On December 3, 2025, the European Commission published its first set of technical FAQs on the EU Cyber Resilience Act (‘CRA’). The CRA is an EU-wide law which lays down cybersecurity requirements for ‘products with digital elements’ (‘PDEs’), including IoT devices, hardware components, and certain software. It becomes fully applicable on December 11, 2027, with […]
Privacy & Cyber Regulatory Enforcement
DOJ Cybersecurity Enforcement Pace Shows No Signs of Slowing Down Going Into 2026
As 2025 drew to a close, the United States Department of Justice (DOJ) announced significant developments in cases relating to the allegedly deficient cybersecurity practices of two Department of Defense (DoD) contractors. These two cases suggest that the federal government will continue to make DFARS 7012 compliance for companies that process Controlled Unclassified Information (CUI) […]
Texas Court Blocks Smart TV Data Collection
A Texas state court has issued a temporary restraining order (“TRO”) blocking Hisense, a major Chinese smart TV manufacturer, from collecting data on the content viewers watch via Automatic Content Recognition (“ACR”) technology. Background The TRO follows lawsuits that Texas Attorney General (“AG”) Ken Paxton filed on December 15, 2025, against Hisense and four other […]
NYDFS Releases New Prescriptive FAQs on MFA
The New York Department of Financial Services (NYDFS) has released a new set of Frequently Asked Questions (FAQs 18–23) under 23 NYCRR Part 500, reinforcing its position that multifactor authentication (MFA) remains a critical component of a covered entity’s cybersecurity program. These FAQs provide highly prescriptive guidance, including clarifications on technical requirements for the “possession” […]
New EU Regulation Clarifies Cybersecurity Rules for IoT Devices and Other ‘Products with Digital Elements’
On November 28 2025, the European Commission adopted a regulation implementing the Cyber Resilience Act (‘CRA’) – an EU-wide law which lays down cybersecurity requirements for companies that design and sell ‘products with digital elements’. PDEs can take many forms including IoT devices, hardware components, and certain software. The CRA imposes cybersecurity obligations in connection […]