Operational guidance, not legal advice. This page distills named public sources (regulator guidance and industry practice). It is not a legal determination, not a notification decision, and not a substitute for your counsel, insurer, or a retained DFIR firm. Verify applicability and current deadlines for your facts and jurisdiction.

First 24 hours after a breach

Updated

In the first 24 hours after a breach: continue the UTC timeline, put an evidence hold on logs and hosts, finish short-term containment, decide who is informed, and map which reporting clocks may have started. This page does not start a clock and is not legal advice.

Operational guidance, last verified 7 September 2026 against NIST SP 800-61r2, CISA incident-response guidance, the SANS Incident Handler's Handbook, the FTC Data Breach Response guide, Regulation (EU) 2024/2847 Article 14, and ENISA's Single Reporting Platform materials. It is not a notification determination and not a substitute for counsel, your insurer, or a retained DFIR firm.

What the first 24 hours are for

Audience: the incident commander and the leadership, counsel, and insurer already looped in during hour one. The first hour scoped systems, decided contain-versus-observe, and started a timeline. The first 24 hours finish short-term containment, hold the evidence, onboard DFIR if you need it, decide who inside the organization is told, and list which reporting clocks might already be running. Customer and regulator notice as a campaign still belong later unless counsel says a clock has started.

NIST SP 800-61r2 is still in containment here, not eradication. The SANS PICERL model does not jump to recovery because the business wants the lights back. If hour one is unfinished — no timeline, no contain-versus-observe call, counsel unpaged — do that first. This page assumes those moves have started.

  • Keep the UTC timeline. Every new fact, action, and decision is a new line, not an edit.
  • Place an evidence hold: logs, hosts, mailboxes, cloud trails. Do not rotate, reimage, or tidy.
  • Finish short-term containment. Long-term containment and eradication wait for a forensic image and a plan.
  • Onboard DFIR if you do not have in-house capture. Give them the timeline and the hold list, not a rebuilt estate.
  • Map which reporting clocks may have started. Mapping is not filing. Counsel decides applicability.
  • Decide who is informed internally. Default is need-to-know. Public posts still tip the actor.

Continue the timeline

A 24-hour timeline is the artifact later people will argue from: counsel, the insurer, DFIR, a regulator, you. SANS treats contemporaneous notes as part of identification. NIST SP 800-61r2's evidence-handling guidance is acquire, preserve, secure, and document. A reconstructed narrative written next week is a different document from the notes you took while it happened.

  • UTC. Time zone conversions after the fact are how two logs disagree.
  • Each line: time, observer, system or account, what was seen, what was done, who authorised it.
  • Add: when DFIR was retained, when the evidence hold was issued and to whom, when leadership was briefed, and the current contain-versus-observe state.
  • Record unknowns as unknowns. 'Not yet scoped: backup accounts' is a fact. Deleting the gap so the timeline looks complete is not.
  • Corrections are new lines. Do not silently rewrite an earlier entry.

Evidence hold

An evidence hold is an instruction, not a feeling. The people who can rotate logs, reimage hosts, empty mailboxes, or expire cloud trails need to hear — in writing — that they must not. The FTC Data Breach Response guide is explicit: do not destroy forensic evidence during investigation and remediation. NIST SP 800-61r2: acquire, preserve, secure, and document. CISA's ransomware guidance treats power-off and rebuild as last resorts because they destroy volatile evidence.

  • Hosts already isolated: leave powered on until memory and disk are captured, or until DFIR says otherwise.
  • Logs that rotate (EDR, identity, cloud audit, mail, VPN, WAF, CI). Extend retention now; do not wait for a ticket next week.
  • Identity artifacts: session lists, MFA enrollments, API keys, SSO audit. Capture before mass password reset from a compromised plane.
  • Backups and snapshots: preserve the copies that existed at detection. Do not 'refresh' them from a dirty primary.
  • Tell IT, cloud admins, and whoever owns SaaS admin that deletion, reimage, and tidy-up are suspended. Name a person they can call.
  • Chain of custody is a log of who touched which artifact, when, and why. You do not need a courtroom form on day one; you need an unbroken note.

