CIRCIA Isn’t Just for the Big Guys

 Why SMBs Need to Prepare for Cyber Incident Reporting—Now 

The Cyber Incident Reporting Clock Is Ticking

The cybersecurity landscape is constantly evolving, but few changes have the potential to shake up the status quo like the forthcoming Cyber Incident Reporting for Critical Infrastructure Act, or CIRCIA. Signed into law in 2022, CIRCIA will require “covered entities” to report specific cyber incidents to CISA within 72 hours and any ransom payments within 24 hours.

The clock starts as soon as you reasonably believe an incident has occurred. If you pay a ransom within that initial 72-hour window, you can summarize both the incident and the payment in a joint report, which is still due within 72 hours. While mandatory compliance is not yet in effect, CISA is finalizing the rule, and enforcement is expected to take place in 2026. The message is clear: organizations of all sizes must prepare.

Not Just a “Big Company” Problem Anymore

If you run a small or mid-sized business, you might think this is just another regulation aimed at the Fortune 500. This time, it is different.

CISA’s proposed rules cover more than 300,000 organizations, including many SMBs in healthcare, technology, insurance, and other regulated industries. The days of assuming “we’re too small to matter” are behind us. Digital transformation, outsourcing, and interconnected supply chains mean that small and midsize companies are now key infrastructure for their clients, partners, and the broader economy.

This Isn’t New—But the Stakes Are Higher

Here is the real twist. Incident response, reporting, and solid security hygiene have always been best practices. What has changed is the visibility and expectation now placed on SMBs. As organizations become critical links in larger ecosystems, both regulators and customers are demanding more transparency and accountability.

In other words, CIRCIA is not introducing a brand-new concept. It formalizes and enforces what leading organizations have already been doing. If you provide essential services, store sensitive data, or enable operations for others, you are already in the spotlight.

What CIRCIA Requires (and when)

CIRCIA will require covered organizations to report cyber incidents to CISA within 72 hours and ransom payments within 24 hours. The clock starts when you reasonably believe an incident has occurred. If a ransom is paid during that 72-hour window, you can summarize both the incident and the payment in a joint report, which is still due within 72 hours.

As of September 2025, these requirements are not yet in effect, but the final rule is expected soon, with enforcement likely to begin in 2026.

Why SMBs Can’t Afford to Wait

For years, incident response and proactive security have been “should-dos” for SMBs, encouraged by clients and partners but rarely enforced by law. CIRCIA is changing that. Suppose you are a managed service provider (MSP), a healthcare SaaS, or a security vendor supporting larger organizations. In that case, your ability to detect, respond to, and report incidents is no longer just your responsibility. It is now a business necessity.

The risk is not just about legal compliance. It is about reputation, operations, and relationships. Being caught off guard by a cyber incident or scrambling to figure out how to report it can erode client trust and jeopardize your place in the supply chain.

What You Should Do Now

1. Assess your current state:
   Review your incident response plan and reporting workflows to ensure they are up to date. Ensure you have clear documentation and that roles and responsibilities are well-defined.
2. Identify gaps:
   Look for missing policies, unclear communication channels, or inadequate training.
3. Build or refine workflows:
   Establish who is responsible for detecting, escalating, and reporting incidents. Make sure you can gather the correct information quickly.
4. Test your readiness:
   Conduct tabletop exercises to simulate incidents and reporting procedures. Make sure everyone knows what to do and when to do it.
5. Train your team:
   Even if your company is small, everyone should know how to recognize and report suspicious activity.
6. Document everything:
   Keep records of your response efforts and decisions to document your progress. Good documentation is not just for audits; it is your best defense in a crisis.

CAP Security Solutions Can Help

I have been advocating for proactive security and clear reporting long before CIRCIA was on the horizon. Preparation is the best way to avoid panic and penalties when regulations go live. Whether you need help developing policies, refining your incident response plan, or training your team, CAP Security Solutions is here to help you get ahead of the curve.

To determine if you are ready for CIRCIA, schedule a discovery call at capsecurity.us or connect with me on LinkedIn for a complimentary consultation.

Don’t Wait for the Deadline

CIRCIA may not be enforced yet, but expectations are already shifting. SMBs are no longer flying under the radar. They are at the forefront of the nation’s cybersecurity posture. Don’t get caught off guard. Start preparing now and turn compliance into a competitive advantage.