


In the rapidly digitizing landscape of modern America, our homes, businesses, and national infrastructure are increasingly reliant on interconnected devices—collectively known as the Internet of Things (IoT). These devices promise convenience and efficiency, but they also pose an unprecedented cybersecurity challenge. From smart thermostats to baby monitors, each device can become a potential gateway for cyberattacks. The Biden Administration’s development of the U.S. Cyber Trust Mark (CTM) attempted to meet this challenge. While we take issue with many elements of that administration’s broader regulatory agenda, the CTM represents a rare case of smart, market-aligned governance.
The CTM is a voluntary labeling program for consumer IoT products that allows manufacturers to demonstrate they meet certain cybersecurity standards. But its true innovation lies not in the sticker slapped on a product box—but in the market incentives it unleashes. Unlike heavy-handed federal mandates, the CTM respects consumer choice, empowers corporate accountability, and opens the door to a new kind of risk-based procurement that strengthens our national cybersecurity from the ground up.
Most existing liability regimes deal primarily with physical injury. Cyber risk, however, is intangible, often global in scale, and notoriously difficult to attribute. A cyber breach may not leave a broken window, but it can compromise a hospital’s operating systems or leak millions of personal records in seconds. The CTM recognizes this gap and addresses it by helping manufacturers and buyers align incentives and shift risk. By voluntarily opting into the program, manufacturers make specific cybersecurity representations—promising diligent identification of vulnerabilities and timely updates. In return, buyers can begin pricing in the long-term cost of ownership, not just the sticker price.
This rebalancing of market forces is long overdue. Cybersecurity must become a procurement issue, not just a technical one. Until now, the decision to buy a piece of connected equipment has rarely involved weighing cybersecurity risk. With the CTM, that’s changing. Operators—especially those in safety-critical sectors—can now demand certain representations from vendors, transferring some responsibility from the buyer to the manufacturer. This isn’t just good policy—it’s sound business.
Moreover, the CTM isn’t limited to protecting the individual buyer. It fosters a broader cultural shift: a competitive marketplace where good cybersecurity becomes a selling point, not an afterthought. It encourages discipline among vendors while allowing insurers, operators, and manufacturers to engage in meaningful price discovery around cyber risk—a necessary step to developing a robust insurance market for this domain. Actuarial tables cannot be built in a vacuum. They require market behavior and claims experience. The CTM may be the catalyst for getting us there.
Importantly, the CTM steers clear of regulatory overreach. It is voluntary, avoiding the pitfalls of a low floor that often accompanies mandatory schemes. It is enforceable under existing contract and tort law rather than attempting to navigate a bureaucratic maze. And it deliberately avoids defining “consumer use” too rigidly, leaving room for innovation and operator discretion.
Critics will inevitably ask whether this goes far enough. Why not make cybersecurity standards mandatory? Why not issue sweeping federal regulations? The answer is simple: central planning cannot keep pace with technological innovation. We’ve seen time and again how government edicts stifle competition, entrench incumbent players, and saddle American companies with burdens that our adversaries ignore. The CTM, by contrast, supports a dynamic and adaptable approach, putting trust in markets rather than mandates.
And this approach has global appeal. As anti-Western regimes like China seek to dominate IoT supply chains and embed vulnerabilities into global technology infrastructure, the CTM gives American and allied manufacturers a chance to reclaim lost ground. It creates a new competitive advantage: not just cost, but trust.
Let’s be clear—this is also a matter of national security. Cyberattacks can cripple power grids, halt transit systems, and expose intelligence networks. Yet many of the devices we rely on are sourced from foreign adversaries, built with opaque firmware, and updated at the whims of overseas suppliers. The CTM gives us a path toward sovereignty in the cyber domain. It allows procurement officers to favor vendors who take security seriously. It enables American manufacturers to compete on risk-adjusted value. And it empowers corporate advisory boards to make decisions based not only on margin—but on mission.
For insurers, this opens a new frontier. As cyber risk becomes quantifiable, insurance products can evolve beyond vague coverage language and exorbitant premiums. For corporate risk officers, it provides a framework to engage vendors and drive accountability. And for consumers, it offers peace of mind in a world where every new device is a potential threat vector.
This is how we win: not through sweeping regulations and bloated bureaucracies, but by aligning economic incentives with our national interest. We win by creating a differentiated market for security and restoring trust—not just in products, but in the ability of free enterprise to solve difficult problems.
The CTM is not a silver bullet. But it’s a smart step in the right direction—a model for how conservatives can engage with emerging threats without sacrificing limited government or market freedom. It’s proof that not every challenge requires a command-and-control solution. Sometimes, the best way to protect our nation is to empower it.
Let us build on this momentum. Let us encourage more voluntary standards, more market discipline, and more innovation in defense of our digital frontier. In an era where cyber threats multiply by the day, the path forward must be guided not just by government edict, but by the enduring strength of the American marketplace.