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.

Can buying a video game on a website using pixel technology make you a Video Privacy Protection Act (VPPA) plaintiff? 

Texas has enacted amendments to its state version of the federal Telephone Consumer Protection Act (Tex. Bus. & Comm.

On June 27, 2025, the United States Supreme Court weighed in on the ongoing debate about age verification requirements for websites, holding that it is constitutional for a state to require websites that have a significant portion of adult content to implement commercial age verification systems. 

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.

CISA has proposed security requirements for certain categories of restricted data transfers. Any U.S. business that transfers its data outside the United States or gives businesses or people outside the United States access to its data should review and work with security and legal professionals to ensure compliance.