Who is informed

Need-to-know is the default for the first 24 hours. CISA warns that actors monitor response activity and will move if they know they have been found. A public status page, an all-hands email, or an in-band 'we see you' message is how you tell them. NIST SP 800-61r2 expects appropriate internal parties to be notified as the incident is handled — not the whole company, and not the internet, unless your plan and counsel say so.

Who to tell in the first 24 hours (operational; not a notification filing)
AudienceIn the first 24 hours?Limit
Commander, leadership, counsel, insurer, DFIRYes — they should already be on the out-of-band bridge from hour one.One commander. Split briefings are how two stories diverge.
IT, cloud, identity, and anyone who can destroy evidenceYes — they must receive the evidence hold.Tell them what not to do. Do not broadcast the full attack narrative on a channel the actor can see.
Board / investorsIf your governance plan says the board is told at incident-declared, tell them. Otherwise counsel and the CEO decide.A board update is not a customer notice and not a regulator filing.
Workforce at large, customers, press, status pageNot by default. Public or all-hands notice is a later, counselled decision.CISA: do not tip the actor. If a legal clock requires notice inside 24 hours, that is counsel's call on your facts — not this page's.
Law enforcementThe FTC guide tells businesses to consider notifying law enforcement. CISA is the US federal cyber reporting path for many operators.Whether you must, and to whom, is jurisdiction- and sector-specific. Ask counsel. This page does not file a report.

Notification clock awareness — not a determination

Some legal regimes start an early-warning clock measured in hours from when you become aware. Others give days or 'without unreasonable delay'. Mapping which clocks might apply is first-24-hours work. Deciding that one applies, and filing, is counsel's work on your facts. This page is jurisdiction-agnostic operational guidance. It is not legal advice. Last verified 7 September 2026 against the sources below; if a later revision of a source changes a deadline, the date is how you can see we have not re-checked yet.

Do not treat 'we are not sure it is a breach' as a reason to skip the map. NIST SP 800-61r2 starts handling at detection, not at legal certainty. The map is a list of questions for counsel, not a filing.

Clocks that MAY start around 24 hours (examples only — verify applicability with counsel; not legal advice)
Kind of event (example)Clock that may runVerify before you treat it as yours
Actively exploited vulnerability in a product with digital elements you manufacture (or an in-scope open-source steward role)Regulation (EU) 2024/2847 (Cyber Resilience Act) Article 14: early warning without undue delay and in any event within 24 hours of becoming aware, to the CSIRT designated as coordinator and to ENISA via the Single Reporting Platform. Then 72-hour notification and a later final report. Article 14 reporting applies from 11 September 2026.Only if CRA applies to you and the product. Scope, 'becoming aware', and 'actively exploited' are legal and factual tests. This page does not apply them. Confirm against the regulation, ENISA's SRP materials, and counsel.
Severe incident having an impact on the security of such a productThe same CRA Article 14 24-hour early-warning / 72-hour notification ladder (final report timing differs from the vulnerability track). Same platform.Same caveat. 'Severe' is defined in the regulation, not by this page.
Other sector or jurisdiction rules (critical infrastructure, financial, health, personal data, US state statutes)Some regimes have an early-warning stage measured in hours. Many personal-data and US state breach-notification statutes are measured in days or 'without unreasonable delay', not 24 hours. The FTC guide notes every US state plus DC, Puerto Rico, and the Virgin Islands has a security-breach notification law; HIPAA and the FTC Health Breach Notification Rule may also apply. Those are usually not 24-hour clocks.Counsel maps YOUR facts to YOUR laws. Do not import a 24-hour duty from CRA or from another sector because the incident is serious. Do not ignore a shorter duty because this table led with CRA.

