How MSPs Can Navigate the Evolving Role of Security Leadership Without Crossing Boundaries
Managed Service Providers (MSPs) have long been the backbone of their clients’ IT operations, handling everything from patching systems to strategic guidance. However, there’s a growing shift: clients are increasingly expecting MSPs to step into executive-level security roles—sometimes even acting as their Chief Information Security Officer (CISO). This transition raises a critical question: How much responsibility should MSPs assume without overstepping ethical or practical boundaries?
In this comprehensive discussion, we explore the complex landscape MSPs face as they gravitate toward security leadership. You’ll learn how to establish clear boundaries, provide valuable guidance, and avoid conflicts of interest, all while positioning your MSP as a trusted advisor.
For decades, MSPs have been quietly managing client IT needs. But as cybersecurity threats have intensified and clients demand more strategic involvement, MSPs find themselves drawn into high-level security discussions. This shift raises the question of whether MSPs are naturally evolving into trusted security advisors or risking conflicts of interest.
Historically, MSPs have involved themselves in strategic conversations, even before the 2020 pandemic, at a level often overlooked. From the beginning, security was central to MSPs’ proposals, focusing on reliability, security, and functionality.
The evolution accelerated post-2020 when external factors like cybersecurity insurance requirements and high-profile security incidents made cybersecurity a boardroom concern. The question is: how far can or should MSPs go in filling these high-level roles?
Clarity in Security Offerings: The Line Between MSP and MSSP
MSPs have been performing security functions—firewalls, backups, patching, and more—for decades, often without calling themselves MSSPs (Managed Security Service Providers). The rise of MSSPs and security-specific tools has sometimes blurred the boundaries, leading to misconceptions.
Despite the emergence of MSSPs, traditional MSPs have been delivering security services that are now considered standard, such as firewall management and vulnerability patches. The real challenge lies in how they scale these efforts responsibly and ethically.
The 2020 Inflection Point: From Technical Support to Strategic Security
The Covid-19 pandemic marked a turning point. Suddenly, clients wanted more than technical solutions—they wanted assurance at the strategic level. This shift is reflected in how cybersecurity insurance forms and compliance standards started requiring detailed security policies and documented risk management.
MSPs have long been involved with high-level discussions, sometimes even before clients realized the importance of such involvement. Now, the demand for strategic security guidance is clearer than ever, but the question remains: how much responsibility should MSPs assume without crossing into roles that could lead to conflicts?
Boundaries and Conflicts: Knowing What’s Within and What’s Too Far
A core concern is the potential conflict of interest when MSPs act as or alongside a formal CISO. One of the biggest risks is the line between advice and execution—when MSPs start implementing policies or making decisions that could expose them to liability or ethical dilemmas.
The role of MSPs is to guide, advise, and recommend. They shouldn’t be the ones making the final call on security policies or governance—those are responsibilities that require full accountability.
If MSPs are involved in developing or executing core security policies, they should avoid being listed as responsible parties in legal or governance documents. Instead, they should act as facilitators or trusted advisors, referring clients to specialists for specific tasks like penetration testing or risk assessments.
Specific Boundaries to Respect
- Penetration testing: Should be recommended and facilitated but not performed directly by MSPs managing the client’s environment to avoid conflicts.
- Business continuity & policies: MSPs can advise but should refrain from being the primary responsible party in official documents.
- Security incident response: MSPs can provide guidance but should not assume legal liability or fiduciary responsibility without proper contractual boundaries.
These boundaries protect both the MSP and the client, ensuring that strategic guidance remains within ethical limits.
The Role of Third-Party Consultants and Virtual CISO (vCISO) Services
An emerging trend involves third-party security consultants or vCISO services entering client environments, often with varying levels of integration. When consultants push for direct implementation of tools or policies—especially without comprehensive understanding—they risk creating disjointed or conflicting solutions.
Having a vCISO or consultant is helpful, but they must operate within a holistic security framework. If they just sell point solutions (like EDR or MFA) without considering how it fits into the overall security posture, problems can arise.
MSPs should be cautious about this: if external consultants are acting independently and selling services that overlap or contradict existing MSP offerings, fragmentation occurs, which can harm the client.
The key is to refer and coordinate. MSPs should maintain control over security architecture and governance, only involving external experts as specialists rather than governance authorities.
The Fine Line of Privacy, Responsibility, and Ethical Considerations
Another critical aspect is the legal and fiduciary responsibilities tied to roles like a virtual CISO or policy maker. Stepping into those roles can entail significant liability.
When you take on responsibilities like managing policies or risk assessments, you’re assuming a fiduciary role. This means you’re accountable for the decisions and advice you provide.
MSPs must decide where their responsibilities end. They can provide recommendations, share templates, and guide strategic discussions—but the final decision and accountability should remain with the client.
Practical Guidance: How MSPs Can Stay on the Right Side of Boundaries
Given the delicate nature of these high-level roles, here’s a distilled set of best practices:
- Be transparent: Clearly communicate what services you provide—advisory versus operational.
- Set boundaries: Avoid being listed as the responsible party in legal or governance documents.
- Refer out: Maintain a trusted network of third-party specialists for tasks like pen testing and policy writing.
- Advise, don’t implement: Provide recommendations and guidance; allow clients to make decisions.
- Document scope and limits: Use contracts and statements of work to specify responsibilities and avoid scope creep.
- Maintain ethical standards: Never act beyond your expertise, especially in legal or fiduciary capacities.
Final Thoughts: The MSPs’ Path Forward
The landscape of cybersecurity is complex and continually evolving. MSPs have a vital role in shaping their clients’ security posture, but this must be done responsibly—and within clear boundaries.
MSPs are the trusted advisors, not the decision-makers for every security function. Their job is to guide and facilitate, helping clients understand their risks and options without taking on liabilities that don’t belong to them.
The future of MSPs involves strategic involvement—being at the C-suite table—while maintaining ethical standards, clarity, and independence. The balance is delicate but essential for long-term trust and success.
FAQ (Frequently Asked Questions)
Q: Can MSPs legally act as a CISO for their clients?
Not typically. MSPs can provide advice and guidance but should avoid being listed as the responsible party in legal or governance documents to prevent liability.
Q: Should MSPs perform penetration testing for their clients?
Generally no, due to conflict of interest. It’s better to recommend and facilitate external pen testers, ensuring contract and scope clarity.
Q: How can MSPs avoid conflicts when higher-level security advice is demanded?
Maintain clear boundaries, document scope, refer specialized tasks to trusted partners, and focus on advisory roles rather than operational responsibilities.
Q: What about security policies—should MSPs establish them?
MSPs can advise and provide templates for policies, but the actual endorsement and responsibility should remain with the client, especially for organizational or HR policies.
Q: Is it necessary for SMBs to have a full-time CISO?
No, most small to mid-sized businesses can’t justify a full-time CISO. MSPs can simulate CISO functions through strategic advice, but not take on legal responsibilities.
Summary
MSPs are increasingly called upon to act as strategic security leaders in their clients’ organizations. While this reflects the growing importance of cybersecurity, maintaining ethical boundaries, clear scope, and referral relationships is vital. Approaching these roles with transparency and responsibility ensures you help clients build security resilience without taking on undue risks or conflicts.