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July 17, 2024

What you need to know about the new SEC Cybersecurity rules

In July 2023, the U.S. Securities and Exchange Commission (SEC) adopted new rules concerning cybersecurity incidents and disclosures. This blog describes the new rules and demonstrates how Darktrace can help organizations achieve compliance with these standards.
Inside the SOC
Darktrace cyber analysts are world-class experts in threat intelligence, threat hunting and incident response, and provide 24/7 SOC support to thousands of Darktrace customers around the globe. Inside the SOC is exclusively authored by these experts, providing analysis of cyber incidents and threat trends, based on real-world experience in the field.
Written by
Kendra Gonzalez Duran
Principal Analyst
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17
Jul 2024

What is new in 2023 to SEC cybersecurity rules?

Form 8-K Item 1.05: Requiring the timely disclosure of material cybersecurity incidents.

Regulation S-K item 106: requiring registrants’ annual reports on Form 10-K to address cybersecurity risk management, strategy, and governance processes.

Comparable disclosures are required for reporting foreign private issuers on Forms 6-K and 20-F respectively.

What is Form 8-K Item 1.05 SEC cybersecurity rules?

Form 8-K Item 1.05 requires the following to be reported within four business days from when an incident is determined to be “material” (1), unless extensions are granted by the SEC under certain qualifying conditions:

“If the registrant experiences a cybersecurity incident that is determined by the registrant to be material, describe the material aspects of the nature, scope, and timing of the incident, and the material impact or reasonably likely material impact on the registrant, including its financial condition and results of operations.” (2, 3)

How does the SEC define cybersecurity incident?

Cybersecurity incident defined by the SEC means an unauthorized occurrence, or a series of related unauthorized occurrences, on or conducted through a registrant’s information systems that jeopardizes the confidentiality, integrity, or availability of a registrant’s information systems or any information residing therein. (4)

How can Darktrace assist in the process of disclosing incidents to the SEC?

Accelerate reporting

Darktrace’s Cyber AI Analyst generates automated reports that synthesize discrete data points potentially indicative of cybersecurity threats, forming reports that provide an overview of the evolution and impact of a threat.

Thus, when a potential threat is identified by Darktrace, AI Analyst can quickly compile information that organizations might include in their disclosure of an occurrence they determined to be material, including the following: incident timelines, incident events, incident summary, related model breaches, investigation process (i.e., how Darktrace’s AI conducted the investigation), linked incident events, and incident details. The figure below illustrates how Darktrace compiles and presents incident information and insights in the UI.

Overview of information provided in an ‘AI Analyst Report’ that could be relevant to registrants reporting a material cybersecurity incident to the SEC
Figure 1: Overview of information provided in an ‘AI Analyst Report’ that could be relevant to registrants reporting a material cybersecurity incident to the SEC

It should be noted that Instruction 4 to the new Form 8-K Item 1.05 specifies the “registrant need not disclose specific or technical information about its planned response to the incident or its cybersecurity systems, related networks and devices, or potential system vulnerabilities in such detail as would impede the registrant’s response or remediation of the incident” (5).

As such, the incident report generated by Darktrace may provide more information, including technical details, than is needed for the 8-K disclosure. In general, users should take appropriate measures to ensure that the information they provide in SEC reports meets the requirements outlined by the relevant regulations. Darktrace cannot recommend that an incident should be reported, nor report an incident itself.

Determine if a cybersecurity incident is material

Item 1.05 requires registrants to determine for themselves whether cybersecurity incidents qualify as ‘material’. This involves considerations such as ‘the nature scope and timing of the incident, and the material impact or reasonably likely material impact on the registrant, including its financial condition and results of operations.’

While it is up to the registrant to determine, consistent with existing legal standards, the materiality of an incident, Darktrace’s solution can provide relevant information which might aid in this evaluation. Darktrace’s Threat Visualizer user interface provides a 3-D visualization of an organization’s digital environment, allowing users to assess the likely degree to which an attack may have spread throughout their digital environment. Darktrace Cyber AI Analyst identifies connections among discrete occurrences of threatening activity, which can help registrants quickly assess the ‘scope and timing of an incident'.

