Reporting obligations

24-hour incident reporting: what the CSRB demands

The Cyber Security and Resilience Bill introduces the UK's most aggressive cyber incident reporting timeline. Regulated organisations must issue an initial notification within 24 hours and a full report within 72 hours -- or face penalties up to 4% of global turnover.

The 24-hour rule

What does the 24-hour rule actually require?

Section 15 of the Cyber Security and Resilience Bill (Regulation 11A) requires every regulated entity to submit an initial incident notification within 24 hours of becoming aware of a reportable incident. The clock starts at operational awareness -- not at root-cause confirmation.

This initial report is deliberately short-form: confirm the incident occurred, describe its nature, and state what immediate measures you have taken. The detailed assessment follows in the 72-hour full report. Notifications must go to both the relevant designated regulator and the CSIRT simultaneously.

End-to-end reporting timeline

From detection to annual review

The CSRB imposes a multi-stage reporting lifecycle. Miss any window and penalty exposure begins immediately.

Detection

T = 0

Incident identified. The clock starts the moment an authorised person becomes aware.

Initial notification

Within 24 hours

Short-form alert to regulator + CSIRT: incident type, scope, and immediate actions.

Full report

Within 72 hours

Detailed assessment: nature, impact, affected systems, root cause (if known), and remediation.

Customer notification

As soon as practicable

Inform affected UK customers of the incident nature and likely adverse effects on them.

Ongoing obligations

Continuous

Updates as new information emerges. Annual reporting to regulators on incident patterns.

Reporting thresholds

Incident vs. near miss vs. non-reportable

The CSRB widens the reporting net far beyond actual service disruption. Understanding the threshold is critical to compliance.

CategoryDefinitionReportable?Example
Significant incidentAn event that has, is having, or is likely to have a significant impact on service continuity, security, or integrity.Yes -- 24h + 72hRansomware encrypts production systems and halts operations for 8 hours.
Near missAn event capable of having a significant impact, even if impact was averted.Yes -- same timelineAttacker gains initial access via compromised credentials; detected and contained before lateral movement.
Non-reportable eventRoutine security events with no potential for significant impact.NoAutomated port scan blocked at perimeter firewall with no further indicators.

Threshold ambiguity

The Bill does not include a prescriptive list of factors for judging "significant impact." Parliamentary debate on Regulation 11A(3) has noted the breadth of the definition, and sector-specific thresholds may be set in secondary legislation. Until those arrive, regulated organisations should err on the side of reporting.

Regulatory comparison

CSRB vs. GDPR vs. NIS2 reporting timelines

Organisations operating across UK and EU jurisdictions face overlapping but distinct incident reporting obligations.

AspectCSRB (UK)GDPR (UK/EU)NIS2 (EU)
Initial notification24 hours72 hours (single notice)24 hours (early warning)
Full report72 hoursN/A -- single notification72 hours (incident notification)
Final / lessons-learned reportUpdates as information emergesN/A1 month after notification
TriggerSignificant impact or capability of significant impact (near miss)Risk to rights and freedoms of individualsSignificant impact on service provision
Who receives itDesignated regulator + CSIRT simultaneouslySupervisory authority (ICO in UK)CSIRT or competent authority
Customer notificationAs soon as reasonably practicableWithout undue delay (if high risk)Without undue delay (if significant)
ModelTwo-stage (24h + 72h)Single notificationThree-stage (24h + 72h + 1 month)

An incident that constitutes both a NIS incident and a GDPR personal data breach requires separate notifications under different legal bases. Dual-reporting procedures should be built into your incident response plan. See our NIS2 vs CSRB comparison for a deeper analysis.

Notification recipients

Who must you notify -- and when?

Section 15 (Regulation 11A) requires simultaneous notification to two bodies, followed by customer disclosure.

Designated regulator

Your sector-specific competent authority (e.g. Ofcom for telecoms, the Information Commission for MSPs and digital service providers). Initial notification within 24 hours; full report within 72 hours.

CSIRT (NCSC)

A copy of every incident notification must be sent to the Computer Security Incident Response Team -- the NCSC -- at the same time as the regulator report. This dual-track is mandatory, not optional.

Affected customers

After notifying the regulator, you must inform UK customers likely to be adversely affected. The notification must explain the incident nature and its likely adverse effects. Regulators may also require public disclosure.

MSP obligations

What reporting should MSPs provide after an incident?

Managed service providers face identical timelines to operators of essential services -- plus unique supply-chain disclosure requirements.

Core MSP reporting duties (Section 15, Regulation 11A)

  • Submit initial notification to the Information Commission within 24 hours of becoming aware of the incident.
  • Provide a full detailed report within 72 hours, including the nature of the incident, affected systems, impact assessment, and measures taken.
  • Send a copy of both notifications to the CSIRT (NCSC) simultaneously.
  • An incident is reportable if it affects your systems' operation or security and has, or is capable of having, significant impact in the UK.
  • Notify affected customers as soon as reasonably practicable after reporting to the regulator, explaining why they are affected and what they should do.

Supply-chain cascade

Because MSPs hold privileged access to client networks, a single MSP breach can cascade across dozens of customer organisations. The CSRB recognises this systemic risk: an estimated 900-1,100 managed service providers fall within scope. If your MSP is compromised, your own reporting obligations may also be triggered even if your systems were not directly breached.

Report contents

What must be included in your reports?

The initial 24-hour notification and the 72-hour full report serve different purposes and require different levels of detail.

Element24-hour initial notification72-hour full report
Incident confirmationConfirm that a reportable incident has occurred or is occurring.Confirm and classify the incident type.
Nature and scopeBrief description of the incident nature and affected service(s).Detailed analysis of attack vectors, entry points, and scope of compromise.
Impact assessmentInitial assessment of potential impact.Quantified impact: systems affected, data compromised, service downtime, geographic reach.
Immediate measuresActions taken to contain or mitigate.Full containment, eradication, and recovery measures implemented.
Root causeNot required at this stage.Preliminary root-cause analysis (or an explanation of why it is still under investigation).
Cross-border impactFlag if other UK or international services are affected.Detail cross-border dependencies and any notifications to other jurisdictions.

Penalties for late or non-reporting

Failing to report on time triggers the same penalty framework as a security failure. Under Section 21 (Regulation 18):

  • Higher band: Up to the greater of £17 million or 4% of global turnover for failing to submit an incident notification under Regulation 11A(2).
  • Standard band: Up to the greater of £10 million or 2% of global turnover for failing to copy notifications to CSIRT or failing to notify customers.
  • Daily penalties: Up to £50,000 per day for continuing failure to comply with information or inspection requirements under Part 4.

The regulator may also require public disclosure of the incident if necessary to manage the threat or inform affected parties -- compounding reputational damage.

Related topic

Near miss reporting: the hidden expansion of scope

The CSRB does not stop at actual breaches. Events capable of having a significant impact are now reportable -- even if no harm materialised. This fundamentally changes what your detection capabilities must cover.

Read the near miss reporting guide

Can your team report an incident in 24 hours?

Most organisations cannot. Our readiness assessment identifies the gaps in your incident detection, classification, and reporting workflows -- before the regulator does.