Navigating the Evolving Patchwork of Incident Reporting Requirements

Navigating the Evolving Patchwork of Incident Reporting Requirements

In March 2022, President Biden signed into law the Cyber Incident Reporting for Critical Infrastructure Act (CIRCIA), a bipartisan initiative that empowers CISA to require cyber incident reporting from critical infrastructure owners and operators. Rapid7 is supportive of CIRCIA and cyber incident reporting in general, but we also encourage regulators to ensure reporting rules are streamlined and do not impose unnecessary burdens on companies that are actively recovering from cyber intrusions.

Although a landmark legislative change, CIRCIA is just one highly visible example of a broader trend. Incident reporting has emerged as a predominant cybersecurity regulatory strategy across government. Numerous federal and state agencies are implementing their own cyber incident reporting requirements under their respective rulemaking authorities – such as SEC, FTC, the Federal Reserve, OCC, NCUA, NERC, TSA, NYDFS, and others. Several such rules are already in force in US law, with at least three more likely to become effective within the next year.

The trend is not limited to the US. Several international governing bodies have proposed similar cy ..

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