News & Analysis as of

Regulation S-K Cyber Incident Reporting Form 10-K

WilmerHale

Preparing for Cybersecurity Disclosure as a Public Company

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The SEC, investment banks and other stakeholders are increasingly focused on cybersecurity in IPO companies given the potential financial, legal and reputational risks....more

A&O Shearman

FORMS 10-K AND 20-F - Preparing for your Annual report

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This guide discusses important themes and trends for the coming annual reporting season. It also includes a “housekeeping checklist” designed to assist you as you prepare your annual report. ANNUAL CYBERSECURITY...more

Vinson & Elkins LLP

Double-Edged Disclosure: Navigating 10-K Season with the SEC’s New Cybersecurity Disclosure Rules

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Public companies are now required to comply with new cybersecurity disclosure requirements in their Annual Reports on Form 10-K for fiscal years ending on or after December 15, 2023. In preparing this cybersecurity...more

Goodwin

Cybersecurity - Cracking the Code on Upcoming Disclosures

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As annual reporting season begins, it is important to take a fresh look at the company’s governance and incident response processes and develop risk-informed and compliant disclosures. While many companies are understandably...more

Carlton Fields

SEC Deals New Cybersecurity Disclosure Requirements to Public Companies

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On July 26, 2023, the SEC adopted new cybersecurity rules, which have two top-line impacts. First, registrants must disclose material cybersecurity incidents promptly on Form 8-K. Second, registrants must disclose new...more

Patterson Belknap Webb & Tyler LLP

New SEC Rules Required Public Companies to Promptly Disclose Cyberattacks

On July 26, 2023, the Securities and Exchange Commission (the “SEC”) adopted rules requiring public companies to promptly disclose material cybersecurity breaches on Form 8-K and detailed information regarding their...more

Paul Hastings LLP

Public Company Watch: August 2023

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In the August edition of our Public Company Watch, we cover key issues impacting public companies, including the SEC’s enhanced disclosure requirements regarding cybersecurity risk management, strategy, governance and...more

Husch Blackwell LLP

Twelve Planning Tips to Avoid Complications with the SEC’s Cybersecurity Disclosure Rules: Part II

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Part I of this blog series discussed the compliance dates and the new definitions in the U.S. Securities Exchange Commission’s (the “SEC”) final rules (the “adopting release”) for cybersecurity disclosures. In Part II, we...more

Kilpatrick

SEC Issues Final Rule on Cybersecurity Incident Reporting and Cybersecurity Risk Management Disclosure

Kilpatrick on

The Securities and Exchange Commission (the “SEC”) issued a final rule on July 26, 2023 that will require public companies to disclose material cybersecurity incidents on Form 8-K within four business days of discovery. In...more

K&L Gates LLP

SEC Adopts Final Rules for Cybersecurity Disclosures

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Companies will soon face new reporting requirements with respect to cybersecurity incidents and governance after the US Securities and Exchange Commission (SEC) adopted final rules on 26 July 2023. The final rules supplement...more

Perkins Coie

It’s Official: Cybersecurity Disclosure Is Coming This Year

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The U.S. Securities and Exchange Commission (SEC) adopted final rules on July 26, 2023, requiring public companies to provide current disclosure, within what may be a short time window, about material cybersecurity incidents...more

Cooley LLP

SEC Adopts Comprehensive Cybersecurity Disclosure Requirements

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On July 26, 2023, the Securities and Exchange Commission (SEC) voted at an open meeting to adopt final rules to mandate standardized cybersecurity disclosures by public companies. The final rules will...more

White & Case LLP

SEC Adopts Mandatory Cybersecurity Disclosure Rules

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On July 26, 2023, the Securities and Exchange Commission ("SEC"), in a 3-2 vote, adopted rules that will require public companies to make prescribed cybersecurity disclosures.1 The rules are designed to elicit "consistent,...more

Morgan Lewis

SEC Adopts Rules on Mandatory Cybersecurity Disclosures

Morgan Lewis on

The US Securities and Exchange Commission (SEC) adopted on July 26, 2023 final rules and amendments for mandating disclosure regarding cybersecurity risk management, strategy, governance, and incident reporting, including...more

Jones Day

SEC Adopts Rules on Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure

Jones Day on

In Short - The Situation: On July 26, 2023, the U.S. Securities and Exchange Commission ("SEC") adopted final rules that significantly alter cybersecurity disclosure obligations for companies. The SEC's final rules adopt...more

Wiley Rein LLP

SEC Adopts Controversial New Cybersecurity Disclosure Rules for Public Companies

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Public companies will soon face new cybersecurity disclosure requirements from the Securities and Exchange Commission (SEC), which voted last week to approve a controversial new cybersecurity rule. The final rule—which is...more

Sullivan & Worcester

SEC Adopts Rules for Cybersecurity Disclosures

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On July 26, 2023, the Securities and Exchange Commission (SEC) adopted rules imposing significant new disclosure requirements regarding cybersecurity risk management, strategy and governance and incident reporting by public...more

Fenwick & West LLP

SEC Adopts New Cybersecurity Disclosure Rules

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On July 26, the U.S. Securities and Exchange Commission adopted rules to enhance and standardize public company disclosure of cybersecurity incidents, risk management, strategy and governance. In particular, the rules,...more

Bass, Berry & Sims PLC

SEC Adopts Cybersecurity Disclosure Rules

On July 26, the Securities and Exchange Commission (SEC), by a 3-2 vote, adopted final rules intended to enhance public companies’ disclosures regarding (1) cybersecurity incidents through a new required current report item...more

Goodwin

Although Scaled Back, the SEC’s Newly Adopted Cybersecurity Disclosure Rule Will Require Significant Effort by Public Companies to...

Goodwin on

As a significant step in its ongoing initiatives on the disclosure, management, and oversight of cybersecurity risks and incidents, on July 26, 2023, the US Securities and Exchange Commission (SEC or Commission) adopted rules...more

Holland & Knight LLP

SEC Finalizes Cybersecurity Incident and Governance Disclosure Obligations for Public Companies

Holland & Knight LLP on

The long-awaited U.S. Securities and Exchange Commission (SEC) cybersecurity rules for public companies have finally arrived. On July 26, 2023, a divided SEC adopted new rules requiring each public company to, among other...more

Epstein Becker & Green

SEC Finalizes Cybersecurity Rule: What It Means

Epstein Becker & Green on

On July 26, 2023, the Securities and Exchange Commission (“SEC”) adopted its long-anticipated cybersecurity reporting rule (the “Final Rule”). The Final Rule applies to public companies subject to the reporting requirements...more

Morgan Lewis

SEC Proposes Mandatory Cybersecurity Disclosures

Morgan Lewis on

The US Securities and Exchange Commission has proposed new rules and amendments to mandate disclosure regarding cybersecurity risk management, strategy, governance, and incident reporting, including amendments to Form 8-K,...more

WilmerHale

SEC Proposes New Public Company Cybersecurity Disclosure Rules

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On March 9, 2022, the SEC proposed rules, by a 3-1 vote, that are intended to enhance disclosures about cybersecurity risk management, strategy, governance, and incident reporting by public companies. The proposed rules are...more

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