13).
Report cybersecurity incidents to NYDFS within 72 hours and any ransomware extortion payments within 24 hours (23 NYCRR 500.17(a)).
File an annual Certification of Material Compliance or Acknowledgment of Noncompliance signed by the CISO and a senior officer by April 15 (23 NYCRR 500.17(b)).
Official source: dfs.ny.gov
Why Bubble fails NY DFS 500
Every reason below comes from Bubble’s published platform limits or their own documentation. Reading the list top-to-bottom tells you which one will bite you first.
Part 500.17(a) requires NYDFS notification within 72 hours of a cybersecurity event, and any ransomware extortion payment must be reported within 24 hours. Bubble publishes no hours-based incident-response SLA, no breach-notification commitment, and no escalation contact chain for licensed-entity customers. A covered entity flowing §500.11 down to Bubble has no contractual hook to hit those deadlines.
Part 500 requires logging adequate to support incident investigation and reconstruction. Bubble's logs interface limits search to the previous two weeks, and the manual does not describe the logs as immutable or tamper-proof. Annual penetration-testing evidence, asset-inventory reconciliation, and post-incident forensics all need a longer, signed log trail than the platform provides.
Since November 1, 2025, Part 500.12 requires MFA for every individual accessing any information system. Bubble's MFA and advanced access controls (SSO, SAML) are gated to higher-tier plans — Enterprise for SSO specifically. A covered entity must verify the vendor's MFA covers all personnel and all admin paths, not just the customer-facing app. On lower Bubble tiers that requirement is not satisfiable.
Part 500.4 expects a CISO with effective oversight of the cybersecurity program. On a shared US-AWS cluster the covered entity's CISO cannot inspect the underlying environment, segment financial data, or apply compensating controls at the infrastructure layer. Auditors and DFS examiners reading §500.11 vendor evidence will note the gap explicitly.
Sources[02]
Part 500.11 requires covered entities to assess third-party service providers' cybersecurity practices. Bubble's plugin model loads third-party JavaScript into the user's browser and runs third-party server actions on Bubble's servers. The covered entity now has a vendor whose vendor surface they cannot enumerate, increasing §500.11 due-diligence burden — and giving DFS examiners a clean finding.
Bubble vs a compliant stack
The same 7requirements an auditor will ask about, scored on both stacks. Read across each row — every red cell is a deal you can’t close on Bubble.
Universal MFA across every information system (§500.12)
Fail
MFA / SSO gated to higher tiers
Mandatory since Nov 1, 2025 — Bubble lower tiers can't meet it
Pass
MFA enforced at app + admin + API token layer
Written asset inventory (§500.13)
Fail
Shared cluster, no per-customer inventory
Pass
Tagged in Terraform / Pulumi as IaC
72-hour incident reporting (§500.17(a))
Fail
No documented IR SLA
Pass
Alerts wired to PagerDuty + runbook with 72h clock
Annual penetration test + vulnerability scanning
Partial
Bubble runs annual pentest at platform level
Customer-app pentest still your responsibility
Pass
Self-managed pentest + continuous scanning
Audit logs sufficient for forensics
Fail
Two-week search window, not tamper-proof
Pass
Postgres event log + S3 archive + WORM bucket
CISO with infrastructure oversight (§500.4)
Partial
No infra-layer visibility on shared cluster
Pass
CISO scopes app + infra + sub-processors
Third-party / plugin governance (§500.11)
Fail
Plugins load third-party JS into the browser
Pass
npm dependency scanning + SBOM + vendor reviews
What it costs your business
If you sell to NY-licensed financial firms — banks, insurers, money transmitters, virtual-currency firms — §500.11 flows the cybersecurity requirements straight down to you. Your customer cannot accept your service without evidence you meet the minimum standards. Vendor due-diligence is where the gap surfaces, usually four to eight weeks before contract.
A NY-licensed insurer's CISO runs your vendor due-diligence checklist against 23 NYCRR 500.11 — without documented universal MFA, asset inventory, and 72-hour IR SLA, the contract stays unsigned.
Your bank prospect points you at NYDFS's October 2025 third-party service-provider guidance and asks you to map your controls; you have no platform-level evidence to map, so the procurement stalls.
NYDFS penalised Block Inc. $40M in 2025 over compliance failures including inadequate board-reviewed third-party cybersecurity policies — your customer's CISO uses that precedent to justify saying no to vendors who can't show §500.11 evidence.
An incident hits your customer's environment via your integration; without a documented 72-hour breach SLA from your platform, they miss the §500.17(a) reporting window and face their own enforcement exposure — and you lose the relationship.
Three honest paths forward
We don’t recommend a rebuild for every founder. Below: what each path costs you, what it preserves, and where it breaks for NY DFS 500.
Cheapest now · riskiest later
Not recommendedLayer MFA at the application level, document compensating controls, attempt a §500.11-equivalent evidence package. The underlying problem — no MFA enforcement across all access paths, no immutable audit log, no breach SLA — is platform-level and cannot be fixed by app-level effort alone.
Pros
Cons
Phased · auditor-defensible
Partial fitCarve customer-facing financial data flows onto a cloud you control with MFA-everywhere, an asset inventory, and a documented IR runbook. Keep Bubble for non-regulated workloads. Reduces §500.11 scope but doesn't eliminate it.
Pros
Cons
Highest upfront · clean audit
ViableRebuild on Next.js with AWS (BAA via Artifact, dedicated VPC, KMS keys) or Azure as the host. Both have SOC 1 and SOC 2 Type 2, both let you enforce MFA-everywhere, EDR on workstations, and a documented 72-hour incident-response process. This is the path most NY-vendor founders end up on.
Pros
Cons
Composite case study
Insurtech vendor to a NY-licensed insurer · 12 months on Bubble
Founder closed a pilot with a NY-licensed regional insurer whose vendor due-diligence team handed back a §500.11 evidence package nine pages long: universal MFA across every access path, asset inventory, 72-hour IR runbook, annual penetration test, audit logs retained longer than two weeks. We rebuilt the customer-facing surfaces on AWS over twelve weeks — Next.js front end on Vercel Enterprise, Postgres on RDS with KMS-managed keys, MFA enforced for every admin and every API token, Inngest queues replacing the Bubble workflows that previously timed out at 300 seconds. The Bubble app kept the marketing site and internal CRM.
Outcome: Vendor due-diligence package signed off in week 14, contract executed in week 16, and a second NY-licensed broker conversation that had been pre-screened out re-opened on the back of the SOC 2 readiness work running in parallel.
Composite case study assembled from patterns we've seen across vendor migrations for NY-licensed financial firms. Anonymised for client privacy — happy to walk you through the actual engagements in a scoping call.
Frequently asked
Pulled from real conversations with founders running healthcare, fintech, and B2B SaaS apps off Bubble. Every answer is grounded in the source we cited above — no marketing fluff.
Sources
The numbered references in the body link here. We cite first-party documents — regulator guidance, vendor manuals, industry standards — never marketing copy.
Bubble Group Inc.manual.bubble.io
Bubble Group Inc.manual.bubble.io
Bubble Group Inc.manual.bubble.io
Bubble Group Inc.manual.bubble.io
New York State Department of Financial Servicesdfs.ny.gov
New York State Department of Financial Services · 2025-04-17dfs.ny.gov
New York State Department of Financial Services · 2024-02-26dfs.ny.gov
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