CIRCIA Compliance Is Coming: What MSPs and CISOs Need to Know Now

Don’t wait for CIRCIA compliance and enforcement. See how MSPs and CISOs can prepare now for new 24–72-hour cyber incident reporting rules coming in 2026.

The cybersecurity landscape is about to shift—especially for MSPs supporting critical infrastructure. The Cyber Incident Reporting for Critical Infrastructure Act (CIRCIA), signed into law in 2022, is gearing up for full implementation. And when it hits, it won’t be business as usual for service providers managing high-stakes environments like legal, financial services or healthcare.

Cybersecurity and Infrastructure Security Agency (CISA) was originally mandated to issue a final rule by October 2025, per statutory deadlines. However, as of September 2025, that deadline has been pushed to May 2026. This delay allows the agency more time to incorporate public feedback, streamline requirements and reconcile CIRCIA with other overlapping regulations. Does that mean you should wait?

The answer is absolutely NO.

In this blog we’ll cover what MSPs should be doing now (if not already), how they should be preparing their clients for the upcoming changes and why waiting until enforcement begins could cost you, and your clients. In this article, we’ll talk about:

• What CIRCIA Compliance is and why it matters

• How MSPs and CISOs should prepare for upcoming compliance requirements

• Which types of clients (e.g., energy, finance, healthcare) are considered critical infrastructure under CIRCIA

• What reporting obligations exist—timelines (24–72 hours), data collection and notifications

• How to build incident response workflows that meet federal guidelines

• Why employee training on incident escalation and forensic handoff is critical

• What operational shifts MSPs should expect as CIRCIA enforcement begins

While the final rules are still being drafted by CISA (Cybersecurity and Infrastructure Security Agency), one thing is clear: MSPs and CISOs will play a critical role in ensuring timely, accurate incident reporting.

What is CIRCIA Compliance and Why It Matters Now

Although CIRCIA was signed into law in 2022, the urgency is rising because final rules are being finalized now—and enforcement is just around the corner.

CISA released proposed rules in 2024, final regulations were expected in 2025 and have now been extended to 2026

Once enacted, covered entities will have just 24–72 hours to report qualifying incidents

MSPs will play a central role in helping clients assess, escalate, and comply quickly

Failure to prepare now could mean missed deadlines, legal exposure, or lost trust

The takeaway: This is the last window for MSPs to build incident workflows and train teams before reporting becomes mandatory.

Understand Who Reports What—and When

CIRCIA requires certain covered entities to report substantial cyber incidents within 72 hours and ransomware payments within 24 hours. That clock starts ticking fast—and the penalties for non-compliance could be steep.

For example, if a ransomware attack compromises a private equity firm’s deal pipeline or investor communication platform, the firm—and its MSP—may have only hours to assess the scope, determine whether sensitive financial or regulatory data was affected and file a report with the appropriate federal agency. Delays could expose the firm to compliance violations, SEC scrutiny or reputational fallout with limited partners.

MSPs need to help clients identify whether they fall under “covered critical infrastructure,” and clarify:

• What qualifies as a reportable incident

• Who is responsible for submitting the report

• What information must be included

Too often, critical stakeholders don’t even know they’re subject to federal reporting until after a breach has occurred. That’s a risk you can’t afford.

Build a Bulletproof Reporting Workflow to Prepare for CIRCIA Compliance

When a cyber event occurs, chaos can follow. Your role as an MSP is to help your clients cut through the confusion and act quickly, decisively and in compliance.

Start by developing an internal workflow that clearly outlines:

• What incident data must be captured

• Who is responsible for reviewing and verifying that data

• Which internal and external parties need to be notified (and in what order)

• How incident timelines are tracked

Document everything. A well-crafted incident response plan is no longer optional—it’s a compliance necessity.

Train Your Team on CIRCIA Compliance (And Theirs)

CIRCIA is going to demand a higher level of discipline and communication from everyone involved. That means upskilling your teams—not just in technical forensics, but also in escalation and communication protocols.

Key areas to focus on include:

• Identifying and escalating incidents rapidly

• Coordinating with legal/compliance teams to review reporting obligations

• Collecting forensic artifacts in a way that preserves integrity

• Knowing when to bring in external specialists or tools

This training should extend to your clients’ teams as well—especially if they're handling any reporting directly.

Prepare for Tighter Timelines and Higher Stakes

Perhaps the biggest change CIRCIA will bring is a fundamental shift in how cyber incidents are prioritized and managed.

The new deadlines will force organizations to treat reporting and mitigation as top-priority actions—not as back-burner tasks after recovery is underway. For MSPs, this means balancing business continuity, technical remediation and regulatory compliance simultaneously.

It’s a heavy lift. But it’s also an opportunity to differentiate yourself as a strategic partner, not just a service provider.

Final Thoughts on CIRCIA Compliance Urgency

CIRCIA is a wake-up call for the entire cybersecurity ecosystem. For MSPs, it’s a chance to lead the charge—helping clients meet new federal obligations, while strengthening their own incident readiness in the process.

• Immediate steps for MSPs:

• Identify which clients may be subject to CIRCIA

• Review and update incident response plans

• Build or refine internal reporting workflows

• Train internal teams and client contacts

• Stay ahead of final CISA rulemaking

Don’t wait for final rules to be released. Start updating your playbooks, training your teams and building your reporting infrastructure now. When the clock starts ticking after an incident, your ability to respond quickly and correctly will define your value—and your reputation.

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