What CIOs need to know about the newly proposed Critical Infrastructure Cyber Incident Reporting Rule



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Creating a world that is safer and more secure is core to our vision at Palo Alto Networks, but this only can be achieved if we’re collectively making the internet, as a whole, safer. To do this requires more widespread awareness of cyber threats and information sharing, and a newly proposed cyber incident reporting rule from the Cybersecurity and Infrastructure Security Agency (“CISA”) is intended to meet this goal.

The proposed Cyber Incident Reporting for Critical Infrastructure Act (CIRCIA) Reporting Requirements would require covered companies to report certain cyber incidents within 72 hours of discovery and ransomware attack payments within 24 hours. It marks a major shift in the US cyber ecosystem because of how expansive the proposed rule is, extending reporting obligations to previously non-regulated entities.

While the rule applies to companies deemed “critical infrastructure”– many companies may be surprised to learn that this designation extends beyond traditional “owners and operators” – such as shipping ports, dams, water treatment facilities, and power plants. In fact, CISA’s proposed rule actually includes any entity that is not a “small business” operating within 16 different sectors, encompassing a range of industries across the entire economy – from communications to healthcare, food and agriculture, and beyond. Additional organizations are also covered under certain criteria listed in the proposed rule. This new rule will affect a vast number of companies; in fact, CISA estimates the proposed rule would cover more than 316,000 organizations across the economy. Given this massive proposed scope, it may affect your business, meaning you will have new responsibilities to report incidents related to your cybersecurity operations.

The proposed new guidelines would require companies to report these “covered cyber incidents” within 72 hours (or 24 hours after a ransomware payment). Covered cyber incidents must be “substantial” and reflect certain scenarios affecting data integrity, confidentiality, or availability – such as a data breach where lots of customer data is stolen or a ransomware attack where corporate systems are locked up until a payment is made. Those are just two examples of situations subject to the proposed rule.

Part of the goal of this proposal is to find patterns, inform others of possible risks, and help affected businesses in a timely manner. The proposed rule also calls for certain protections for those who comply and consequences for those who don’t.

It’s still early days for the proposal, and it’s likely to evolve in some ways before it’s finalized. As it stands, the proposed rule is incredibly broad and will impact a major swath of organizations. The cybersecurity regulatory landscape continues to evolve and CIRCIA’s incident reporting requirements are just one of the many new and emerging regulations organizations will need to comply with. We anticipate this increased pressure could evolve into demand for cybersecurity solutions that can better enable compliance by helping to simplify cyber incident identification and response processes.

Protecting Critical Infrastructure

This stresses the importance of now more than ever investing in an advanced security platform to help address security challenges while meeting evolving regulatory requirements quickly and efficiently. This could include:

  • Implementing comprehensive security measures to ensure you have strong visibility of your assets and risk exposure. Use this for continuous monitoring and inspection against malicious activities and anomalies.
  • Utilizing AI-driven automation tools to help with security operations for threat investigation, response, and remediation. These tools also exist for data classification to automate the classification of documents to include levels of sensitivity and better protect against data leakage.
  • Considering where you can decrease operational complexity to build in more capacity for reporting. This can include streamlining the cybersecurity tooling used and supercharging your team’s efforts with AI technology.
  • Considering how you can build cybersecurity into your business by design instead of patching solutions on as an afterthought. A clear view of your vulnerabilities and weaknesses can help you uncover where to prioritize those efforts.
  • Being ready to address your business’s cyber risk with transparency as more information becomes public about incidents.

As governments around the world continue to put in place regulatory requirements covering cybersecurity protections, as well as incident reporting, the best way to be prepared is through a platform approach. It simplifies efforts by creating an integrated user experience, supercharged with AI giving you an “All Access backstage pass” to see your whole cybersecurity ecosystem in one place. It creates interoperability between security solutions, leading to improved visibility and control over the security infrastructure. It also allows for unified management and operations, so you can write policy from one place and enforce it everywhere, consistently, through quick cloud-based deployment. In essence, it’s a comprehensive solution that pulls together all of your data with a unified approach to reporting so you can meet whatever rules come next.

This level of integration is also the key to creating better security outcomes. With the growing mismatch between the speed of an attack and the speed of resolution, the industry standard should be near real-time resolution. This is difficult if not impossible for companies with many security products stitched together. As you reduce the complexity of your operations by streamlining the number of tools and vendors, it makes it easier to manage the environment, remain in compliance with regulations, quickly identify and respond to risks, and create better security outcomes.

One thing is for sure – Cybersecurity is not static, and neither are regulatory requirements. The companies that are most innovative and adaptable will be set up for success in this environment.

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