CISA Sharing Law Delay Risks Undermining Vulnerability Hunting
Category:Policy & Governance
The temporary extension of the Cybersecurity Information Sharing Act of 2015 (CISA 2015) has drawn concern from lawmakers who warn that expiration could severely hinder vulnerability hunting operations. The law enables companies to share cyber threat data with government agencies without legal liability. Without it, cooperation between private firms and agencies like U.S. Cyber Command may break down. MITRE-relevant behaviors include T1592 (Gather Victim Network Information) and T1587 (Develop Capabilities) because threat data informs remediation across global infrastructure. Senators Mike Rounds and Gary Peters stress that the ability to share field-discovered vulnerabilities—especially those uncovered during hunt-forward missions abroad—is vital for collective defense. These missions identify exploitable flaws within allied systems, and without legal protections, companies may refuse to share patching information. This could limit the government’s ability to disseminate indicators across industry. The business impact includes slower remediation cycles, reduced visibility into ecosystem-wide threats, and increased regulatory exposure when companies withhold disclosure to avoid risk. This can degrade national cyber readiness and create larger exploit windows for adversaries. Additionally, the lack of consensus in Congress suggests uncertainty that may affect long-term security planning for enterprises operating in critical sectors. Mitigation includes maintaining structured internal vulnerability reporting pipelines, preparing for shifts in federal guidance, and participating in ISAC/ISAO communities. Organizations should track federal developments, review legal frameworks around data sharing, and ensure internal compliance teams are ready to adapt processes if liability protections change.
CORTEX Protocol Intelligence Assessment
Business Impact: Expiration of data-sharing protections may slow large-scale vulnerability remediation and reduce cooperative defense across sectors. Enterprises may face longer exposure to known threats. Technical Context: The law enables secure sharing of threat and vulnerability data discovered during hunt-forward missions. Loss of protections may hinder dissemination of IOCs and remediation guidance.
Strategic Intelligence Guidance
- Participate in ISACs and ISAOs to maintain data sharing even if federal protections lapse.
- Prepare legal and compliance teams for shifts in liability exposure.
- Strengthen internal vulnerability disclosure and tracking mechanisms.
- Monitor legislative developments that impact cyber threat cooperation.
Targets
Intelligence Source: CISA Sharing Law Delay Risks Undermining Vulnerability Hunting | Nov 19, 2025