Fast-Track · Weeks, Not Months

Virtual CISO USA

Virtual CISO for US Companies - SEC, NYDFS, SOC 2 & Board-Level Security Leadership

Praxis-Q provides an on-demand Virtual CISO for US companies - security strategy, board reporting, SEC cyber-disclosure readiness, NYDFS and SOC 2 program ownership, and incident-response leadership at a fraction of a full-time hire.

At a Glance

Model

Fractional

Frameworks

SOC 2/NYDFS

Coverage

Strategy + Ops

Market

USA

Most mid-market US companies need senior security leadership - someone who owns the risk register, sits in front of the board, and makes framework decisions across SOC 2, HIPAA and CMMC - long before they can justify a full-time CISO's salary and equity package. Praxis-Q's Virtual CISO service provides that fractional leadership on a retainer basis, and for companies subject to SEC oversight, that leadership matters more than ever since the SEC's 2023 cybersecurity disclosure rule requires public companies to describe their board's cybersecurity oversight and disclose material incidents within four business days of determining materiality - a requirement that's been the subject of an active industry petition to amend or rescind Item 1.05 since May 2025, but remains in force as adopted while that petition is pending.
Who does the work: engagements are led by practitioners holding CISA (ISACA), CEH (EC-Council), eJPT (INE) and ISO/IEC 27001 Lead Auditor credentials. The principal consultant's CISA is verifiable on Credly.
Who you are working with: Praxis-Q is the compliance and cybersecurity practice of Techtweek Infotech LLC, a Wyoming-registered company, and of PraxisQ Consulting LLP (India). SOC engagements are contracted through the LLC; other services through the LLP (see Terms). Delivery is remote-first from our India practice; email is answered within 24 hours and calls are by appointment. Book a US-hours call or reach the team on +1 917-508-5334.

vCISO USA

Virtual CISO USA

Virtual CISO for US Companies - SEC, NYDFS, SOC 2 & Board-Level Security Leadership

The Problem

Hiring a full-time CISO costs $250K+ and takes months, yet SEC cyber-disclosure rules, NYDFS and enterprise buyers now expect executive security ownership. Most growing US firms run without it.

What We Do

  • Assess
  • Strategy
  • Govern
  • Operate
  • Respond

What You Get

  • Board and audit-committee security reporting
  • SEC cyber-disclosure (Item 1.05) readiness
  • NYDFS 23 NYCRR 500 program ownership
  • SOC 2 / ISO 27001 program leadership
  • Security roadmap, budget and vendor risk
  • Incident response leadership

Why weeks, not months

AI-assisted evidence review, one client portal

Every vCISO USA engagement runs on the Praxis-Q compliance platform. You upload evidence per control, AI scores it against the requirement, and your auditor reviews in the same workflow — from scoping through to the issued, publicly verifiable certificate.

AI evidence scoring

Every upload is scored against the control before an auditor sees it — gaps surface in minutes, not at the review meeting.

One client portal

Scoping, evidence, auditor queries and status live in one place. No email chains, no spreadsheet trackers.

Auditor sign-off

Praxis-Q auditors review inside the same workflow, so review rounds shrink and the certificate issues sooner.

What a Virtual CISO Actually Does

A vCISO owns the security programme's strategic direction: building and maintaining the risk register, deciding which framework (or combination - SOC 2, HIPAA, CMMC, state privacy law) actually applies to the business, reporting to the board or leadership team in language they can act on, leading incident response when something goes wrong, and managing the vendor risk process for third-party tools and subprocessors. This is a governance and leadership function, not a hands-on engineering role - a vCISO directs the security programme rather than personally configuring firewalls, which is why it pairs naturally with Praxis-Q's other services (penetration testing, SOC-as-a-Service monitoring) that provide the technical execution a vCISO's programme calls for.

Why Mid-Market Companies Need This Now

The SEC's Cybersecurity Risk Management, Strategy, Governance and Incident Disclosure rule, effective since December 2023, requires public companies to disclose material cybersecurity incidents on Form 8-K Item 1.05 within four business days of determining materiality, and to describe the board's role in cybersecurity oversight in the annual 10-K. A joint industry petition filed in May 2025 asks the SEC to rescind or narrow the Item 1.05 disclosure requirement specifically, citing premature-disclosure risk during active incidents, and as of 2026 that petition remains pending without the rule having been withdrawn - meaning the obligation is still live for any company it covers. Even for private mid-market companies not directly subject to the SEC rule, the governance expectations it set (documented board oversight, a defined incident materiality process) have become the de facto standard enterprise customers and acquirers expect to see, which a vCISO is specifically positioned to build and own.