DFIR engagement in the first 24 hours

If you cannot capture memory and disk yourself, the first 24 hours is when a DFIR firm should already be on the way, not when you start shopping. Insurers often require you to use a panel firm and to notice them first — check the policy. A dedicated 'when you need DFIR' guide is not on this site yet. Until it is, this is the hour-to-day-one checklist.

  • Page the retained firm, or ask counsel and the insurer which panel firm to call. Do not wait for complete scope.
  • Hand them the UTC timeline, the scope list (including unknowns), the contain-versus-observe decision, and the evidence-hold list.
  • Do not rebuild, reimage, or mass-rotate before they say what they need imaged. NIST and SANS put eradication after identification and containment.
  • Keep the out-of-band bridge. Do not add the firm to a possibly compromised identity plane as their only path in.
  • One internal owner for the firm (usually the commander or counsel). Split instructions are how two images get taken and neither is complete.

Where this shows up in ShipReady Metrics

The signed-in app does not run this 24-hour plan, hold your evidence, or file a notice. If you already have a session: signed-in app → Compliance → CRA reporting tracks the 24-hour / 72-hour / 14-day ladder from your recorded awareness. It does not start a clock for you, and it is not a determination that CRA applies. A named human still submits. The cyber risk register lives under Security; the obligation map (frameworks you have marked in-scope) is under Compliance. None of those surfaces preserve volatile evidence or notify a regulator.

Primary sources (last verified 7 September 2026)

Every operational and regulatory claim on this page is taken from one of these. If a later revision of a source changes the advice, the date above is how you can see we have not re-checked yet.

Regulation (EU) 2024/2847 Article 14 is a legal requirement only when CRA applies to you. ENISA's Single Reporting Platform materials describe the filing path; they do not decide that you are in scope. NIST SP 800-61 Revision 2 remains the current final Computer Security Incident Handling Guide (August 2012) — guidance, not a statute. CISA's playbooks are operational procedures written for US federal civilian executive branch information systems. The SANS handbook is a practitioner checklist. The FTC guide is business guidance from a US regulator; the legal notification duties are in the statutes it points at, not in the guide itself.

Frequently asked questions

What should we do in the first 24 hours after a data breach?

Keep the UTC timeline, issue an evidence hold so logs and hosts are not rotated or reimaged, finish short-term containment, onboard DFIR if you lack in-house capture, decide who inside the organization is told, and map which reporting clocks may have started. Do not treat the map as a filing. NIST SP 800-61r2, CISA, SANS, and the FTC guide are the operational sources; counsel owns the legal ones.

Have our notification clocks started?

This page cannot tell you. Some regimes — including CRA Article 14 for in-scope manufacturers of products with digital elements, from 11 September 2026 — run a 24-hour early-warning clock from becoming aware. Many personal-data and US state statutes do not. Mapping possible clocks is first-24-hours work; deciding that one applies is counsel's work on your facts. Last verified 7 September 2026. Not legal advice.

Who should we tell in the first 24 hours?

The commander, leadership, counsel, the insurer, DFIR, and anyone who can destroy evidence (they need the hold). Board notice follows your governance plan. Workforce-wide, customer, press, and status-page notice are not the default: CISA warns that public or in-band messages tip the actor. If a legal clock requires notice inside 24 hours, that is counsel's call.

Do we need a DFIR firm today?

If you cannot capture memory and disk yourself, yes — page the retained firm or the insurer's panel in the first 24 hours, not after you have rebuilt. Hand them the timeline and the hold list. Do not reimage first. A longer 'when you need DFIR' guide is not on this site yet; the operational rule is: evidence you already destroyed cannot be recovered.

Is this legal advice?

No. It is a day-one plan distilled from NIST SP 800-61r2, CISA, the SANS Incident Handler's Handbook, the FTC Data Breach Response guide, Regulation (EU) 2024/2847 Article 14, and ENISA SRP materials. Whether a clock has started, whether CRA or any other regime applies, and what you must file are legal questions for counsel on your facts. This page does not start a reporting clock.

Published by ShipReady Metrics, an evidence-based technology and compliance intelligence platform. This guide is educational and vendor-neutral.