Contents
In 30 seconds
- Isolate, don’t power off: disconnecting preserves evidence; shutting down can destroy it and makes it harder to confirm the attacker is gone 25.
- In Moldova, a provider identified under Law 48 notifies the ASC within 24 hours, updates within 72 hours and sends the final report within a month 13.
- Payment providers notify the NBM on the same working day; personal data breaches go to the CNPDCP within 72 hours 1719.
- US and UK authorities and ENISA do not encourage paying the ransom: it does not guarantee recovery and funds new attacks 7912.
- Before returning to production, check backups and restored assets, then get independent validation 14.
The first hours: do’s and don’ts
The first decisions determine whether you will still be able to find out what happened. CISA and NCSC guidance says the same: isolate in a coordinated way, preserve evidence, communicate on a channel the attacker cannot see 25.
- Isolate affected systems; if there are many, take the network offline at the switch. In the cloud, take a volume snapshot 2.
- Power devices off only if you cannot disconnect them: shutting down destroys evidence in volatile memory 2.
- Take system images and memory captures on a sample of devices, starting with volatile evidence 2.
- Keep a central decision log — what, when, who, why — with standardised time 5.
- Investigate, as far as possible, before restoring 5.
The conflict between preserving evidence, containment and continuity is real; ENISA asks for it to be decided through a clear, pre-agreed process with chain-of-custody rules 8. The ASC methodological guide adopts the same requirement for Moldova 25.
Whom to notify, and how fast
In the Republic of Moldova, the competent authority is the Cybersecurity Agency (ASC), which is also the national incident response team 1314. A provider identified under Law 48/2023 notifies it within 24 hours of becoming aware — even when significant impact can only be reasonably assumed — follows up with an update within 72 hours and a final report within a month 13. Notification is made through the “Report an incident” form on ncsc.md 16; the official template provided for by Decision 562/2025 is approved by the ASC director 15.
| Who | To whom | Deadline |
|---|---|---|
| Identified provider (Law 48) | ASC; users, on a significant threat | 24 h / 72 h / one month 13 |
| Bank, payment provider | NBM, through PCSI | Same day / 3 days / 20 days 19 |
| Any data controller (Moldova) | CNPDCP | 72 h where feasible 1718 |
| NIS2 entity (Romania) | DNSC, through PNRISC | 6 h cross-border / 24 h / 72 h / one month 20 |
| Data controller (Romania) | ANSPDCP | 72 h where feasible 2122 |
The new personal data law, Law 195/2024, has been in force since 23 August 2026 and adopts the GDPR rules: notification within 72 hours “where feasible”, with the reasons if late, informing people at high risk, and documenting every breach 1722. A Moldovan company with EU customers and a representative there has no “one-stop shop”: it notifies every authority in the states where affected people live 23.
The notification clock: who, and how fast
Indicative, based on the legal texts cited below; not legal advice. Deadlines run from the moment you became aware of the incident.
Your notification calendar
- 24 hASC: incident notification
From becoming aware; also when significant impact can only be reasonably assumed. Law 48/2023, Art. 12(1).
- 24 hUsers: the significant threat
Informing affected users; otherwise the ASC demands it and, after 3 hours, notifies them itself. Art. 12(6)–(7).
- 72 hASC: the update
Initial assessment and indicators of compromise. Art. 12(3).
- 72 hCNPDCP: the personal data breach
Where feasible, within 72 hours at most; if later, with the reasons for the delay. Law 195/2024, Art. 33.
- +1 monthASC: the final report
Within one month of the update; if the incident is ongoing, a progress report first. Art. 12(8); Decision 562/2025, point 19.
- Day 0NBM: initial notification (critical functions)
By the end of the working day; if the incident occurred less than 2 hours before close, within 4 hours of the start of the next day. Through PCSI or to [email protected]. Point 81.1.
- Day 1NBM: initial notification (payment services)
For significant functions or payment service continuity: by the next working day at the latest. Point 81.2.
- 72 hCNPDCP: the personal data breach
Where feasible, within 72 hours at most; if later, with the reasons for the delay. Law 195/2024, Art. 33.
