v0.7 prototype. Materiality is a legal/accounting judgment. Tool is a triage; GC + outside counsel still required.
8 QUESTIONS · ITEM 1.05 + REG S-K ITEM 106 + SAB TOPIC 99

Cyber Incident Materiality Test

8 questions across operational, data, financial, regulatory, and reputational factors. Get a triage classification on whether Item 1.05 8-K disclosure is likely triggered — and what the 4-business-day clock means.

Honest limits: Item 1.05 materiality is a legal and accounting judgment requiring General Counsel, Disclosure Committee, and outside securities counsel. The 4-business-day clock starts on the date materiality is DETERMINED — not the date the incident is discovered. Investigation can continue after the 8-K is filed (Item 1.05 explicitly permits amendments). This tool is a triage screen. For hands-on support on Item 1.05 drafting: rohit@unfoldingvalues.com.
What this tool does NOT replace:
  • General Counsel and outside securities counsel review
  • Disclosure Committee meeting and written materiality memo
  • Forensic investigation findings and timeline reconstruction
  • Insurance carrier and incident-response retainer coordination
  • Coordination with FBI / CISA / DOJ delay procedure under Item 1.05(c)
  • Item 106 annual 10-K cybersecurity governance disclosures
  • Foreign jurisdiction notification (GDPR 72-hour rule, etc.)