01-30_GENERALS_Fall25_PT - Flipbook - Page 15
Companies must develop incident
response strategies that account for both
jurisdictions.
The focus on supply chain security
in both frameworks creates additional
considerations. Bill C-8 requires
operators to assess and mitigate risks
from third-party products and services,
while CIRCIA emphasizes understanding
vulnerabilities exploited in incidents.
Organizations should implement robust
vendor risk management programs that
satisfy requirements in both jurisdictions.
Preparing for Compliance
Organizations should begin by assessing
whether they qualify as designated operators under Bill C-8 or covered entities
under CIRCIA. Conducting readiness
assessments of current cybersecurity posture against anticipated requirements will
identify gaps requiring attention.
Contracts with vendors and thirdparty service providers need review to
ensure alignment with new disclosure
obligations and information-sharing
protocols. Data localization requirements
under Bill C-8 mandate that cybersecurity
records remain within Canada,
necessitating potential changes to data
storage practices.
Executive leadership and boards of
directors require education about these
regulatory changes. Cybersecurity has
evolved from an information technology
issue to a regulated compliance matter
with 昀椀nancial, legal, and reputational
consequences. Organizations should
engage cybersecurity and legal
advisors familiar with these regulatory
frameworks to develop practical
compliance strategies.
Legislative Outlook
Both Bill C-8 and the CIRCIA Final Rule
represent the new reality of cybersecurity
governance in North America. Bill C-8
must complete the full legislative process
through House and Senate readings and
committee review. However, given the
substantial progress of its predecessor,
Bill C-26, which advanced to third reading
in the Senate, observers anticipate relatively swift passage.
The message from both governments
is clear: critical infrastructure protection
is a strategic imperative, and voluntary
best practices are no longer su昀케cient.
Organizations must demonstrate
resilience, accountability, and compliance
through documented cybersecurity
programs and timely incident reporting.
Canadian associations should
encourage members to monitor
legislative developments closely,
assess their potential designation
status, and begin implementing the
robust cybersecurity frameworks these
regulations will require. Proactive
preparation will ease the transition when
these requirements take e昀昀ect.
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