Brief Plan: NIS2, SEC Cybersecurity Rules, and PCI DSS 4.0 (2024–2025)
This plan assigns four high-priority briefs to the Compliance and Governance pillars, keyed to dated milestones for NIS2, the SEC cybersecurity disclosure rules, and PCI DSS 4.0. Publication windows backcast from the regulatory deadlines so readers receive…
This plan assigns four high-priority briefs to the Compliance and Governance pillars, keyed to dated milestones for NIS2, the SEC cybersecurity disclosure rules, and PCI DSS 4.0. Publication windows backcast from the regulatory deadlines so readers receive guidance before enforcement inflection points.
Brief lineup and publication windows
| Brief | Pillar | Milestone | Publication window | Angle and deliverables |
|---|---|---|---|---|
| NIS2 national transposition sprint | Compliance | 2024-10-17 — EU Member States must transpose NIS2 into national law | 2024-09-23 to 2024-10-04 | Map confirmed national laws (e.g., DE IT-SiG 3.0 draft, FR draft ordonnance) and summarize scope tiers, 24h/72h reporting clock, and supervisory powers. Include a checklist for operators of essential/important entities to evidence readiness by transposition day. |
| NIS2 first 90 days of enforcement | Governance | Q4 2024 to Q1 2025 — national authorities begin audits and incident reporting under transposed laws | 2024-12-02 to 2024-12-20 | Capture initial supervisory guidance (ENISA templates, national CSIRTs), early fines or remedial orders, and observed bottlenecks in 24-hour incident notice workflows. Provide board-level oversight questions for ICT supply-chain assurance. |
| SEC cyber disclosure year-two posture | Governance | FY 2024 Form 10-K filings (for calendar-year issuers due Feb–Mar 2025) must include Item 106 risk management and governance disclosures; Item 1.05 Form 8-K incident reporting ongoing (SRCs compliance began 2024-06-15) | 2025-01-13 to 2025-02-07 | Assess how year-one filings handled materiality thresholds, board oversight, and third-party incident coverage. Offer updated control language and 8-K decision trees that align with SEC adopting release guidance and Enforcement statements. |
| PCI DSS 4.0 future-dated controls deadline | Compliance | 2025-03-31 — future-dated PCI DSS 4.0 requirements (e.g., targeted risk analyses, authentication changes, customized approach docs) become mandatory; v3.2.1 already retired 2024-03-31 | 2025-02-03 to 2025-02-21 | Provide a last-mile remediation map by requirement family (11.6.1, 12.5.2, 8.3.7/8, 3.4.2). Include ROC/SAQ evidence checklists and QSA coordination timelines for merchants and service providers. |
| PCI DSS 4.0 merchant peak-season lessons | Compliance | Post–2024 holiday peak under PCI DSS 4.0 baseline; future-dated controls lock on 2025-03-31 | 2025-01-06 to 2025-01-24 | Capture what changed in peak-season control execution after v3.2.1 sunset (network segmentation, MFA, anti-phishing). Publish runbook updates for log review thresholds and incident response drill cadence before the March 2025 enforcement gate. |
QA and evidence plan
- Primary sources only: Use the NIS2 Directive (EU 2022/2555), Member State transposition laws as they are enacted, ENISA guidance, the SEC adopting release (Rel. 33-11216), staff statements, and PCI SSC v4.0 documentation (RTP, FAQs, ROC/SAQ templates). Avoid secondary summaries unless they cite primary documents.
- Citation depth: Minimum of two citations per brief: one to the governing rule text and one to a competent authority or scheme owner clarification (e.g., ENISA, SEC Division of Corporation Finance, PCI SSC FAQ).
- Data freshness: Re-verify milestone dates and effective periods one week before publication windows open; update if any Member State slips NIS2 transposition or if PCI SSC releases new FAQs.
- Peer review: Route drafts through Compliance desk review plus legal counsel spot check for SEC and EU content. Require red-team pass for incident reporting decision trees to avoid overgeneralization.
- Pre-publish checks: Run
scripts/check_feed_lengths.pyandscripts/validate/check_citations.pyonce briefs are drafted to enforce Zeph Tech word-count and citation availability standards.