- ≤ 3 daysNBM: intermediate report
Circumstances, affected systems, estimated impact and measures taken. Point 81.3.
- ≤ 20 daysNBM: final report, signed by management
Root causes, actual impact and measures to prevent recurrence. Point 81.4.
- Any timeASC: voluntary notification
Open to anyone, with no new obligations; the “Report an incident” form on ncsc.md. Law 48/2023, Art. 13.
- 72 hCNPDCP: the personal data breach
Where feasible, within 72 hours at most; if later, with the reasons for the delay. Law 195/2024, Art. 33.
- 6 hPNRISC: cross-border impact
From any information indicating cross-border impact. A Romanian rule, on top of NIS2. GEO 155/2024, Art. 15(3).
- 24 hPNRISC: early warning
With any suspicion of unlawful acts and cross-border impact. Art. 15(7)(a).
- 72 hPNRISC: incident report
Initial assessment and indicators of compromise. Art. 15(7)(b).
- 72 hANSPDCP: personal data breach
Without undue delay, where feasible within 72 hours; the standard form or online notification. GDPR, Art. 33.
- +1 monthPNRISC: final report
Within one month of the 72 h report; an intermediate report if requested. Art. 15(7)(c)–(d).
- 72 hThe data protection authority
Without undue delay, where feasible within 72 hours; information may be provided in phases. GDPR, Art. 33(1), (4).
- No notificationWith no personal data affected, GDPR requires no notification
Still check whether you fall under NIS2 or a sector law.
- High riskThe data subjects
Without undue delay if the risk to them is high; not required if the data was encrypted and unintelligible. GDPR / Law 195/2024, Art. 34.
- AlwaysDocumenting the breach
Every breach is documented, even those not notified. Art. 33(5).
If you are also a provider identified under Law 48/2023, the ASC deadlines apply as well.
Do you have EU customers and a representative there? Notify every authority in the states where affected people live (EDPB 9/2022, point 73).
In the first hours
- Isolate, don’t power off: disconnect systems from the network; shutting down destroys evidence in memory.
- Communicate on a separate channel from the compromised network, so as not to alert the attacker.
- Preserve evidence: disk images, memory captures, logs — before any remediation.
- Don’t touch the attacker’s infrastructure (ping, nslookup) and don’t reset passwords in a hurry.
- Keep a decision log: what, when, who, why — with standardised time.
- Start the notification clock from the moment you became aware of the incident.
Ransomware: to pay or not
The official position is the same on both sides of the Atlantic. CISA and the FBI “do not encourage paying”: it does not guarantee recovery and encourages further attacks; report anyway, whether you pay or not 12. NCSC UK stresses that law enforcement does not encourage, endorse or condone payment, and ENISA advises not to pay and not to negotiate 79. Even after paying, decryption can take weeks and does not fix the vulnerabilities the attacker came through 6.
The EDPB guidelines treat ransomware separately: if there is a backup and no data was exfiltrated, notification may not be required, but the breach is documented; and risk assessment does not wait for the forensic report 24.
Containment, eradication, recovery
In 2025 NIST rewrote its incident response guide (SP 800-61 Rev. 3) as a CSF 2.0 profile: the old phases map onto the framework’s functions, and lessons learned are shared immediately, not only at the end 1.
| Rev. 2 phase | CSF 2.0 functions in Rev. 3 |
|---|---|
| Preparation | Govern, Identify, Protect 1 |
| Detection and analysis | Detect, plus improvement (ID.IM) 1 |
| Containment, eradication, recovery | Respond, Recover, plus improvement 1 |
| Post-incident activity | Improvement (ID.IM) 1 |
- Establish the root cause and look for indicators of compromise and persistence on unconfirmed targets too — otherwise you underestimate the scope 1.
- Check backup integrity before restoring — NCSC advises assuming they may be compromised too 16.
- Before production, check restored assets for indicators of compromise and fix the root cause 1.
- Look for the “precursor” malware (the dropper) before rebuilding 2.
- Declare the incident over against criteria and write an after-action report 1.
