CISO Tribune

Disclosure · Form 10-K · fiscal 2025

Bit Digital, Inc 10-K cybersecurity disclosure (Item 1C), fiscal 2025

Filed March 27, 2026· period ended December 31, 2025· BTBT· CIK 1710350· Updated · filing on sec.gov ↗

Bit Digital, Inc's Form 10-K for fiscal 2025, filed March 27, 2026, names the Head of IT as its top security role, with oversight by the full board.

What Bit Digital's Item 1C says

Bit Digital's Form 10-K for fiscal 2025 places oversight of cybersecurity risk with the Board of Directors as a whole. Departments of the company report to the Head of IT, who oversees the cybersecurity strategy defined in the Cybersecurity Policy.

Board and management oversight

The Board of Directors approves the policy that defines the company's cybersecurity principles, goals and targets. Management provides interim and year-end reports to the Board of Directors on IT General controls related to cybersecurity and information security matters.

Who leads security

The Head of IT oversees the cybersecurity strategy, and departments identified under the Cybersecurity Policy report to that role. The management team includes members with IT backgrounds who guide the company's cybersecurity efforts.

How the company manages cyber risk

The company's cybersecurity risk management is integrated into its overall enterprise risk management and shares common reporting channels and governance processes. The Cybersecurity Policy uses a risk-based approach based on industry standards to balance the level of cybersecurity against the risks faced by the company. Upon discovering a potential violation or breach, the member of management must document the incident and request that the individual surrender any devices that may have suffered a security breach.

Third parties and incidents

The company states that it assessed all third-party vendors, including its third-party IT firms, before engaging them for various services. The company also performs yearly risk assessments on critical vendors and suppliers as part of its information technology general controls cyber security processes. In 2025, the company did not identify any cybersecurity events that have materially affected or are reasonably likely to materially affect its business strategy, results of operations, or financial condition.

What the section does not state

The section does not name the person who holds the top security role. The section does not name a board committee as responsible for cybersecurity oversight. The section does not name a specific security framework or standard.

Read from the Form 10-K filed March 27, 2026, on . Every sentence rests on a passage of the section reproduced below.

The filing's fields, each with its sentence

Who leads security (the top role, as the filing names it)

Head of IT

Reports to

not identified

Board oversight

Full board

“The Board of Directors as a whole oversees the Cybersecurity Policy and its implementation of the Company's oversight, programs, procedures, and policies related to cybersecurity, cybersecurity risks, information security, and data privacy.”

CISO or other person named

not identified

Frameworks and standards named

not identified

Outside assessors, consultants or testers

not identified

Experience of the security leadership, as stated

Stated

“The management team includes members with IT backgrounds to guide our cybersecurity efforts.”

Material incident

The filing states none

“In 2025, we did not identify any cybersecurity events that have materially affected or are reasonably likely to materially affect our business strategy, results of operations, or financial condition.”

The section

644 words, Form 10-K filed March 27, 2026 for the period ended December 31, 2025

Read by claude-sonnet-5-5 on November 2, 2026; every quote verified in the stored text by code.

How peers in the same industry describe the seat

The SEC assigns Bit Digital, Inc standard industrial classification 6199, Finance services (SEC SIC list). 8 other filers in our library have the same code.

FilerTop security roleReports toBoard oversight
IREN LimitedFY 2026, filed August 27, 2026Chief Information Security Officernot identifiedAudit and Risk Committee
BeneficientFY 2026, filed June 30, 2026Chief Technology Officerour Boardfull board
HIVE Digital Technologies Ltd.FY 2026, filed June 2, 2026Chief Information Officernot identifiedaudit committee of the Board
FORUM MARKETS IncFY 2025, filed April 1, 2026Chief Financial Officernot identifiedAudit Committee
Bitfarms LtdFY 2025, filed March 31, 2026Vice President, Global Corporate ITexecutive managementaudit committee of the Board
Greenidge Generation Holdings Inc.FY 2025, filed March 31, 2026not identifiednot identifiedAudit Committee
Mawson Infrastructure Group Inc.FY 2025, filed March 31, 2026not identifiednot identifiedAudit Committee
Universal TokenFY 2025, filed March 31, 2026not identifiednot identifiednot identified

Item 1C, verbatim from the filing

The text below is the Cybersecurity item of Bit Digital, Inc's Form 10-K as filed with the SEC on March 27, 2026, reproduced word for word from the filing on sec.gov. Page numbers and navigation lines have been removed; nothing has been added. It describes governance as of that date.