Furthermore, in order to establish materiality it would be useful to understand how an attack might extend across recipients and environments. In the image below, Darktrace/Email identifies how a user was impacted across different platforms. In this example, Darktrace/Email identified an attacker that deployed a dual channel social engineering attack via both email and a SaaS platform in an effort to acquire login credentials. In this case, the attacker useding a legitimate SharePoint link that only reveals itself to be malicious upon click. Once the attacker gained the credentials, it proceeded to change email rules to obfuscate its activity.

Darktrace/Email presents this information in one location, making such investigations easier for the end user.

Darktrace/Email indicating a threat across SaaS and email
Figure 2: Darktrace/Email indicating a threat across SaaS and email

What is regulation S-K item 106 of the SEC cybersecurity rules?

The new rules add Item 106 to Regulation S-K requiring registrants to disclose certain information regarding their risk management, strategy, and governance relating to cybersecurity in their annual reports on Form 10-K. The new rules add Item 16K to Form 20-F to require comparable disclosure by [foreign private issuers] in their annual reports on Form 20-F. (6)

SEC cybersecurity rules: Risk management

Specifically, with respect to risk management, Item 106(b) and Item 16K(b) require registrants to describe their processes, if any, for assessing, identifying, and managing material risks from cybersecurity threats, as well as whether any risks from cybersecurity threats, including as a result of any previous cybersecurity incidents, have materially affected or are reasonably likely to materially affect them. The new rules include a non-exclusive list of disclosure items registrants should provide based on their facts and circumstances. (6)

SEC cybersecurity rules: Governance

With respect to governance, Item 106 and Item 16K require registrants to describe the board of directors’ oversight of risks from cybersecurity threats (including identifying any board committee or subcommittee responsible for such oversight) and management’s role in assessing and managing material risks from cybersecurity threats. (6)

How can Darktrace solutions aid in disclosing their risk management, strategy, and governance related to cybersecurity?

Impact scores

Darktrace End-to-End (E2E) leverages AI to understand the complex relationships across users and devices to model possible attack paths, giving security teams a contextual understanding of risk across their digital environments beyond isolated CVEs or CVSS scores. Additionally, teams can prioritize risk management actions to increase their cyber resilience through the E2E Advisory dashboard.

Attack paths consider:

  • Potential damages: Both the potential consequences if a given device was compromised and its immediate implications on other devices.
  • Exposure: Devices' level of interactivity and accessibility. For example, how many emails does a user get via mailing lists and from what kind of sources?
  • Impact: Where a user or asset sits in terms of the IT or business hierarchy and how they communicate with each other. Darktrace can simulate a range of possible outcomes for an uncertain event.
  • Weakness: A device’s patch latency and difficulty, a composite metric that looks at attacker MITRE methods and our own scores to determine how hard each stage of compromise is to achieve.

Because the SEC cybersecurity rules require “oversight of risks from cybersecurity threats” and “management’s role in assessing and managing material risks from cybersecurity threats” (6), the scores generated by Darktrace E2E can aid end-user’s ability to identify risks facing their organization and assign responsibilities to address those risks.

E2E attack paths leverage a deep understanding of a customer’ digital environment and highlight potential attack routes that an attacker could leverage to reach critical assets or entities. Difficulty scores (see Figure 5) allow security teams to measure potential damage, exposure, and impact of an attack on a specific asset or entity.

An example of an attack path in a digital environment
Figure 3: An example of an attack path in a digital environment

Automatic executive threat reports

Darktrace’s solution automatically produces Executive Threat Reports that present a simple visual overview of model breaches (i.e., indicators of unusual and threatening behaviors) and activity in the network environment. Reports can be customized to include extra details or restricted to high level information.

These reports can be generated on a weekly, quarterly, and yearly basis, and can be documented by registrants in relation to Item 106(b) to document parts of their efforts toward assessing, identifying, and managing material risks from cybersecurity threats.

Moreover, Cyber AI Analyst incident reports (described above) can be leveraged to document key details concerning significant previous incidents identified by the Darktrace solution that the registrant determined to be ‘material’.

