ARTICLE
6 July 2026

Cybersecurity Due Diligence Remains A Critical Focus In U.S. M&A Transactions

MF
Masuda, Funai, Eifert & Mitchell, Ltd.

Contributor

Since its founding in 1929, Masuda Funai has focused its practice on successfully representing international and domestic companies entering, operating and expanding in the United States. With offices in Chicago, Schaumburg and Los Angeles, the firm assists clients in every aspect of business, including establishing, acquiring, financing and selling operations and facilities; transferring overseas employees to the U.S.
As cybersecurity incidents and regulatory scrutiny intensify, M&A buyers are placing unprecedented emphasis on evaluating target companies' cyber defenses during due diligence. This analysis explores how cyber-related risks now influence deal valuation, transaction timing, and post-closing integration, while examining the specific areas buyers scrutinize—from governance structures and incident response capabilities to regulatory compliance and insurance coverage. Understanding these evolving diligence
United States Corporate/Commercial Law
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Cybersecurity has become a central component of M&A due diligence as buyers increasingly recognize the potential financial, operational and reputational risks associated with cyber incidents. Recent regulatory developments, expanded disclosure requirements and a growing number of ransomware and data breach events have heightened scrutiny of target companies' cybersecurity practices. As a result, acquirers are devoting greater attention to evaluating cybersecurity controls, incident response capabilities and compliance with applicable privacy and data protection laws during the diligence process.

In addition to assessing whether a target has experienced prior cybersecurity incidents, buyers are increasingly examining the maturity of the target's overall cybersecurity program. Areas of focus often include governance structures, third-party vendor management, employee training, access controls, cybersecurity insurance coverage and procedures for identifying and responding to security threats. For businesses that handle significant volumes of personal, financial or sensitive data, buyers are also reviewing compliance with applicable federal and state privacy requirements and evaluating potential exposure arising from regulatory investigations or private litigation.

Given the growing significance of cyber-related risks, transaction parties should address cybersecurity considerations early in the deal process. Buyers may seek enhanced representations and warranties, specific indemnification protections or remediation measures as conditions to closing, while sellers can benefit from identifying and addressing potential vulnerabilities before entering the market. As cybersecurity continues to influence valuation, transaction timing and post-closing integration efforts, robust cyber diligence is increasingly viewed not merely as a compliance exercise, but as a critical component of assessing and preserving deal value. Companies that proactively evaluate and manage these risks will be better positioned to execute transactions efficiently, avoid post-closing surprises and facilitate a smoother integration of acquired operations.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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