Privacy & Information Security Law Blog

As we pass the two-month anniversary of the effectiveness of the U.S. Securities and Exchange Commission’s (“SEC’s”) Form 8-K cybersecurity reporting rules under new Item 1.05, this blog post provides a high-level summary of the filings made to date.

As we previously reported, the U.S. Securities and Exchange Commission’s (“SEC”) new Form 8-K rules for reporting material cybersecurity incidents take effect today, December 18, for filers other than smaller reporting companies. The new rules require reporting to the SEC within four business days from the determination of materiality.