While the disclosures required by Item 106(c) relate to the governance processes by which the board of directors, the management, and other responsible bodies within an organization oversee risks resulting from cybersecurity threats, the information provided by Darktrace’s Executive Threat Reports and Cyber AI Analyst incident reports can also help relevant stakeholders communicate more effectively regarding the threat landscape and previous incidents.

DISCLAIMER

The material above is provided for informational purposes only. This summary does not constitute legal or compliance advice, recommendations, or guidance. Darktrace encourages you to verify the contents of this summary with your own advisors.

References

  1. Note that the rule does not set forth any specific timeline between the incident and the materiality determination, but the materiality determination should be made without unreasonable delay.
  2. https://www.sec.gov/files/form8-k.pdf
  3. https://www.sec.gov/news/press-release/2023-139
  4. https://www.ecfr.gov/current/title-17/chapter-II/part-229
  5. https://www.sec.gov/files/form8-k.pdf
  6. https://www.sec.gov/corpfin/secg-cybersecurity
Inside the SOC
Darktrace cyber analysts are world-class experts in threat intelligence, threat hunting and incident response, and provide 24/7 SOC support to thousands of Darktrace customers around the globe. Inside the SOC is exclusively authored by these experts, providing analysis of cyber incidents and threat trends, based on real-world experience in the field.
Written by
Kendra Gonzalez Duran
Principal Analyst

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May 1, 2026

How email-delivered prompt injection attacks can target enterprise AI – and why it matters

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What are email-delivered prompt injection attacks?

As organizations rapidly adopt AI assistants to improve productivity, a new class of cyber risk is emerging alongside them: email-delivered AI prompt injection. Unlike traditional attacks that target software vulnerabilities or rely on social engineering, this is the act of embedding malicious or manipulative instructions into content that an AI system will process as part of its normal workflow. Because modern AI tools are designed to ingest and reason over large volumes of data, including emails, documents, and chat histories, they can unintentionally treat hidden attacker-controlled text as legitimate input.  

At Darktrace, our analysis has shown an increase of 90% in the number of customer deployments showing signals associated with potential prompt injection attempts since we began monitoring for this type of activity in late 2025. While it is not always possible to definitively attribute each instance, internal scoring systems designed to identify characteristics consistent with prompt injection have recorded a growing number of high-confidence matches. The upward trend suggests that attackers are actively experimenting with these techniques.

Recent examples of prompt injection attacks

Two early examples of this evolving threat are HashJack and ShadowLeak, which illustrate prompt injection in practice.

HashJack is a novel prompt injection technique discovered in November 2025 that exploits AI-powered web browsers and agentic AI browser assistants. By hiding malicious instructions within the URL fragment (after the # symbol) of a legitimate, trusted website, attackers can trick AI web assistants into performing malicious actions – potentially inserting phishing links, fake contact details, or misleading guidance directly into what appears to be a trusted AI-generated output.

ShadowLeak is a prompt injection method to exfiltrate PII identified in September 2025. This was a flaw in ChatGPT (now patched by OpenAI) which worked via an agent connected to email. If attackers sent the target an email containing a hidden prompt, the agent was tricked into leaking sensitive information to the attacker with no user action or visible UI.

What’s the risk of email-delivered prompt injection attacks?

Enterprise AI assistants often have complete visibility across emails, documents, and internal platforms. This means an attacker does not need to compromise credentials or move laterally through an environment. If successful, they can influence the AI to retrieve relevant information seamlessly, without the labor of compromise and privilege escalation.

The first risk is data exfiltration. In a prompt injection scenario, malicious instructions may be embedded within an ordinary email. As in the ShadowLeak attack, when AI processes that content as part of a legitimate task, it may interpret the hidden text as an instruction. This could result in the AI disclosing sensitive data, summarizing confidential communications, or exposing internal context that would otherwise require significant effort to obtain.

The second risk is agentic workflow poisoning. As AI systems take on more active roles, prompt injection can influence how they behave over time. An attacker could embed instructions that persist across interactions, such as causing the AI to include malicious links in responses or redirect users to untrusted resources. In this way, the attacker inserts themselves into the workflow, effectively acting as a man-in-the-middle within the AI system.

