M3AAWG has submitted comments to the Department of Homeland Security's (DHS) Proposed Rulemaking on “Cyber Incident Reporting for Critical Infrastructure Act (CIRCIA) Reporting Requirements”. M3AAWG recognizes the key role effective cyber incident reporting can have in addressing the impacts of cybersecurity incidents and combating online abuse. Cyber incident reporting can minimize consequences to victims, capture lessons learned, and improve cybersecurity nationwide, thereby increasing the likelihood that perpetrators will be held accountable. However, overly broad cyber incident reporting rules often do not, on balance, yield benefits commensurate with the significant costs those rules impose on both reporting entities and the government.
We generally support CISA’s efforts to craft a proposed rule that seeks to achieve the intended goals of the CIRCIA mandates. However, M3AAWG urges CISA to consider the following suggestions to clarify or modify its proposed rule, as detailed below. We note that our comments today are focused on certain critical areas of concern to our members and do not represent a comprehensive discussion of all issues covered in the expansive CIRCIA NPRM.