NIS2 incident reporting: 24 hours, 72 hours, one month

NIS2 replaces a single deadline with a cascade. The first report is due before most investigations have a root cause, so the process has to be designed for partial information.

#The reporting cascade

ReportDeadlineContent
Early warningWithout undue delay, within 24 hours of becoming aware of a significant incidentWhether it is suspected to be unlawful or malicious; whether it could have cross-border impact
Incident notificationWithin 72 hours of becoming awareUpdates the early warning; initial assessment of severity and impact; indicators of compromise where available
Intermediate reportOn request of the CSIRT or competent authorityRelevant status updates
Final reportWithin one month of the incident notificationDetailed description, type of threat or root cause, mitigations applied, cross-border impact
Progress reportIf the incident is ongoing at the final-report deadlineStatus, with a final report within one month of handling the incident

Trust service providers must submit the incident notification within 24 hours rather than 72 [1].

#Who is in scope

NIS2 applies to medium and large entities in sectors listed as essential or important — including energy, transport, banking, health, digital infrastructure, ICT service management, and a range of manufacturing and digital providers — plus some entities regardless of size. Member states had to transpose the directive by 17 October 2024, and national laws differ in detail, including which authority or CSIRT receives reports. Confirm the receiving body in each country where you operate before you need it.

#Designing for the 24-hour report

  • Define "significant incident" criteria in advance (Article 23(3): severe operational disruption or financial loss, or considerable damage to others).
  • Pre-approve the early-warning template and who can send it at 3 a.m.
  • Collect IoCs from the first hour; the 72-hour report expects them.
  • Keep one timeline as the source for every report, so the one-month report doesn't contradict the first.

#Sources

  1. [1] NIS2 Directive (EU) 2022/2555, Article 23 (text via SpringLex)

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