The Department of Defense Introduces Cybersecurity Risk Management Construct (CSRMC) to Enhance Cyber Defense

The Department of Defense (DoD) has introduced the Cybersecurity Risk Management Construct (CSRMC), a new framework that replaces the legacy Risk Management Framework. CSRMC emphasizes automation, continuous monitoring, and real-time visibility, marking a significant shift away from static, checklist-driven processes.

The Department of Defense (DoD) recently published in the Federal Register its long-awaited final rule (the Rule) amending the Defense Federal Acquisition Regulation Supplement (DFARS) to formally implement the Cybersecurity Maturity Model Certification (CMMC) program. The Rule, effective November 10, 2025, will move CMMC from a policy framework into binding contractual obligations for most defense contractors.

AI policy for the health and life sciences sector has continued to take shape. Building on recent activity, on July 23, 2025, the White House released its highly-anticipated AI Action Plan, setting forth the Trump Administration’s recommended policy actions to accelerate AI innovation and build American AI infrastructure. This Plan recommends policies that would promote AI adoption, the creation of “AI-ready” scientific datasets and the establishment of real-world AI evaluation systems by and for the health care and life sciences industries.

The U.S. Court of Appeals for the Sixth Circuit has upheld a 2024 Federal Communications Commission (FCC) Order that significantly broadens telecommunications carriers’ breach notification obligations. This decision, issued on August 14, 2025, in Ohio Telecom Association v. FCC, mandates that carriers disclose breaches of any customer personally identifiable information (PII), not just customer proprietary network information (CPNI), and applies to both inadvertent and intentional breaches.²

On January 16, 2025, the Federal Trade Commission (FTC) issued a Final Rule updating the Children’s Online Privacy Protection (COPPA) Rule, significantly expanding compliance obligations for online services that collect, use, or disclose personal information from children under 13.¹ The amendments impose new restrictions on targeted advertising, add data security requirements, refine parental consent mechanisms, and introduce additional compliance measures.

On January 8, 2025, the DOJ published a final rule prohibiting and restricting certain transactions that could allow persons from countries of concern, such as China, access to bulk sensitive personal data of U.S. citizens or to U.S. government-related data (regardless of volume).

On January 17, 2025, days before the inauguration, former President Joe Biden issued an executive order titled Strengthening and Promoting Innovation in the Nation's Cybersecurity (EO 14144). Building on previous efforts, including Executive Order 14028, this directive seeks to bolster cybersecurity across federal systems, supply chains and critical infrastructure from adversarial nations, particularly from the People’s Republic of China (PRC).

UPDATE: The California Privacy Protection Agency (CPPA) has extended the deadline for submitting public comments from January 14 to February 19, 2025, in response to the recent California wildfires. This extension aims to afford stakeholders additional time to provide comprehensive and detailed feedback, considering the significant challenges posed by the wildfires.