CIRCIA, the Cyber Incident Reporting for Critical Infrastructure Act, which was signed into law in March 2022, requires covered entities to report any major cybersecurity incident within 72 hours, and to report ransomware payments within 24 hours of making the payment.
Last year, CISA announced a notice of proposed rulemaking (NPRM), asking the public to submit written comments on the proposal over a period of 60 days starting on April 4. CISA is currently reviewing and considering the comments received during the public comment period in developing the Final Rule, which CISA is required to publish 18 months after the publication of the NPRM.
CISA’s proposed rules to implement CIRCIA are set to enter effect in October 2025. However, this proposed regulation may change based on the priorities of the Trump administration. The resignation of Jen Easterly, former director of CISA, and the formation of the Department of Government Efficiency (“DOGE”) could signal an intent to reduce regulatory burdens for businesses. CISA is unlikely to go away, but its proposed regulations under CIRCIA could see changes or delays.