The Cybersecurity Information Sharing Act of 2015 (“CISA 2015”), which provides liability protections and other safeguards for sharing certain cybersecurity information with the U.S. federal government and private entities, was reauthorized as part of the funding bill enacted on February 3, 2026. CISA 2015’s information‑sharing provisions, which had been scheduled to sunset on January 30, 2026, will now remain in effect through September 30, 2026.

As we have previously discussed, CISA 2015 establishes a framework for sharing cyber threat indicators and defensive measures, and it offers several important protections for organizations that participate. These protections include Freedom of Information Act (“FOIA”) disclosure exemptions, limits on liability related to sharing, and safeguards against waiver of legal privileges. See our earlier posts from 2015 and 2016 for more background. The Consolidated Appropriations Act, 2026 reauthorizes the statute without substantive changes by simply updating the sunset date in 6 U.S.C. § 1510(a) to “September 30, 2026.”

With this extension, organizations can continue benefiting from the protections afforded by CISA 2015 when sharing qualified cyber information. Although there is some congressional interest in a longer-term reauthorization, it is unclear if those efforts will make progress in the coming year. We recommend organizations monitor future legislative developments to know whether Congress will reauthorize and possibly modify CISA 2015 beyond the new sunset date. Also, consider assessing whether your current cyber information sharing practices should continue without the benefit of the current protections from CISA 2015. 

Photo of Ashden Fein Ashden Fein

Ashden Fein is co-chair of Covington’s Data Privacy and Cybersecurity Practice. He advises clients on cybersecurity and national security matters, including crisis management and incident response, risk management and governance, government and internal investigations, and regulatory compliance. Ashden also serves as lead counsel…

Ashden Fein is co-chair of Covington’s Data Privacy and Cybersecurity Practice. He advises clients on cybersecurity and national security matters, including crisis management and incident response, risk management and governance, government and internal investigations, and regulatory compliance. Ashden also serves as lead counsel in criminal, civil, and internal investigations involving cybersecurity, insider risk, and U.S. national security issues.

Ashden regularly counsels clients on preparing for and responding to cyber-based attacks, assessing security controls and practices for the protection of data and systems, developing and implementing cybersecurity risk management and governance programs, and complying with federal and state regulatory requirements. Ashden frequently supports clients as the lead investigator and crisis manager for global cyber and data security incidents, including data breaches involving personal data, advanced persistent threats targeting intellectual property across industries, state-sponsored theft of sensitive U.S. government information, extortion and ransomware, and destructive attacks.

Ashden also assists clients from across industries with leading internal investigations and responding to government inquiries related to U.S. national security and insider risks. He frequently represents government contractors in False Claims Act matters involving cybersecurity and national security. Additionally, he advises aerospace, defense, and intelligence contractors on security compliance under U.S. national security laws and regulations including, among others, the National Industrial Security Program (NISPOM), U.S. government cybersecurity regulations, FedRAMP, and requirements related to supply chain security.

Before joining Covington, Ashden served on active duty in the U.S. Army as a Military Intelligence officer and prosecutor specializing in cybercrime and national security investigations and prosecutions — to include serving as the lead trial lawyer in the prosecution of Private Chelsea (Bradley) Manning for the unlawful disclosure of classified information to Wikileaks. Ashden is a retired U.S. Army officer.

Photo of Jess Gonzalez Valenzuela Jess Gonzalez Valenzuela

Jess Gonzalez Valenzuela (they/them and she/her) is an associate in the firm’s San Francisco office, specializing in the Data Privacy and Cybersecurity Practice Group. Jess assists clients with cybersecurity issues such as incident response, risk management, internal investigations, and regulatory compliance. Additionally, Jess…

Jess Gonzalez Valenzuela (they/them and she/her) is an associate in the firm’s San Francisco office, specializing in the Data Privacy and Cybersecurity Practice Group. Jess assists clients with cybersecurity issues such as incident response, risk management, internal investigations, and regulatory compliance. Additionally, Jess supports clients navigating complex data privacy challenges by offering regulatory compliance guidance tailored to specific business practices. Jess is also a member of the E-Discovery, AI, and Information Governance Practice Group and maintains an active pro bono practice.

