Incident Notification Obligations

Last week, the government announced two sets of proposed revisions to the Federal Acquisition Regulation (FAR) to improve the cybersecurity of the government’s information systems. Both sets of revisions relate to President Biden’s May 2021 Executive Order 14028 on Improving the Nation’s Cybersecurity.

First, the Department of Defense (DoD), the General Services Administration

The European Council and European Parliament recently reached a provisional agreement on the text for the EU’s proposed Directive on minimum cybersecurity standards to be implemented across the EU (NIS2). The text is expected to be formally adopted in the coming months. NIS2 seeks to replace and strengthen the EU’s current Network and Information Society

On January 7, 2019, the US self-regulatory organization the National Futures Association (“NFA”) announced that it had adopted amendments to its information security requirements that include a cybersecurity incident notification obligation.1 As discussed below, the NFA’s amendments represent the continued maturation of information security in the US financial services sector and are incremental, rather