Michelle A. Reed of Paul Hastings. Courtesy photo'Be Prepared and Practice': Paul Hastings' Michelle Reed Breaks Down Firm's First SEC Cybersecurity Incident Disclosure Report
Michelle Reed, co-chair of data privacy and cybersecurity group at Paul Hastings, shared her insights on the biggest takeaways from the novel data and her predictions for cybersecurity disclosures in the year ahead.
January 14, 2025 at 09:00 PM
8 minute read
What You Need to Know
- The number of cybersecurity incidents disclosed by public companies has increased 60% since the SEC rules went into effect.
- Fewer than 10% of the disclosed incidents included a description of the material impact to the company.
- 78% of disclosures were made within eight days of discovery of the incident, with 42% of companies providing an update by issuing an updated Form 8-K after the initial disclosure.
Last month, Paul Hastings released its first SEC Cybersecurity Incident Disclosure Report, which analyzed 75 disclosures issued by 48 public companies that disclosed cybersecurity incidents between Dec. 18, 2023, and Oct. 31, 2024.
The report was published one year after the U.S. Securities Exchange Commission enacted requirements around businesses' cybersecurity disclosures, which ordered public companies to disclose all "material" cybersecurity incidents—including the nature, scope and timing of the incidents and their impact on the companies, their finances and their operations—within four days of assessing them.
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