Cybersecurity (Item 1C)
What to check in your filing: Verify Item 1C describes processes, governance and board oversight, and that material incidents are evaluated for 8-K Item 1.05.
2 staff comments from 1 companies. Outcomes: Agreed to revise: 1, Awaiting / response not in dataset: 1
Magnitude International Ltd (MAGH) · 2026-03-04 · Form 20-F for the fiscal year ended April 30, 2025 Amendment No. 1 to Form 20-F for the fiscal year ended April 30, 2025 · Comment 1 · Item 15. Controls and Procedures, page 76 Agreed to revise
Staff comment: We note your response to our prior comment 1 and your amendment to your filing in response to our prior comments 1, 2, and 3 to include a conclusion regarding the effectiveness of your disclosure controls and procedures, include cybersecurity disclosures, and include the certifications from your principal executive officer and principal financial officer. In light of the amendment to address such previously omitted items, please tell us what consideration you gave to reconsidering your conclusion regarding your disclosure controls and procedures. letter →
Company response: 1 to our Form 20-F for the fiscal year ended April 30, 2025. Upon identifying the need to amend our original Form 20-F to include the previously omitted items, management, including our principal executive officer and principal financial officer (the “Certifying Officers”), re-evaluated the effectiveness of our disclosure controls and procedures (“DCP”) as of April 30, 2025. This re-evaluation was conducted specifically to determine whether the omission of these items from the original filing indicated a material weakness or a significant deficiency in our DCP that would alter the original conclusion of effectiveness. The re-evaluation considered the following factors: 1. Nature of the… response letter →
Magnitude International Ltd (MAGH) · 2026-02-23 · Form 20-F for the fiscal year ended April 30, 2025 · Comment 2 · Item 16K. Cybersecurity, page 78 Awaiting / response not in dataset
Staff comment: Please tell us why cybersecurity disclosure is not applicable given that Item 16K applies to annual reports on Form 20-F, or amend your filing to include the applicable cybersecurity disclosures. See Instruction to Item 16K of Form 20-F. letter →
Free weekly digest
New SEC comment letters by topic, notable staff comments, fresh disclosure examples and effective-date reminders. One email a week.
Subscribe free →Opens our beehiiv signup page. Free; unsubscribe anytime.
Templates & resources
- AICPA & CIMA – SEC reporting resources (AICPA & CIMA · Professional body · Free / member)
- BDO Accounting, Reporting & Compliance Hub (ARCH) (BDO · Firm guide · Free)
- Deloitte DART – Roadmap Series (Deloitte · Firm guide · Free)
- Deloitte Roadmap: SEC Comment Letter Considerations (Deloitte · Firm guide · Free)
- KPMG Financial Reporting View (KPMG · Firm guide · Free)
- PwC Viewpoint (PwC · Firm guide · Free / paid)
- SEC – Cybersecurity disclosure rule (press release 2023-139) (SEC · Regulator · Free)
- SEC – EDGAR Full Text Search (SEC · Regulator · Free)