My first two blog posts discussed how uncertainty stymies public-private operational collaboration, and the confusion created by the terminology used to describe “offensive cyber operations” (which I prefer to just call “cyber operations” for reasons explained in my second post).

Unfortunately, the release of the National Cyber Strategy (Trump II NCS, we’ll use “NCS” throughout) does little to resolve either of those problems. Still, it provides some insight into swirling questions about this Administration’s approach to offensive cyber policy, and particularly the private sector’s role.

Overall Reaction to the Trump II National Cyber Strategy

At the outset, let’s applaud the Trump Administration for releasing its much-anticipated NCS, settling months of speculation about how its approach to cyber operations might differ from prior Administrations. Every Administration since the Bush Administration has sought to put its own imprint on cyber policy by releasing a cyber strategy, resulting in four cyber strategies since 2003: the Bush Administration’s 2003 National Strategy to Secure Cyberspace, the Trump I Administration’s 2018 National Cyber Strategy, the Biden Administration’s 2023 National Cybersecurity Strategy, and the Trump II NCS. (The total is six if you count the Obama Administration’s Cyber Policy Review and the Cyber Deterrence Strategy.) The Trump Administration is now responsible for two of those documents.

Media reporting throughout 2025 sparked conjecture that the Trump II’s approach to cyber operations would set a new course. We learned early in the Trump II Administration that officials discussed letter of marque (a constitutional instrument allowing Congress to authorize private parties to conduct military operations on behalf of the U.S. Government) in a meeting with industry.  

An article published in the fall suggested that Congress shared the Administration’s appetite for a more muscular approach to cyber operation, as a bill had been introduced authorizing the President to issue letters of marque permitting private parties to conduct cyber operations outside the geographic boundaries of the United States. Finally, we learned in December that the Trump Administration planned to seize the opportunity to “revisit bedrock cyber policies.”

These breadcrumbs established expectations that the Trump II NCS would break new ground, marking a substantial shift from the approach of past Administrations. It turns out such assumptions were overblown. In the end, the most surprising aspect of the Trump II NCS may be how surprisingly conventional it is.

The strategy has plenty in common with past cyber strategies. It reaffirms many truisms found in Bush, Obama, Trump I, and Biden cyber strategies:

• We increasingly face cyber threats from both nation states and criminal actors.
• We must better defend federal systems and the critical infrastructure.
• Resilience plays a key role in cybersecurity.
• U.S. disruption campaigns are an important component of a cyber strategy.
• The private sector is a vital partner in combating cyber adversaries.

The Trump II NCS also exhibits a flaw that has dogged most Administrations’ cyber strategies. The seven-page strategy lacks specificity, the same shortcoming that prompted the Government Accountability Office to criticize the Trump I and Biden cyber strategies. While the Trump II NCS identifies an array of cyber challenges facing the Nation, from managing artificial intelligence to defending the supply chain, it fails to prescribe concrete remedies, even at the strategic level. It outlines where the Administration wants the Nation to go without specifying who will be responsible for driving progress, how progress will be measured, what resources will be required, what milestones should be met, or what trade-offs may be necessary.

In this case, the lack of detail raises  questions regarding how policy positions espoused in the Trump II NCS jibe with other Administration policies and initiatives. For instance, the strategy:

• Acknowledges cyber workforce challenges, but how does this square with the Administration’s cuts to the Cybersecurity and Infrastructure Security Agency’s and National Institute for Standards and Technology’s budgets and the firings, layoffs, and forced relocations affecting personnel with cyber missions?
• States that it will ensure AI promotes innovation and global stability “through cyber diplomacy,” but how does this goal align with the objectives stated in the National Security Strategy and elsewhere of establishing global “tech dominance”?
• Promotes common sense regulation as one of its six “Pillars of Action,” but how does this pillar tie into the Administration plan to drastically scale back regulations?

In fairness, these questions and other lack of detail may be addressed in the future. The Office of the National Cyber Director (ONCD) has stated that it intends to draw up implementation plans that will presumably flesh out such details. Agency-specific plans may also be forthcoming.

Where the Trump II NCS distinguishes itself from past cyber strategies is in tone. It echoes a recurring theme in many Trump II documents: dominance. It presages a more aggressive, preemptive, and expansive use of U.S. instruments of national power, similar to approaches this Administration has used to combat threats like narco-trafficking. The strategy does not, however, explain precisely how it will translate this confrontational approach into action in the cyber realm.

The Trump II NCS and Private Sector Cyber Operations

The Administration’s position on private sector participation in cyber operations, as outlined in the Trump II NCS and subsequent official statements, is a mixed bag, resolving some questions while leaving others unsettled.

In my circle of policy geeks, debate has long centered on how the Trump II NCS would integrate the private sector into cyber operations, and specifically whether it would endorse “hack back,” loosely defined as retaliatory cyber action undertaken by a private party. Hack back is an evergreen topic that has resurfaced repeatedly over the past five administrations. No Administration has given hack back its blessing, despite advocates’ invitations to do so. Some speculated that the Trump Administration would be the first. They were wrong, at least so far.

The Trump II NCS’s text stakes out a nebulous position on hack back. Pillar 1 of the six-pillar strategy (entitled “Shape Adversary Behavior”) states, “we will unleash the private sector by creating incentives to identify and disrupt adversary networks and scale our national capabilities.” While this could be interpreted to be an endorsement of hack back, Administration officials have publicly beat back that reading.

Shortly after release of the strategy, an ONCD official stated that while the United States seeks to impose costs on cyber adversaries, “That does not mean hack back, that does not mean letters of marque.” He added, “We’re not interested in fighting pirates with pirates.” National Cyber Director Sean Cairncross further clarified that “private sector, industry or companies engaging in cyber offensive campaigns — that's not what we're talking about.” 

Ultimately, the Trump II NCS’s strategic objective of “Shaping Adversary Behavior” doesn’t differ markedly from past Administrations’ goals. The Obama Administration’s 2015 Cyber Deterrence Strategy sought to “increase the costs and consequences” for U.S. adversaries. The Biden Administration similarly pledged in its 2023 National Cybersecurity Strategy to make cybercrime “unprofitable” and ensure nation-state adversaries “no longer see it as an effective means of achieving their goals.” All these approaches aim, in different ways, to influence adversary behavior. While the Trump Administration might pursue these goals differently, the Trump II NCS does not explain how, other than by emphasizing it will act quickly and decisively.

In Conclusion

So, what does the Trump II NCS mean for the private sector? We’re still not sure. The strategy references the “private sector” or “industry” sparingly, five times each and only once in direct connection to cyber operations. It reaffirms the importance of private-sector involvement in defending, securing, and even “disrupting” cyber threats; however, it has little to say about what new authorities, incentives, or permissions will be offered.

Perhaps forthcoming implementation plans will provide greater clarity. In the meantime, we’ll keep exploring effective public-private cyber operations collaboration and delve into a possible operational framework in the next blog post.

The views of CCPL Fellows do not necessarily reflect the policy positions of the CCPL.