Jess is committed to Diversity, Equity, and Inclusion (DEI) initiatives within the legal field. They are a member of Covington’s LGBTQ+ and Latino Firm Resource Groups, and serve as is co-lead for the First Generation Professionals Network and Disability and Neurodiversity Network in the San Francisco office.

Photo of Analese Bridges Analese Bridges

Analese Bridges is an associate in the firm’s Washington, DC office and a member of the Data Privacy and Cybersecurity and Advertising and Consumer Protection Practice Groups. She represents and advises clients on a range of cybersecurity, data privacy, and consumer protection issues…

Analese Bridges is an associate in the firm’s Washington, DC office and a member of the Data Privacy and Cybersecurity and Advertising and Consumer Protection Practice Groups. She represents and advises clients on a range of cybersecurity, data privacy, and consumer protection issues, including cyber and data security incident response and preparedness, cross-border privacy law, government and internal investigations, and regulatory compliance.

Photo of John Webster Leslie John Webster Leslie

Web Leslie advises clients on a broad range of challenges and opportunities at the intersection of technology and security, including investigations, regulatory, and transactional matters related to cybersecurity, national security, critical infrastructure, and data privacy.

In his white-collar practice, Web helps clients navigate…

Web Leslie advises clients on a broad range of challenges and opportunities at the intersection of technology and security, including investigations, regulatory, and transactional matters related to cybersecurity, national security, critical infrastructure, and data privacy.

In his white-collar practice, Web helps clients navigate both government and internal investigations. He specializes in complex civil and criminal investigations related to alleged government contracts fraud and other cybersecurity-related allegations under the False Claims Act, FTC Act, and equivalent state laws. Additionally, Web assists clients in responding to a variety of cyber incidents, ranging from intrusions and extortion by advanced persistent threats to business email compromises and large-scale data breaches. Web also helps clients investigate insider threat activity and potential noncompliance with regulatory and contractual cybersecurity requirements.

In his advisory and transactional practice, Web assists clients across a wide range of industries and critical infrastructure sectors manage risk in an evolving regulatory landscape. He regularly advises on cybersecurity compliance and best practices, information security program development, incident response preparedness, insider threat risks, third-party risk management, and international cyber regulations, among other areas. Web also advises clients on a variety of government and industry standards, including the NIST Cybersecurity Framework 2.0, NIST SP 800-53, NIST SP 800-171, FedRAMP and state equivalents (e.g., GovRAMP, TX-RAMP), CJIS, ISO/IEC standards (e.g., ISO 27001), SOC2 Type 2, and other sector-specific requirements (e.g., HIPAA Security Rule, PCI DSS, DFARS Clause 252.204-7012, NERC Critical Infrastructure Protection).

In addition to his regular practice, Web counsels pro bono clients on data breach, immigration, and criminal law matters.

Web previously served in government in different roles at the Department of Homeland Security (DHS), including at the National Protection and Programs Directorate—known today as the Cybersecurity and Infrastructure Security Agency (CISA)—where he specialized in cybersecurity and critical infrastructure protection, public-private partnerships, and interagency cyber operations. He also served as Special Assistant to the Secretary of Homeland Security.

Photo of Claire O'Rourke Claire O'Rourke

Working with emerging, national, and multinational companies and non-profits, Claire O’Rourke handles matters involving a range of data privacy and cybersecurity issues.

Claire works with clients in the technology, financial services, life sciences, and healthcare industries, among others. She provides strategic advice on…

Working with emerging, national, and multinational companies and non-profits, Claire O’Rourke handles matters involving a range of data privacy and cybersecurity issues.

Claire works with clients in the technology, financial services, life sciences, and healthcare industries, among others. She provides strategic advice on preparation for, response to, and legal obligations and risk mitigation after a cybersecurity incident. Claire also counsels clients on compliance with generally applicable and sector-specific federal and state privacy laws. She has assisted clients in drafting and reviewing privacy policies and terms of service, designing new products and services to comply with applicable privacy laws, and reviewing contract or other agreements for potential privacy issues.

Prior to practicing law, Claire was a congressional staffer and worked for a trade association that assists small businesses.