Why can’t other solutions catch email-delivered prompt injection attacks?

AI prompt injection challenges many of the assumptions that traditional email security is built on. It does not fit the usual patterns of phishing, where the goal is to trick a user into clicking a link or opening an attachment.  

Most security solutions are designed to detect signals associated with user engagement: suspicious links, unusual attachments, or social engineering cues. Prompt injection avoids these indicators entirely, meaning there are fewer obvious red flags.

In this case, the intention is actually the opposite of user solicitation. The objective is simply for the email to be delivered and remain in the inbox, appearing benign and unremarkable. The malicious element is not something the recipient is expected to engage with, or even notice.

Detection is further complicated by the nature of the prompts themselves. Unlike known malware signatures or consistent phishing patterns, injected prompts can vary widely in structure and wording. This makes simple pattern-matching approaches, such as regex, unreliable. A broad rule set risks generating large numbers of false positives, while a narrow one is unlikely to capture the diversity of possible injections.

How does Darktrace catch these types of attacks?

The Darktrace approach to email security more generally is to look beyond individual indicators and assess context, which also applies here.  

For example, our prompt density score identifies clusters of prompt-like language within an email rather than just single occurrences. Instead of treating the presence of a phrase as a blocking signal, the focus is on whether there is an unusual concentration of these patterns in a way that suggests injection. Additional weighting can be applied where there are signs of obfuscation. For example, text that is hidden from the user – such as white font or font size zero – but still readable by AI systems can indicate an attempt to conceal malicious prompts.

This is combined with broader behavioral signals. The same communication context used to detect other threats remains relevant, such as whether the content is unusual for the recipient or deviates from normal patterns.

Ask your email provider about email-delivered AI prompt injection

Prompt injection targets not just employees, but the AI systems they rely on, so security approaches need to account for both.

Though there are clear indications of emerging activity, it remains to be seen how popular prompt injection will be with attackers going forward. Still, considering the potential impact of this attack type, it’s worth checking if this risk has been considered by your email security provider.

Questions to ask your email security provider

  • What safeguards are in place to prevent emails from influencing AI‑driven workflows over time?
  • How do you assess email content that’s benign for a human reader, but may carry hidden instructions intended for AI systems?
  • If an email contains no links, no attachments, and no social engineering cues, what signals would your platform use to identify malicious intent?

Visit the Darktrace / EMAIL product hub to discover how we detect and respond to advanced communication threats.  

Learn more about securing AI in your enterprise.

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About the author
Kiri Addison
Senior Director of Product

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April 30, 2026

Mythos vs Ethos: Defending in an Era of AI‑Accelerated Vulnerability Discovery

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Anthropic’s Mythos and what it means for security teams

Recent attention on systems such as Anthropic Mythos highlights a notable problem for defenders. Namely that disclosure’s role in coordinating defensive action is eroding.

As AI systems gain stronger reasoning and coding capability, their usefulness in analyzing complex software environments and identifying weaknesses naturally increases. What has changed is not attacker motivation, but the conditions under which defenders learn about and organize around risk. Vulnerability discovery and exploitation increasingly unfold in ways that turn disclosure into a retrospective signal rather than a reliable starting point for defense.

Faster discovery was inevitable and is already visible

The acceleration of vulnerability discovery was already observable across the ecosystem. Publicly disclosed vulnerabilities (CVEs) have grown at double-digit rates for the past two years, including a 32% increase in 2024 according to NIST, driven in part by AI even prior to Anthropic’s Mythos model. Most notably XBOW topped the HackerOne US bug bounty leaderboard, marking the first time an autonomous penetration tester had done so.  

The technical frontier for AI capabilities has been described elsewhere as jagged, and the implication is that Mythos is exceptional but not unique in this capability. While Mythos appears to make significant progress in complex vulnerability analysis, many other models are already able to find and exploit weaknesses to varying degrees.  

What matters here is not which model performs best, but the fact that vulnerability discovery is no longer a scarce or tightly bounded capability.

