Cybersecurity Agency Gets Three Comments, One Completely Off-Topic
Published Date: 1/17/2025
Notice
Summary
CISA is asking for your thoughts on a new incident reporting form that helps track cybersecurity problems. This form affects anyone who reports cyber incidents and aims to make sharing info easier and faster. You’ve got until February 18, 2025, to send in your comments—no cost to you, just a little time to help improve the process!
Analyzed Economic Effects
4 provisions identified: 2 benefits, 1 costs, 1 mixed.
New CISA Incident Reporting Form
If your organization reports cyber incidents to CISA, a new Incident Reporting Form will replace the current form for non-CIRCIA authorities. CISA estimates 26,000 respondents, an average initial report time of 3 hours and updated report time of 7.5 hours, total annual respondent burden of 198,250 hours, and total annualized respondent cost of $8,870,611.
Streamlining: Removed and Grouped Questions
CISA removed the proposed 'Violation of Law and Policy' question and will allow grouping like systems instead of requiring full details for every impacted system, except when specific system details are necessary. For entities reporting under FISMA, FEDRAMP, or other regulations whose regulators require it, CISA may still ask more detailed impacted-user and system questions.
New Preparedness and Logging Questions
The new form adds a question asking how prepared an entity was to handle the incident with answer choices: Unprepared, Minimally Prepared, Moderately Prepared, or Well Prepared. CISA also proposes adding fields to indicate availability of DNS security logs, DHCP logs, and IP address management logs for sharing.
CIRCIA Reports Remain Separate and Delayed
CISA says this information collection is distinct from the Cyber Incident Reporting for Critical Infrastructure Act (CIRCIA) reporting and will not replace CIRCIA reports. CISA anticipates that CIRCIA reporting will not go into effect until late 2025 or early 2026.
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