Item 1C. Cybersecurity

The Company's cybersecurity principles,

goals and targets are defined in a policy approved by the Board of Directors (the "Cybersecurity Policy"). This Policy is

anchored in a risk-based approach based on industry standards to balance the level of cybersecurity against the risks faced by the Company.

Material risks are managed by both internal resources and third-party contractors. The Company believes that effective information security

management is necessary for the secured sharing and protection of information within the Company's cyberspace.

The Cybersecurity Policy applies to all directors,

officers, employees and contractors of the Company and any parent, holding companies and subsidiaries regardless of their contract terms,

who use the Company's technological devices.

The Board of Directors is responsible for leading

the Company to minimize the risk of unauthorized and malicious use, disclosure, potential theft, alteration or damaging effects on the

Company's operations while concurrently enabling the sharing of information in cyberspace. The Board of Directors is committed

to ensuring that risks to the confidentiality, integrity or availability of Company-owned information assets are managed appropriately

by implementing an information security risk management approach. The Company's cybersecurity risk management is integrated into

its overall enterprise risk management, sharing common reporting channels and governance processes that apply across the enterprise risk

management program.

The Board of Directors as a whole oversees the

Cybersecurity Policy and its implementation of the Company's oversight, programs, procedures, and policies related to cybersecurity,

cybersecurity risks, information security, and data privacy. Departments of the Company have been identified under the Cybersecurity

Policy to report to the Company's Head of IT overseeing the cybersecurity strategy as defined in the Cybersecurity Policy.

The management team includes members with IT

backgrounds to guide our cybersecurity efforts. Management continuously assesses risk as internal and external factors evolve and remains

committed to ensuring employees have the adequate resources and training to fully understand cybersecurity guidelines and expectations.

In the event of a Policy breach, members of the management team may be asked by the IT Department to assist with security investigations.

If any member of management is unaware of the best course of action in dealing with an IT-related matter, the manager shall immediately

contact the Company's Head of IT. Upon discovering a potential violation of the Policy or a cybersecurity breach, the member of

management must document the incident and request the individual surrender possession of any devices that may have suffered a security

breach.

We assessed all third-party vendors, including our third-party IT firms,

before engaging them for various services. We have partnered with third-party IT providers to support our cybersecurity and information

technology functions, with the Managed Security Operations Center operating 24/7/365 for automated email monitoring, malicious email quarantine,

and reporting; secure systems design and architecture, security controls implementation, penetration testing, disaster recovery testing,

and risk assessments. Through these partnerships, we maintain continuous security monitoring and control validation We also perform yearly

risk assessments on critical vendors and suppliers as part of our information technology general controls cyber security processes.

Additionally, the Company's management

leverages manual controls to verify data integrity and mitigate risk, considering the Company's size and business model. Management

also provides interim and year-end reports to the Board of Directors on the Company's and its subsidiaries' IT General controls

(ITGC) related to cybersecurity and information security matters.

In 2025, we did not identify any cybersecurity

events that have materially affected or are reasonably likely to materially affect our business strategy, results of operations, or financial

condition. However, despite our efforts, we cannot eliminate all risks from cybersecurity threats, or provide assurances that we have

not experienced an undetected cybersecurity incident. For more information about these risks, please see " Risk Factors—

Cyberattacks and security breaches of our system, or those impacting our third parties, could adversely impact our brand and reputation

and our business, operating results, and financial condition. "

Earlier filings on record

Fiscal 2024 Form 10-K, filed March 14, 2025 sec.gov ↗

Top security role, as the filing names it

Head of IT

Reports to, as the filing names it

not identified

Board oversight

Full board

“The Board of Directors oversees the Policy and its implementation of the Company's oversight, programs, procedures, and policies related to cybersecurity, cybersecurity risks, information security, and data privacy.”

