Navigating New SEC Cybersecurity Disclosure Rules: Lessons from Recent Breaches

This article examines the new SEC cybersecurity disclosure rules, effective December 15, 2023, by analyzing how companies like Okta, Clorox, and 23andMe handled significant cyber incidents prior to the rule's full enforcement. It highlights key considerations for CISOs, CFOs, and financial reporting personnel regarding the timing, nature, and materiality of disclosures, emphasizing the importance of proactive communication and understanding the nuances of the 8-K filing requirements.