Why Cyber Risk is Now an Enterprise Priority in 2026

Cyber risk and practice are entering a more demanding era. Organizations are dealing with a heightened threat landscape and a more assertive enforcement climate. Already in 2025, they contended with relentless ransomware campaigns, state-linked operations, and large-scale systemic outages, as A&O Shearman writes.

Last year, regulators focused on resilience, governance, and accountability. Enforcement emphasized technical controls, board oversight, third-party risk, and defensible decision-making. These developments collectively reframed cyber risk as an enterprise governance issue rather than a purely technical concern heading into 2026.

Law enforcement disrupted established groups, leaving the ransomware ecosystem fragmented. Nevertheless, state-linked actors frequently campaigned against supply chains and critical infrastructure.

Defective software updates triggered widespread outages, heightening operational resilience concerns. Consequently, United Kingdom, European Union, and United States regulators bolstered their cybersecurity and disclosure frameworks.

The UK proposed a Cyber Security and Resilience Bill and ransomware payment restrictions. EU initiatives included the Network and Information Systems Directive, the Digital Operational Resilience Act, and the Cyber Resilience Act.

In the US, regulatory emphasis was on accurate and timely cybersecurity disclosures. Third-party risk oversight and whistleblowing related to cyber issues both increased.

The key themes globally are resilience, scope expansion, and enforcement readiness. Organizations are expected to demonstrate dependency mapping, tested recovery procedures, and meaningful third-party assurance.

Incident reporting obligations have multiplied across jurisdictions, creating more complexity. Sanctions and anti-money-laundering considerations remain central to ransomware response, with heightened scrutiny of payment decisions.

Boards and management face growing expectations of cyber literacy and accountability, including potential individual enforcement exposure.

Legal teams should note that these developments affect transactional due diligence, contract structuring, and integration planning, especially with respect to third-party dependencies and regulatory approvals across jurisdictions. Managing disclosure controls, board governance, and cross-border regulatory risk is critical. So is aligning public statements with internal assessments.

Attorneys can expect to be called upon to advise on ransomware response protocols, sanctions exposure, whistleblowing frameworks, and enterprise risk management to support defensible oversight.