Data, privacy and AI rules

Due in 60 days12Regulations190

12 due in 60 days · 190 regulations

CIRCIA

Enacted United States (Federal) · Enacted Mar 15, 2022 · no upcoming deadlines

Official text
Add to calendar
Apple Calendar or OutlookGoogle Calendar Download .ics

Deadlines

Transition endsJul 3, 2024 · 2.3 years ago · Source
NPRM comment period closedExtended comment period on the CIRCIA proposed rule closed.

Summaries for reference, not legal advice. Check the official text.

What it does

Directs CISA to require covered critical infrastructure entities to report covered cyber incidents within 72 hours of reasonably believing one occurred and ransom payments within 24 hours of payment, and to preserve related data. Reporting obligations begin only once CISA's final rule takes effect.

Who it applies to
As proposed: entities in any of the 16 critical infrastructure sectors that exceed the SBA small business size standard for their industry, or meet sector-based criteria (e.g. hospitals, certain IT and communications providers, water systems). CISA estimated about 316,244 covered entities.
Penalties
CISA may issue requests for information and subpoenas; failure to comply with a subpoena may be referred to DOJ for a civil action and contempt. False statements are subject to 18 U.S.C. 1001; federal contractors may face procurement actions including suspension or debarment.
Enforced by
Cybersecurity and Infrastructure Security Agency (CISA), DHS; DOJ for civil enforcement of subpoenas
Official name
Cyber Incident Reporting for Critical Infrastructure Act of 2022 (CIRCIA) and proposed implementing rule (6 CFR Part 226)
Citation
6 U.S.C. 681-681g; Pub. L. 117-103, div. Y; NPRM 89 FR 23644 (Apr. 4, 2024), RIN 1670-AA04
Topics
Cybersecurity, Breach notification
Verified 2026-09-22 cisa.gov reginfo.gov federalregister.gov hunton.com
Research notes

Final rule not yet published as of 2026-09-22 (Federal Register search). CISA missed the statutory October 2025 deadline, then targeted May 2026, and the latest Unified Agenda lists the final rule for 09/2026 (month only). CISA held further town halls in 2026 (Federal Register notices of Feb. 13 and May 26, 2026) and has said it intends to streamline scope. Obligations will start on the final rule's effective date, expected to be well after publication.

Related

In forceUnited States
AI state-law preemption EODirects federal agencies to push back on state AI laws seen as onerous. It orders a DOJ AI Litigation Task Force, a Commerce list of conflicting state laws, BEAD and grant funding conditions, an FCC disclosure-standard proceeding and an FTC policy statement on AI outputs. It does not itself preempt any state law; that needs Congress or court rulings.In effect since Dec 11, 2025
EnactedUnited States
CFPB Open Banking Rule (Section 1033)Requires banks, card issuers and other data providers to give consumers and authorized third parties their transaction and account data through a secure developer interface, free of charge. Third parties must limit collection, use and retention to what the consumer requested. The CFPB is reconsidering the rule and a federal court has barred its enforcement until that reconsideration ends.Next: Apr 1, 2027 Tier 2 compliance date (original) · in 5 months
In forceUnited States (Federal)
CMMC 2.0Requires defense contractors and subcontractors that handle Federal Contract Information (FCI) or Controlled Unclassified Information (CUI) to meet a specified CMMC level (Level 1 self-assessment, Level 2 self- or third-party (C3PAO) assessment against NIST SP 800-171, Level 3 DIBCAC assessment against selected NIST SP 800-172 controls) as a condition of contract award. Requirements are phased into DoD solicitations over four years.Next: Nov 10 Phase 2: Level 2 C3PAO certification · in 14 days
AmendedUnited States (Federal)
COPPA RuleRequires operators of child-directed online services, or those with actual knowledge they collect personal information from children under 13, to give notice and obtain verifiable parental consent before collecting, using or disclosing that data. The 2025 amendments add separate parental consent for disclosures to third parties (including for targeted advertising), require a written data retention policy and a written information security program, expand 'personal information' to include biometric identifiers and government-issued identifiers, and tighten Safe Harbor program oversight.In effect since Apr 21, 2000
In forceUnited States (Federal)
DOJ Bulk Data RuleProhibits U.S. persons from data brokerage and genomic-data transactions with countries of concern or covered persons, and restricts vendor, employment and investment agreements involving bulk U.S. sensitive personal data or government-related data unless CISA security requirements are met. Restricted transactions require a data compliance program, due diligence, audits, recordkeeping and reporting.In effect since Apr 8, 2025
AmendedUnited States (Federal)
FCC CPNI Breach RuleThe 2023 order expands carrier breach rules from CPNI to all customer personally identifiable information, covers inadvertent disclosures, requires notice to the FCC (in addition to the Secret Service and FBI) within seven business days, and adopts a harm-based trigger for customer notice. Until the revised 64.2011 takes effect, the existing CPNI breach rule (law enforcement notice within 7 business days, customer notice after a waiting period) continues to apply.In effect since Mar 13, 2024
AmendedUnited States (Federal)
FTC Health Breach Notification RuleRequires vendors of personal health records (including health and wellness apps) and PHR related entities not covered by HIPAA to notify affected individuals, the FTC and, for 500+ residents of a state, prominent media, after a breach of unsecured PHR identifiable health information. The 2024 amendments confirm that unauthorized disclosures (not just hacks) are breaches, clarify coverage of health apps drawing data from multiple sources, allow email notice, and expand notice content.In effect since Sep 24, 2009
AmendedUnited States (Federal)
GLBA Safeguards RuleRequires non-bank financial institutions under FTC jurisdiction to maintain a written information security program with a qualified individual, risk assessments, access controls, encryption, MFA, monitoring and board reporting. Since May 13, 2024, institutions must notify the FTC within 30 days of discovering a 'notification event' (unauthorized acquisition of unencrypted customer information) affecting at least 500 consumers.In effect since May 23, 2003
Questions about CIRCIA
What are the CIRCIA compliance deadlines?
Jul 3, 2024: NPRM comment period closed.
Who does CIRCIA apply to?
As proposed: entities in any of the 16 critical infrastructure sectors that exceed the SBA small business size standard for their industry, or meet sector-based criteria (e.g. hospitals, certain IT and communications providers, water systems). CISA estimated about 316,244 covered entities.
What are the penalties under CIRCIA?
CISA may issue requests for information and subpoenas; failure to comply with a subpoena may be referred to DOJ for a civil action and contempt. False statements are subject to 18 U.S.C. 1001; federal contractors may face procurement actions including suspension or debarment.