An entity reports one cyber incident
Five reports, four bodies, four clocks — 12 hours, 72 hours, 72 hours, 72 hours and 30 days — and the guidance says explicitly that none of them satisfies any of the others. The elapsed time is short and the concurrency is the point.
longest dependent chain
across 3 bodies
scheduling or queue, not assessment
vs. 131 if run end-to-end
Where the time goes
Critical-path days only. Steps that run alongside others are real work but do not lengthen the process, so counting them here would overstate the prize.
| statutory | 127d | A legislated period that must elapse regardless of readiness. |
|---|
The process, step by step
Applies when: An entity becomes aware of a cyber security incident affecting a critical infrastructure asset or personal information.
| # | Step | Who | Why it waits | Clock | Typical | Basis |
|---|---|---|---|---|---|---|
| 1 |
The entity becomes aware of an incident
assessment
Every clock in this process starts here, and they run at different speeds. |
— | assessment | — | 0 legislated | — |
| 2 |
Critical cyber security incident report
notification
Twelve hours from becoming aware, for an incident having a significant impact on a critical infrastructure asset. after
The entity becomes aware of an incident 126d slack
|
Australian Signals Directorate — Australian Cyber Security Centre | statutory | 1 | 1 legislated | Security of Critical Infrastructure Act 2018 (Cth) |
| 3 |
Other cyber security incident report
notification
Seventy-two hours, for incidents with a relevant impact that are not critical. after
The entity becomes aware of an incident 124d slack
|
Australian Signals Directorate — Australian Cyber Security Centre | statutory | 3 | 3 legislated | Security of Critical Infrastructure Act 2018 (Cth) |
| 4 |
APRA material incident notification
notification
only if triggered Seventy-two hours, on a materiality test defined by depositor, policyholder and beneficiary interests. Triggered when: The entity is APRA-regulated — a bank, insurer or superannuation fund. after
The entity becomes aware of an incident 124d slack
|
Australian Prudential Regulation Authority | statutory | 3 | 3 legislated | APRA Prudential Standard CPS 234 |
| 5 |
Ransomware or extortion payment report
notification
only if triggered Seventy-two hours after a payment is made, for entities above $3 million turnover and all critical infrastructure entities. Triggered when: A ransomware or cyber extortion payment is made, and the entity has annual turnover above $3 million or is responsible for a critical infrastructure asset. after
The entity becomes aware of an incident 124d slack
|
Australian Signals Directorate — Australian Cyber Security Centre | statutory | 3 | 3 legislated | Cyber Security Act 2024 (Cth) |
| 6 |
Assess whether it is an eligible data breach
assessment
Thirty days to assess a suspected breach — the longest clock, and the only one asking about harm to individuals. after
The entity becomes aware of an incident 97d slack
|
Office of the Australian Information Commissioner | statutory | 30 | 30 legislated | Privacy Act 1988 (Cth) |
| 7 |
Notify the OAIC and affected individuals
notification
As soon as practicable once the breach is assessed as eligible. after
Assess whether it is an eligible data breach 90d slack
|
Office of the Australian Information Commissioner | statutory | — | 7 legislated | Privacy Act 1988 (Cth) |
| 8 |
Annual CIRMP report and board attestation
certification
Ninety days after financial year end — 28 September for a 30 June year end.
|
Australian Signals Directorate — Australian Cyber Security Centre | statutory | 90 | 90 legislated | Security of Critical Infrastructure Act 2018 (Cth) |
on the critical path scheduling/queue = delay not caused by the assessment itself
Proposed changes
-
One incident, five reports, four regulators, and the law says none of them counts for the others
merge
A regulated Australian entity suffering one intrusion owes a 12-hour report to ASD, a 72-hour report to ASD, a 72-hour report to APRA, a 72-hour ransomware payment report to ASD again, and a Privacy Act assessment and notification. The guidance states explicitly that these do not satisfy each other.
-
Twelve hours, written by the people currently containing the intrusion
resequence
A critical cyber security incident must be reported within 12 hours of the entity becoming aware. At twelve hours an organisation usually does not know what happened, and the people who could find out are the people writing the report.
Sources
- Security of Critical Infrastructure Act 2018 (Cth): critical cyber security incidents reportable within 12 hours of becoming aware; other cyber security incidents within 72 hours
- Privacy Act 1988 (Cth), Notifiable Data Breaches scheme: assess and notify as soon as practicable and within 30 days of becoming aware
- Cyber Security Act 2024 (Cth) and Cyber Security (Ransomware Payment Reporting) Rules 2025: ransomware payment reportable within 72 hours; commenced 30 May 2025; enforcement from 1 January 2026
- APRA Prudential Standard CPS 234: notify APRA as soon as possible and no later than 72 hours after becoming aware of a material information security incident
- The OAIC 30-day rule does not replace SOCI incident reporting; the regimes run in parallel and do not satisfy each other
- Notifications to the ACSC are in addition to any other notifications the entity may be required to make at law
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