The consequence of this shift is not simply earlier discovery. It is a change in the defender-attacker race condition. Disclosure once acted as a rough synchronization point. While attackers sometimes had earlier knowledge, disclosure generally marked the moment when risk became visible and defensive action could be broadly coordinated. Increasingly, that coordination will no longer exist. Exploitation may be underway well before a CVE is published, if it is published at all.

Why patch velocity alone is not the answer

The instinctive response to this shift is to focus on patching faster, but treating patch velocity as the primary solution misunderstands the problem. Most organizations are already constrained in how quickly they can remediate vulnerabilities. Asset sprawl, operational risk, testing requirements, uptime commitments, and unclear ownership all limit response speed, even when vulnerabilities are well understood.

If discovery and exploitation now routinely precede disclosure, then patching cannot be the first line of defense. It becomes one necessary control applied within a timeline that has already shifted. This does not imply that organizations should patch less. It means that patching cannot serve as the organizing principle for defense.

Defense needs a more stable anchor

If disclosure no longer defines when defense begins, then defense needs a reference point that does not depend on knowing the vulnerability in advance.  

Every digital environment has a behavioral character. Systems authenticate, communicate, execute processes, and access resources in relatively consistent ways over time. These patterns are not static rules or signatures. They are learned behaviors that reflect how an organization operates.

When exploitation occurs, even via previously unknown vulnerabilities, those behavioral patterns change.

Attackers may use novel techniques, but they still need to gain access, create processes, move laterally, and will ultimately interact with systems in ways that diverge from what is expected. That deviation is observable regardless of whether the underlying weakness has been formally named.

In an environment where disclosure can no longer be relied on for timing or coordination, behavioral understanding is no longer an optional enhancement; it becomes the only consistently available defensive signal.

Detecting risk before disclosure

Darktrace’s threat research has consistently shown that malicious activity often becomes visible before public disclosure.

In multiple cases, including exploitation of Ivanti, SAP NetWeaver, and Trimble Cityworks, Darktrace detected anomalous behavior days or weeks ahead of CVE publication. These detections did not rely on signatures, threat intelligence feeds, or awareness of the vulnerability itself. They emerged because systems began behaving in ways that did not align with their established patterns.

This reflects a defensive approach grounded in ‘Ethos’, in contrast to the unbounded exploration represented by ‘Mythos’. Here, Mythos describes continuous vulnerability discovery at speed and scale. Ethos reflects an understanding of what is normal and expected within a specific environment, grounded in observed behavior.

Revisiting assume breach

These conditions reinforce a principle long embedded in Zero Trust thinking: assume breach.

If exploitation can occur before disclosure, patching vulnerabilities can no longer act as the organizing principle for defense. Instead, effective defense must focus on monitoring for misuse and constraining attacker activity once access is achieved. Behavioral monitoring allows organizations to identify early‑stage compromise and respond while uncertainty remains, rather than waiting for formal verification.

AI plays a critical role here, not by predicting every exploit, but by continuously learning what normal looks like within a specific environment and identifying meaningful deviation at machine speed. Identifying that deviation enables defenders to respond by constraining activity back towards normal patterns of behavior.

Not an arms race, but an asymmetry

AI is often framed as fueling an arms race between attackers and defenders. In practice, the more important dynamic is asymmetry.

Attackers operate broadly, scanning many environments for opportunities. Defenders operate deeply within their own systems, and it’s this business context which is so significant. Behavioral understanding gives defenders a durable advantage. Attackers may automate discovery, but they cannot easily reproduce what belonging looks like inside a particular organization.

A changed defensive model

AI‑accelerated vulnerability discovery does not mean defenders have lost. It does mean that disclosure‑driven, patch‑centric models no longer provide a sufficient foundation for resilience.

As vulnerability volumes grow and exploitation timelines compress, effective defense increasingly depends on continuous behavioral understanding, detection that does not rely on prior disclosure, and rapid containment to limit impact. In this model, CVEs confirm risk rather than define when defense begins.

The industry has already seen this approach work in practice. As AI continues to reshape both offense and defense, behavioral detection will move from being complementary to being essential.

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About the author
Andrew Hollister
Principal Solutions Engineer, Cyber Technician
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