SEC and Cybersecurity: The New Disclosure Obligations that have Transformed the Role of the CISO
The SEC's rules on the disclosure of cyber incidents, effective from December 2023, require reporting of material incidents within four business days via Form 8-K. In May 2025, American banking associations petitioned the SEC to revoke the rule. The practical outcome: the CISO has become a direct interlocutor for the board and legal department in materiality decisions.