SEC Form 8-K Item 1.05 Draft: Cyber Incident Materiality & Disclosure

For general counsel and CISOs at US-listed companies: a materiality analysis outline, a draft Item 1.05 disclosure that avoids operational detail, a four-business-day clock and an amendment checklist for follow-up filings.

Use cases

• A GC and CISO preparing an Item 1.05 8-K within hours of a materiality decision.
• A disclosure committee needing a documented materiality factor analysis.
• A securities team preparing the 8-K/A when new facts about data accessed emerge.