FR 2025-01165

In the latest document from the Cybersecurity and Infrastructure Security Agency (CISA), the agency is seeking input on a new data collection effort related to cyber incident reporting. As cybersecurity threats become increasingly sophisticated, CISA aims to gather more useful information to better prevent and respond to these incidents. The proposed information collection request introduces a revamped form that attempts to streamline the reporting process while soliciting comprehensive details necessary for effective analysis and response.

General Summary

CISA's notice details an effort to improve their existing incident reporting systems by refining the kinds of data they collect. This initiative includes revisiting the type and amount of information requested from stakeholders when they report cybersecurity incidents. The document highlights that CISA has considered previous public feedback, leading to the modification of some questions to minimize the burden on respondents. Additionally, CISA underscores the importance of preparedness in handling cyber threats, indicating that the new form will include questions about entities' readiness levels. Public comments on this proposal are open until February 18, 2025.

Significant Issues or Concerns

One of the primary concerns highlighted in the document is the complexity of the language used, which may hinder the general public’s ability to contribute effectively. Legal and technical terms might not be easily understood by everyone, potentially limiting the diversity and breadth of feedback.

Furthermore, the document outlines substantial burdens associated with the reporting requirements. The anticipated total burden hours and associated costs appear significant, which could be seen as onerous, especially for smaller entities or those lacking adequate resources.

Additionally, the document seems to provide insufficient clarity on how the collected feedback will impact decision-making. While requesting further public comments, the notice does not clearly outline how these will influence CISA's final decisions or the development of the reporting form.

Impact on the Public

The proposed changes are likely to have a broad impact on entities that encounter cybersecurity incidents. For the general public, improved threat detection and mitigations resulting from enhanced data collection could lead to increased national cybersecurity resilience. However, there is a risk that the complexity and potential reporting burden might discourage smaller entities from fully participating in the reporting process or fulfilling their reporting obligations.

Impact on Specific Stakeholders

For organizations directly involved in stakeholder reporting, especially state, local, tribal, and territorial governments, private sector entities, and academia, the proposal may present both challenges and opportunities. On one hand, they might gain from a more effective national response to cybersecurity threats. On the other, the burden of providing detailed information and the resources required to accommodate such requests could be significant, particularly for smaller organizations.

The refined questionnaire aims to reduce redundant data requests but may still impose significant demands on organizations with limited cybersecurity infrastructure. Additionally, confusion could arise for these stakeholders due to the separation of this collection process from the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (CIRCIA) requirements, without simple clarifications in the document.

In conclusion, while CISA's proposal is a step towards a more robust national cybersecurity framework, ensuring that the process is accessible, clear, and minimally burdensome for all stakeholders is crucial for its success. Public input will be vital to refining these processes further, balancing the informational needs with the diverse capabilities of reporting entities.

The Federal Register document contains several references to financial impacts related to the new information collection request by the Cybersecurity and Infrastructure Security Agency (CISA). These financial references provide insights into the costs associated with the implementation and maintenance of the incident reporting form.

Financial Overview

The document outlines the annual burden cost for respondents, which is estimated at $8,870,611. This figure represents the cost to entities such as State, Local, Tribal, and Territorial Governments, Private Sector, and Academia for the time and resources required to comply with the reporting requirements.

Additionally, the annual Government cost is cited as $4,351,162. This amount likely covers the federal expenses involved in managing, reviewing, and using the collected incident data, including the maintenance of the reporting systems and analysis of the reports submitted.

Relation to Identified Issues

The significant financial figures mentioned in the document, such as the 198,250 total burden hours, emphasize the considerable commitment required from both the respondents and the government. Such a large number of hours and corresponding costs could be seen as burdensome, particularly for smaller entities that might lack the resources necessary to compile and report the detailed information requested. This concern aligns with the issues identified in the document, which suggest that the burden of detailed incident reporting may be challenging for entities with limited capacity.

Furthermore, the separation of financial allocations related to this incident reporting and those required for the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (CIRCIA) may cause confusion. Entities that are obliged to report under both frameworks might face difficulties in understanding the distinctions and financial implications, contributing to the perceived burden.

By focusing on efficiently utilizing financial resources and streamlining reporting processes, CISA can potentially address some of the concerns about the burden on respondents. It is crucial for CISA to provide clarity on how financial inputs are intended to improve the system, which in turn could encourage more effective participation and compliance from the involved entities.