When the US Cybersecurity Disclosure Act was signed into law in March 2022, many in the policy and business communities welcomed it as both overdue and, frankly, daunting. The Act’s core requirement—that companies report significant supply-chain-related cybersecurity incidents—was born of growing concern over vulnerabilities that ripple outward from seemingly minor nodes in complex vendor networks. The SolarWinds breach and others like it had already underscored how third-party service providers could unwittingly open doors to bad actors, leaving regulators and stakeholders uneasy. Now, the Act compels firms, especially those in critical infrastructure and high-tech sectors, to shine a brighter light on these interconnected risks.
What makes the Act particularly striking is that it shifts the focus beyond direct internal systems. It forces a reckoning with the broader digital ecosystem in which a company operates. For IT service providers, this means a heightened responsibility to map not just their own defenses but also the often opaque web of vendor dependencies that make up their supply chains. And this isn’t merely a matter of good housekeeping. The disclosure requirements attach teeth: firms must report significant supply-chain breaches promptly, with penalties looming for non-compliance or misrepresentation.
The big question, then, is how firms—particularly mid-sized IT service providers who may lack the extensive compliance departments of the tech giants—can operationalize this mandate. One practical entry point lies in leveraging public resources that, until recently, may have seemed the domain of only the most risk-averse or compliance-focused teams. The National Institute of Standards and Technology (NIST), through its open cybersecurity framework datasets, offers precisely the kind of scaffolding that firms can build upon.
These datasets—spanning threat intelligence, common vulnerability enumerations, and supply-chain risk models—are, in a sense, a gift to firms tasked with untangling their vendor networks. They provide a taxonomy of risks, scenarios, and controls that can help firms create dependency maps and incident response protocols. But making use of them requires more than just downloading a spreadsheet or two. It demands a deliberate process of integrating these frameworks into day-to-day supply-chain management practices.
For instance, IT service providers might begin by cataloging all third-party software and hardware vendors, mapping these against NIST’s known vulnerability lists and threat profiles. This is no small undertaking. Dependencies often extend several layers deep, and visibility tends to deteriorate the further downstream one looks. A vendor may themselves be dependent on subcontractors or components that sit outside the immediate purview of the contracting firm. Here is where the NIST datasets help create structure—allowing firms to classify vendors based on the criticality of services provided, historical incident trends, and known exposure levels.
However, cataloging alone isn’t enough. The Act’s reporting provisions envision not just an inventory of risks but a readiness to act when incidents occur. This brings us to the matter of disclosure forms and processes. The law, while specifying the obligation, leaves firms some discretion in how they craft their reports—as long as these are timely, accurate, and sufficiently detailed to inform regulators and, where relevant, the public. A good incident disclosure form should, at a minimum, capture key elements: the nature of the incident (ransomware, data breach, service disruption), the supply-chain vector through which it occurred, detection date and method, immediate containment actions, and ongoing risk mitigation steps.
Designing such a form isn’t only about ticking regulatory boxes. The reality is that, in the heat of a cybersecurity incident, firms will need something practical—something that guides the internal dialogue between technical teams, compliance officers, and executives. The form should be simple enough to use under pressure yet robust enough to satisfy external scrutiny. It should allow space for uncertainty—because in the early hours of an incident, facts are often incomplete. And perhaps most importantly, it should embed prompts that force reflection: has this supply-chain vulnerability been communicated to other potentially affected partners? Has law enforcement or an appropriate agency been notified where necessary?
What complicates all this is that the supply-chain landscape itself is dynamic. Vendors change, new dependencies emerge as systems evolve, and threat actors continue to adapt. The risk maps built today will need constant updating—a fact that, in truth, leaves many firms struggling to strike the right balance between comprehensive oversight and manageable workload. It’s not uncommon to hear executives express quiet frustration at the sheer volume of data and relationships that now fall within their compliance remit. Yet, if anything, the Act has made clear that this is the new normal.
Interestingly, some firms are turning the compliance burden into an opportunity. By proactively disclosing incidents, even beyond the strict letter of the law, they seek to position themselves as trustworthy partners in an environment where reputational risk can eclipse financial penalties. This shift—from reluctant disclosure to strategic transparency—reflects an evolving understanding of cybersecurity not as a technical issue alone, but as a business imperative intertwined with brand, trust, and market positioning.
And as firms adapt, one suspects the Act itself is just the beginning. There is already chatter in policy circles about expanding disclosure requirements to encompass more granular risk data, or about standardizing incident reporting formats across sectors. How that plays out remains to be seen. For now, what’s clear is that supply-chain cybersecurity has moved from the margins of corporate governance to the heart of it—and that’s a shift no IT service provider can afford to ignore.