After the incident: proof the breach is closed
Systems working again does not mean the attacker has left. After eradication, CISA calls for monitoring for re-entry, an independent test or review to validate the return to normal, testing controls before production, and emulating the attacker’s tactics to verify countermeasures 4. Advisory AA20-245A recommends having eradication confirmed by a third party 3, and NCSC notes partners may ask for independent assurance before reconnecting to your systems 6.
The lessons-learned meeting is held with owners and deadlines; findings feed into the risk assessment, and logs are kept for at least 12 months 1815.
How we help after an incident
- Compromise assessment
We look for the attacker’s traces and persistence mechanisms on restored and unconfirmed systems.
- Retesting the entry vector
We verify the vulnerability the attacker came through is closed and that there is no alternative route.
- Attack emulation
We replay the attacker’s tactics so you can see whether the new detection and countermeasures work.
- A report for the authority and partners
Findings, evidence and the conclusion of the independent test, ready to attach to the final report.
Frequently asked questions
Should I switch off the affected computers?
How quickly must an incident be reported in Moldova?
Must the data protection authority be notified too?
Should we pay the ransom?
How do we prove the attacker is gone?
Sources
Every statement about a law or standard links to its official source. Consulted on the date shown.
- NIST SP 800-61 Rev. 3 — Incident Response Recommendations and Considerations for Cybersecurity Risk Management (April 2025)csrc.nist.gov · accessed 23 October 2026
- CISA, FBI, NSA — #StopRansomware Guide (September 2023)cisa.gov · accessed 23 October 2026
- Joint advisory AA20-245A — Technical Approaches to Uncovering and Remediating Malicious Activitycisa.gov · accessed 23 October 2026
- CISA — Incident & Vulnerability Response Playbooks (November 2021)cisa.gov · accessed 23 October 2026
- NCSC UK — Recovering from a highly disruptive cyber attack: immediate activities (2026)ncsc.gov.uk · accessed 23 October 2026
- NCSC UK — Recovering from a highly disruptive cyber attack: rebuild (2026)ncsc.gov.uk · accessed 23 October 2026
- NCSC UK — Mitigating malware and ransomware attacksncsc.gov.uk · accessed 23 October 2026
- ENISA — NIS2 Technical Implementation Guidance (June 2025)enisa.europa.eu · accessed 23 October 2026
- ENISA — Threat Landscape for Ransomware Attacks (July 2022)enisa.europa.eu · accessed 23 October 2026
- Europol — the launch of No More Ransom (25 July 2016)europol.europa.eu · accessed 23 October 2026
- Europol — No More Ransom at six: 136 free tools (26 July 2022)europol.europa.eu · accessed 23 October 2026
- CISA, FBI — advisory AA25-071A (revised 2026)cisa.gov · accessed 23 October 2026
- Law No. 48/2023 on cybersecurity (consolidated)legis.md · accessed 23 October 2026
- Government Decision No. 1028/2023 — Cybersecurity Agencylegis.md · accessed 23 October 2026
- Government Decision No. 562/2025 — security requirements and incident notificationlegis.md · accessed 23 October 2026
- ASC — “Report an incident”ncsc.md · accessed 23 October 2026
- Law No. 195/2024 on personal data protectionlegis.md · accessed 23 October 2026
- CNPDCP — personal data breach notificationdatepersonale.md · accessed 23 October 2026
- NBM — ICT regulation (Decision No. 29/2025)bnm.md · accessed 23 October 2026
- Emergency Ordinance No. 155/2024 (Romania), approved by Law No. 124/2025legislatie.just.ro · accessed 23 October 2026
- ANSPDCP — personal data breach notification formdataprotection.ro · accessed 23 October 2026
- Regulation (EU) 2016/679 (GDPR), consolidated versioneur-lex.europa.eu · accessed 23 October 2026
- EDPB — Guidelines 9/2022 on personal data breach notificationedpb.europa.eu · accessed 23 October 2026
- EDPB — Guidelines 01/2021, notification examples (including ransomware)edpb.europa.eu · accessed 23 October 2026
- ASC — Methodological guide for applying cybersecurity requirements (approved 8 April 2026)ncsc.md · accessed 23 October 2026
About the authors
The guides are written by the team that does the testing, not a marketing department. We update them when the law, the standard or what we see in testing changes.