SEC Cybersecurity Disclosure Rule: What CISOs and Security Engineers Must Do Before the Deadlines Hit
The SEC's cybersecurity disclosure rule requires public companies to report material incidents on Form 8-K within four business days of a materiality determination, and to disclose risk management programs and board oversight annually in 10-K filings. Large accelerated filers have been subject to incident reporting requirements since December 18, 2023, with enforcement precedent already set through the SEC's fraud charges against SolarWinds and CISO Timothy Brown. Security teams must build materiality determination workflows, align IR playbooks to disclosure triggers, and ensure 10-K disclosures accurately reflect internal security posture.