Key Takeaways

• The SEC’s agreement with defendants to dismiss, with prejudice, its case against SolarWinds Corporation (SolarWinds) and its chief information security officer (CISO) signals a retreat from aggressive, novel enforcement theories in cybersecurity disclosure cases.
• Although technical cybersecurity violations without investor harm

Congress included in the appropriations bill of November 12, 2025, an extension of the Cybersecurity Information Sharing Act of 2015 (CISA 2015), 6 U.S.C. §§ 1501–10, through January 30, 2026. 

Congress members have proposed legislation that would introduce new measures to enhance the United States’ cybersecurity resilience in the face of advancing quantum computing capabilities.

On September 23, 2025, the California Privacy Protection Agency confirmed that their cyber audit regulations will at long last go into effect on January 1, 2026. 

You can be forgiven for losing track since these were first proposed in September 2023, but now is the time to start considering how they will apply to your company and budgeting for that impact. 

State Updates, Security Mandates, and the Federal Regulatory Horizon

The U.S. Department of Justice (DOJ) “Data Security Program” (DSP), also known as the “Sensitive Data Rule” or “Bulk Data Rule,” has prompted numerous questions about its scope and application. 

Key Takeaways

• Multiple agencies of the U.S.

With 2025 more than half over and many state legislatures adjourned for the year, we look back at significant legislative developments concerning state comprehensive consumer privacy laws. 

The TAKE IT DOWN Act (the Act), enacted on May 19, 2025, is a powerful (and controversial) new tool designed to stop people from sharing “nonconsensual intimate imagery,” or NCII, online.

On July 1, 2025, amendments to the Colorado Privacy Act and CPA rules will take effect, significantly expanding the scope of requirements for businesses that control or process biometric identifiers and biometric data. The amendments expand the scope of the law by imposing certain requirements on employers when they collect biometric identifiers or biometric data from their employees (incl

In May 2025, Montana enacted Senate Bill 163 (SB 163), amending that state’s Genetic Information Privacy Act (MGIPA) to include protections for neurotechnology data—namely, data collected from the activity of the central or peripheral nervous system.

Can a communications provider be held liable when it reports to the National Center for Missing and Exploited Children (NCMEC) an image the provider believes to be child sexual abuse material based on signals provided by NCMEC? 

Continued cyberthreats drove expanded data security and breach notification requirements in 2024. Although sectors deemed high-risk saw significant activity, we also saw proposed regulations that stand to have a significant impact on a wide swath of private companies in the year to come.

This Update outlines highlights of data security law in 2024.

After much anticipation, on November 8, the California Privacy Protection Agency (CPPA) Board voted to advance proposed regulations for insurance, cybersecurity audits, risk assessments, and automated decision-making technology (ADMT) to formal rulemaking.