Cyber incident response in 2025: Rising risks and dynamic challenges

For organizations affected by cyber incidents, effective response strategies have become essential for reducing potential damage and restoring operations. An analysis of data breaches in 2024 revealed that while the number of data breaches only increased incrementally, the breaches were more severe in terms of the quantity of personally identifiable information (PII) that was exposed. 

Incident response (IR) teams play a crucial role in identifying the scope of an incident, determining what data was compromised, and executing response plans — which importantly, include notifying affected parties in accordance with applicable laws and regulations.

In 2025, business security professionals will likely face three significant trends shaping the way cyber incidents are managed.

1. Prioritizing notification over data mining

Traditionally, incident response involved extensive data mining to determine exactly who and what was affected. However, larger organizations are increasingly opting for blanket breach notifications to all potentially impacted individuals. While this approach can reduce costs and expedite compliance, it comes with trade-offs, such as inaccuracies in contact lists.

Incomplete or duplicate data can result in poorly executed notification processes, which may draw regulatory scrutiny. To mitigate these risks, companies must prioritize clean, well-organized data during incident response efforts. Ensuring data accuracy and minimizing errors in outreach is not just about compliance; it reflects a commitment to transparent and responsible communication with business stakeholders.

2. Rising legal risks for small and medium-sized businesses

Larger enterprises often accept the heightened legal exposure that comes with notifying broader groups of individuals, reserving resources to address potential class action lawsuits. However, small and medium-sized businesses (SMBs) face a different reality.

Recent legal trends have lowered the threshold for class action lawsuits, with courts in several states certifying cases involving as few as 100 individuals. For SMBs, even a notification effort involving 200 to 300 people can result in costly legal challenges.

To protect themselves, SMBs should to ensure they have adequate cyber coverage and access to experienced legal counsel well-versed in incident response. Proactive planning can make the difference between weathering a breach and facing serious financial risks.

3. Navigating complex and evolving state laws

The regulatory landscape for data privacy and breach notification continues to grow more complex. In the United States, requirements vary widely by state. For example:

• Massachusetts prohibits breach notifications from including the number of individuals affected or the type of data exposed.
• Utah mandates that these specifics be disclosed in notification letters.
• Pennsylvania requires credit monitoring services to be offered not only when Social Security numbers are compromised but also for breaches involving bank account information.

Organizations operating across multiple states need clear, up-to-date guidance to navigate these evolving requirements. Understanding what to report, how to notify affected individuals, and what remediation services to provide is critical to remaining compliant and avoiding penalties.

More dynamic challenges in 2025 cybersecurity incident response 

As cyber threats grow more advanced, organizations will face a host of dynamic challenges in 2025. A strategic approach that balances speed, accuracy and compliance in a fast-evolving threat landscape will be required.

An increase of hybrid incidents — those that combine multiple attack vectors such as ransomware, supply chain breaches, and phishing campaigns — are demanding more coordinated responses. The level of cooperation required across internal departments such as IT, legal, and public relations — as well as external entities like third-party vendors, cybersecurity consultants, and law enforcement — demands advance planning and greater preparation.

Complicating matters further is the growing use of advanced tools and techniques by attackers, such as employing generative artificial intelligence (GenAI) tools to automate phishing campaigns or deploying multi-stage malware that evades detection. These tactics often leave organizations scrambling to identify the full scope of the attack while mitigating immediate threats.

To prepare for this dynamic landscape, an organization’s IR team should participate in regular tabletop exercises that simulate multi-vector attacks to identify gaps in response plans. Additionally, the development of proactive incident response plans that pre-establish clear communication channels, protocols, and enable rapid decision-making will be critical to containing these incidents and preventing further fallout.

Planning for an evolving threat landscape

The demand for PII is fueling a surge in data breaches, with cybercriminals increasingly leveraging advanced tools like GenAI to scale their attacks. This heightened demand for PII poses significant financial and reputational risks for organizations of all sizes.

To stay ahead of these challenges, business security professionals can focus on three key areas:

• Ensuring data accuracy and organization during the notification process to maintain regulatory compliance and public trust.
• Proactively assessing legal risks and securing appropriate cyber coverage to mitigate financial exposure.
• Keeping pace with the evolving regulatory environment through expert guidance and resources.

In a world where cyber threats are growing more sophisticated, incident response strategies must evolve to meet the demands of an increasingly complex risk landscape. By addressing these challenges head-on, security professionals can help safeguard their organizations and the broader ecosystem.