When Compliance Becomes a Liability

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The SEC has operationalized breach notification expectations, converting policy-level incident response into time-bound, third-party-enforceable disclosure obligations.

Audit committees are now asking whether the organization can prove, in real time, that service provider notification clauses are contractually binding and exercised against the same clock as internal teams.

Most enterprises rely on vendor attestations and legacy response plans that were never designed to withstand a 30-day evidentiary standard.

This gap transfers risk from systems to individuals who certified readiness without validating enforceability under the new disclosure regime.

Compliance is no longer declarative; it is evidentiary.

Decision and corrective implications are addressed in this week's CISO Briefing.