“Effective communication begins with a factual summary tailored to predefined audiences, avoids PR spin, and adheres to regulatory requirements,” the guide states. “Service providers should be transparent by sharing what is known, unknown, and under investigation, while providing frequent, iterative updates as new information emerges or circumstances change.”

Security Leaders Weigh In

Joshua Marpet, Senior Product Security Consultant, Finite State:

Agencies advocating clear communication with timely updates, and avoiding PR style language is great! Useless, but great. Companies will use whatever language their crisis communications firm advocates for, because that is how they avoid liability. Firms with the backbone to be open, honest, and transparent are not exactly the majority out there. Unless you have communication strategies mandated, you have an perfect example of Marpet’s law: “Unless it’s mandated, or someone is paying for it, ain’t gonna happen.”

The EU CRA is a great example of mandating that type of communication. 24 hours, 72 hours, and 14 days, after an incident, there are specific types of communications with defined pieces of data you MUST give to the public and stakeholders. This is what we need, not best wishes and prayers.

Denis Calderone, CTO, Suzu Labs:

Let’s be honest, at a high level, none of this is new. Cross-functional incident teams, designated spokespeople, escalation paths, time-stamped updates, practice transparency. All of that has been in every incident response framework going back to NIST 800-61. Where this guidance actually adds value is in the operational specifics and the timing. It explicitly tells organizations to assume that their own telecommunications and primary communication channels may be disrupted or unreliable during a crisis. That means establishing and testing backup methods like radios, SMS phone trees, and out-of-band channels before you need them. When I run tabletop exercises for clients, one of the first things I do is take their communications down. Email is gone, Teams is gone, your status page is offline. Now coordinate your response and communicate with your customers. Most organizations completely fall apart at that point, and that is exactly the scenario this guidance is built for.

The timing also matters. This drops alongside CISA’s CI Fortify initiative, which tells critical infrastructure operators to prepare to deliberately disconnect OT systems from third-party networks during a geopolitical crisis. If you’re a water utility or a power plant making a real-time decision about whether to isolate, you need your service providers telling you exactly what is happening and what is not happening. The guidance specifically calls for articulating “what it is and what it is not” to prevent misattribution. After the year we’ve had with attacks against water utilities, ports, power generation, and PLC suppliers, CISA clearly does not want the next big CI outage to trigger days of “was this a nation-state attack?” speculation while downstream operators are making blind isolation decisions.

What gives this more weight than a typical government advisory is who helped write it. Microsoft, Sophos, Cloudflare, and American Water all contributed. Cloudflare’s November 2025 outage is explicitly cited as an informing event, and for good reason. Their status page went down during the incident, their own response team initially misidentified the root cause partly because of the communication breakdown, and the whole thing spiraled. The organizations that have been through it are helping write the playbook, and that gives the operational details real credibility.

John Strand, Owner, Black Hills Information Security, Inc.:

I think everything in this plan is great. There’s just one area I wish they would address more directly. When the decision is made to shut down network access, there need to be very clear lines defining who is authorized to make that decision and what political protections exist for the people making those calls.

During a breach of this nature, one of the biggest communication problems is often figuring out who’s on first and who’s on second. Who can actually make the call? Who has the authority to shut down access?

What often happens is that the decision gets escalated again and again and again until it eventually reaches a director, CEO, commissioner, or some other senior official who has enough authority to make the call. Meanwhile, valuable time is being lost.

Incident response plans need to go deeper than motherhood and apple pie statements about communicating with customers, coordinating between organizations, and keeping everyone informed. That’s all important, but the plan needs to explicitly identify who has the authority to make the really hard decisions during an incident.

Just as importantly, there needs to be political cover for the people who make those decisions.

Hindsight is always 20/20. After an incident, everyone gets to sit around and analyze whether shutting something down was absolutely necessary. The person making that decision in the middle of an active breach doesn’t have that luxury.