Person named in the filing

not identified

Experience, as stated

Stated

“The management team includes members with IT backgrounds to guide our cybersecurity efforts.”

Material incident

The filing states none

“In 2024, we did not identify any cybersecurity events that have materially affected or are reasonably likely to materially affect our business strategy, results of operations, or financial condition.”

Read by claude-sonnet-5-5 on November 2, 2026; every quote verified in the stored text by code.

Item 1C. Cybersecurity

The Company's cybersecurity principles,

goals and targets are defined in a policy approved by the Board of Directors (the "Policy"). This Policy is anchored in a

risk-based approach based on industry standards to balance the level of cybersecurity against the risks faced by the Company. Material

risks are managed by both internal resources and third-party contractors. The Company believes that effective information security management

is necessary for the secured sharing and protection of information within the Company's cyberspace.

The Policy applies to all directors, officers,

employees and contractors of the Company and any parent, holding companies and subsidiaries regardless of their contract terms, who use

the Company's technological devices.

The Board of Directors is responsible for leading

the Company to minimize the risk of unauthorized and malicious use, disclosure, potential theft, alteration or damaging effects on the

Company's operations while concurrently enabling the sharing of information in cyberspace. The Board of Directors is committed to

ensuring that risks to the confidentiality, integrity or availability of Company-owned information assets are managed appropriately by

implementing an information security risk management approach.

The Board of Directors oversees the Policy and

its implementation of the Company's oversight, programs, procedures, and policies related to cybersecurity, cybersecurity risks,

information security, and data privacy. Departments of the Company have been identified under the Policy to report to the Company's

Head of IT overseeing the cybersecurity strategy as defined in the Policy.

The management team includes members with IT backgrounds

to guide our cybersecurity efforts. Management continuously assesses risk as internal and external factors evolve and remains committed

to ensuring employees have the adequate resources and training to fully understand cybersecurity guidelines and expectations. In the event

of a Policy breach, members of the management team may be asked by the IT Department to assist with security investigations. If any member

of management is unaware of the best course of action in dealing with an IT-related matter, the manager shall immediately contact the

Company's Head of IT. Upon discovering a potential violation of the Policy or a cybersecurity breach, the member of management

must document the incident and request the individual surrender possession of any devices that may have suffered a security breach.

We assessed all third-party vendors, including

our third-party IT firm, before engaging them for various services. . We have partnered with a third-party IT firm for cybersecurity services,

with the Managed Security Operations Center operating 24/7/365 for automated email monitoring, malicious email quarantine, and reporting.

The Head of IT will be notified and proceed accordingly if an event or incident requires input.

Additionally, the Company's management leverages manual controls

to verify data integrity and mitigate risk, considering the Company's size and business model. Management also provides interim

and year-end reports to the Board of Directors on the Company's and its subsidiaries' IT General controls (ITGC) related to

cybersecurity and information security matters.

In 2024, we did not identify any cybersecurity

events that have materially affected or are reasonably likely to materially affect our business strategy, results of operations, or financial

condition. However, despite our efforts, we cannot eliminate all risks from cybersecurity threats, or provide assurances that we have

not experienced an undetected cybersecurity incident. For more information about these risks, please see " Risk Factors—

Cyberattacks and security breaches of our system, or those impacting our third parties, could adversely impact our brand and reputation

and our business, operating results, and financial condition." and "We may suffer significant and adverse effects due to hacking

or one or more adverse software events ".

The fields above are exact quotes from the stored text. "Not identified" means no supporting sentence was found, not that the company has no such arrangement. A name in a filing is not a record of who holds the seat today: the Wire tracks that.

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