May 13, 2025

With the U.S. Securities and Exchange Commission (SEC) strengthening cybersecurity disclosure rules, organizations face increasing pressure to not only protect digital assets but also to demonstrate how cybersecurity is embedded in business operations. However, translating high-level regulatory requirements into everyday actions can be challenging. This is where a controls-focused cybersecurity strategy becomes essential—bridging the gap between governance and ground-level execution.

The SEC Cybersecurity Rules – A Quick Recap

The SEC’s cybersecurity rules require public companies to disclose material cybersecurity incidents and outline their cyber risk management strategies, governance practices, and oversight mechanisms. These rules emphasize:

• Timely and transparent incident reporting
• Board and executive accountability
• Description of cybersecurity risk management processes
• Integration of cybersecurity into enterprise risk management frameworks

Why the Gap Exists

While regulations demand high-level assurances, many security teams operate at the technical or tactical level—managing tools, alerts, and compliance checklists. These situations can lead to missing, incomplete or outdated documentation when teams are busy protecting the front lines. If this reflects your situation, the result is a disconnect between what regulators want to see and what teams are doing on the ground. Without a clear link between strategy and operations, you may struggle to demonstrate maturity, resilience, and accountability.

A Controls-Focused Strategy Bridges the Divide

A controls-focused cybersecurity program framework brings structure, clarity, and alignment to cyber programs. By mapping SEC rule requirements to specific, repeatable controls, you can:

• Translate the legal obligations into measurable operational actions
• Establish a unified control library aligned to business objectives
• Enable consistent and risk prioritized assessments and gap analysis
• Operationalize governance through evidence-based activities
• Facilitate board-level reporting with traceable control narratives

This approach ensures that cybersecurity isn’t just a checklist—it’s a strategic program rooted in business context (strategic objectives and risk tolerance) and regulatory alignment.

Clear Documentation is Key

Clarity on documentation gaps becomes more apparent when the SEC requirements are mapped to your organization. Policies and procedures provide structure when interpreting the requirements into operational baselines. Filling the gaps requires consistent processes facilitated by understandable documentation. Important areas to ensure are codified include:

• Stating the organization’s definition of materiality and how it relates to the SEC requirements
• Describing the boards’ role in oversight of cybersecurity risks
• Having an understandable process that encompasses risk assessment, identification and management

This documentation creates a baseline guide that sets expectations and provides a template for success. These documents create a tangible link between process and the organizations expectation for the handling of SEC requirements.

From Framework to Daily Execution

A controls focused framework links strategic priorities to frontline behaviors. For example:

• A policy requiring incident response readiness is mapped to controls like tabletop exercises and runbook validation.
• Asset management obligations are tied to daily tasks like scanning and inventory reconciliation.
• Disclosure readiness is supported by a communications protocol and legal alignment control.

Through this linkage, you can create a line of sight from boardroom objectives to operational execution—proving that they’re doing what they say and saying what they do.

Bridging the divide between SEC cybersecurity disclosure expectations and daily security operations requires more than good intentions. It requires a well-structured, controls-based approach that embeds accountability, consistency, and resilience across the enterprise. By creating well documented policies and procedures the SEC requirements become embedded in operations and governance. With the right framework in place, cybersecurity becomes a driver of trust, compliance, and strategic execution—not just a technical concern.

Is your cybersecurity program ready to align with SEC expectations? Start by evaluating your control framework and its connection to regulatory requirements. Consider conducting a risk assessment, maturity assessment or control mapping exercise to identify alignment gaps. Engage your legal, risk, IT, and security teams to design a unified control strategy that supports both governance and operational excellence. For tailored support, partner with experts who can help you develop and operationalize a controls-focused program that builds resilience and regulatory confidence.