Framework Ownership Across SOC 2, HIPAA and CMMC

Companies rarely need just one framework - a healthcare SaaS vendor might need SOC 2 for enterprise sales and HIPAA for its healthcare customers simultaneously; a defense-adjacent manufacturer might need CMMC and a customer-driven SOC 2 report at the same time. A vCISO's job is deciding how these overlap, sequencing which gets built first, and making sure evidence is reused across frameworks rather than duplicated in three separate silos. Praxis-Q's vCISOs work directly with our SOC 2, HIPAA and CMMC delivery teams so the framework strategy and the actual implementation stay aligned rather than being handed off cold.

Fractional vs Full-Time: The Real Cost Comparison

A full-time CISO at a company big enough to need one typically commands a substantial base salary plus equity and benefits, and for a mid-market company that doesn't yet have the security programme complexity to keep that role fully occupied, it's a poor use of budget. A fractional vCISO retainer delivers the same strategic leadership and board-facing governance at a materially lower ongoing cost, scaled to the hours the business actually needs, and Praxis-Q's clients typically graduate to a full-time hire only once the security programme's operational complexity genuinely justifies it - at which point we help recruit and onboard that hire rather than losing the engagement.

What to Expect in the First 90 Days

Praxis-Q's vCISO engagements start with a risk assessment and framework-fit review in the first two to three weeks, followed by building or updating the risk register and incident response plan, then establishing a regular board or leadership reporting cadence by day 60. By day 90, most clients have a documented security roadmap prioritised against their actual compliance and customer requirements, rather than a generic checklist, and the vCISO is actively running point on whichever framework engagement (SOC 2, HIPAA, CMMC) is the immediate priority.

Frequently Asked Questions

What does a Virtual CISO do?
A vCISO provides executive security leadership on demand - strategy, governance, board reporting, compliance program ownership and incident response - without the cost of a full-time hire.
Do you support SEC cyber-disclosure rules?
Yes. We prepare US public companies for SEC Item 1.05 incident disclosure and governance reporting, and align programs to NYDFS and SOC 2.
What is the difference between a vCISO and a general security consultant?
A consultant is typically engaged for a defined project with a start and end date - a specific assessment or implementation. A vCISO is an ongoing leadership role: owning the risk register, reporting to the board continuously, and making framework and prioritisation decisions over time rather than delivering one report and moving on. Praxis-Q's vCISO retainers are structured as ongoing relationships, not one-off projects.
How many hours per month does a vCISO typically work?
It varies by company size and programme maturity - some retainers are a handful of hours a month for board reporting and strategic oversight, others are more substantial for a company actively building out a compliance programme from scratch. Praxis-Q scopes hours to the actual work in front of the client rather than a fixed generic package.
Can a vCISO sign our SOC 2 attestation?
No - only a licensed CPA firm can issue a SOC 2 report under AICPA attestation standards. A vCISO owns and drives the security programme that produces the evidence a SOC 2 audit needs, but the attestation itself is a separate, structurally distinct function performed by an independent CPA firm.
Does a vCISO handle incident response if we have a breach?
Yes - leading incident response is one of the core functions of the role, including coordinating the technical response, managing communication to leadership and the board, and where applicable, advising on regulatory notification obligations (state breach laws, SEC Item 1.05 for public companies, HIPAA breach notification for covered entities). Praxis-Q's vCISOs are on call for exactly this scenario, not just for scheduled strategic work.
What exactly does the SEC cybersecurity disclosure rule require?
Public companies must disclose a material cybersecurity incident on Form 8-K Item 1.05 within four business days of determining it's material, and describe their board's role in cybersecurity oversight and management's role in assessing and managing cyber risk in their annual 10-K. A joint industry petition asking the SEC to narrow or rescind Item 1.05 has been pending since May 2025, but the rule remains in force as adopted in the meantime.
When should we move from a vCISO to a full-time hire?
Generally once the security programme's operational complexity - team size managing it, number of frameworks in play, incident frequency - genuinely exceeds what a fractional retainer can cover, rather than at a fixed company size or revenue threshold. Praxis-Q flags this transition point proactively with clients and can support recruiting and onboarding the full-time hire rather than treating the transition as a loss of the relationship.

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