Regulatory & Standards Drift: Evidence Interoperability Collapses Across Concurrent Enforcement Regimes

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Between January 1 and January 17, 2026, multiple cybersecurity regulatory regimes entered enforceability across China, the United States, the European Union, and the United Kingdom. The regimes define scope, reporting thresholds, audit requirements, and evidentiary standards independently. No coordination mechanism governs their concurrent operation.

Extraterritorial scope expanded in parallel across jurisdictions. Whole-entity applicability replaced service-level scoping. Audit-trigger thresholds diverged across consumer, financial, and infrastructure regimes. Evidence retention and production timelines became non-overlapping.

China CSL: extraterritorial reach now covers any overseas activity "endangering PRC cybersecurity." Fines increased tenfold (up to RMB 10 million operators, RMB 1 million individuals). AI governance embedded into statutory framework.

Sweden NIS2: entire entity subject to requirements once any service line triggers scope.

CCPA: independent cybersecurity audits required where processing presents "significant risk." Certification submissions to CPPA begin April 2028.

UK/EU MoU: incident-sharing coordination established between CTP and CTPP oversight regimes before designation processes complete in either jurisdiction.

DORA Article 58 review assessing auditor applicability was due January 17.

Organizations operating across these jurisdictions are subject to overlapping cybersecurity enforcement timelines without a shared scope definition, audit boundary, or evidentiary format. China's extraterritorial expansion applies to network activities, cloud routing, and vendor dependencies with any PRC nexus. Sweden's whole-entity principle does not recognize partial compliance. CCPA audit documentation retention (five years) operates independently of data minimization obligations elsewhere. The evidence formats required under each regime are not interoperable. The timelines do not permit sequential production.

Compliance adequacy is no longer determined by control presence, but by the ability to produce jurisdiction-specific governance evidence under simultaneous, non-aligned enforcement conditions.