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

The wave of online safety regulation is continuing to surge, with Brazil’s recent enactment of Law No. 15,211/2025—the Digital Statute for Children and Adolescents (Digital ECA)—as the latest addition. 

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. 

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. 

The Connecticut Governor signed SB 1295 into law on June 25, 2025, again amending the Connecticut Data Privacy Act (CTDPA). 

The U.S. Securities and Exchange Commission (SEC) adopted final rules relating to cybersecurity disclosure on July 26, 2023, which will take effect on December 18, 2023.