Practical guide · Incident response

After a cyber incident:
the first hours and what follows

What to do immediately, whom to notify and how fast in Moldova and Romania, what authorities say about ransomware, and how to show the attacker is really gone.

Updated 9 min read 25 cited sources
Contents
  1. The first hours: do’s and don’ts
  2. Whom to notify, and how fast
  3. Ransomware: to pay or not
  4. Containment, eradication, recovery
  5. After the incident: proof the breach is closed
  6. How we help after an incident
  7. Frequently asked questions
  8. Sources

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.
ASC (Law 48)
24 h 13
NBM
same day 19
Personal data
72 h 1722
The ransom
don’t pay 12

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.

WhoTo whomDeadline
Identified provider (Law 48)ASC; users, on a significant threat24 h / 72 h / one month 13
Bank, payment providerNBM, through PCSISame day / 3 days / 20 days 19
Any data controller (Moldova)CNPDCP72 h where feasible 1718
NIS2 entity (Romania)DNSC, through PNRISC6 h cross-border / 24 h / 72 h / one month 20
Data controller (Romania)ANSPDCP72 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.

Which regime is your organisation under?
Did the incident affect personal data?

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 phaseCSF 2.0 functions in Rev. 3
PreparationGovern, Identify, Protect 1
Detection and analysisDetect, plus improvement (ID.IM) 1
Containment, eradication, recoveryRespond, Recover, plus improvement 1
Post-incident activityImprovement (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

  1. Compromise assessment

    We look for the attacker’s traces and persistence mechanisms on restored and unconfirmed systems.

  2. Retesting the entry vector

    We verify the vulnerability the attacker came through is closed and that there is no alternative route.

  3. Attack emulation

    We replay the attacker’s tactics so you can see whether the new detection and countermeasures work.

  4. 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?
As a rule, no: disconnect them from the network. Shutting down destroys evidence in volatile memory; power off only devices you cannot disconnect 25.
How quickly must an incident be reported in Moldova?
Providers identified under Law 48/2023 notify the ASC within 24 hours, follow up within 72 hours and send the final report within a month; payment providers notify the NBM on the same working day 1319.
Must the data protection authority be notified too?
If personal data is affected, yes: in Moldova the CNPDCP, under Law 195/2024, within 72 hours where feasible; in Romania the ANSPDCP, under the GDPR. Notifying the cyber authority does not replace it 172122.
Should we pay the ransom?
Authorities do not encourage it: paying does not guarantee recovery, encourages further attacks and does not close the breach. First check the No More Ransom tools, and report the incident anyway 61112.
How do we prove the attacker is gone?
Through monitoring after eradication and an independent test or review that includes emulating the attacker’s tactics; CISA and NCSC recommend third-party confirmation 346.
Can we restore straight from backups?
Only after checking their integrity: NIST requires checking backups before restoring and restored assets before production, and NCSC advises assuming backups may be compromised too 16.

Sources

Every statement about a law or standard links to its official source. Consulted on the date shown.

  1. NIST SP 800-61 Rev. 3 — Incident Response Recommendations and Considerations for Cybersecurity Risk Management (April 2025)csrc.nist.gov · accessed 23 October 2026
  2. CISA, FBI, NSA — #StopRansomware Guide (September 2023)cisa.gov · accessed 23 October 2026
  3. Joint advisory AA20-245A — Technical Approaches to Uncovering and Remediating Malicious Activitycisa.gov · accessed 23 October 2026
  4. CISA — Incident & Vulnerability Response Playbooks (November 2021)cisa.gov · accessed 23 October 2026
  5. NCSC UK — Recovering from a highly disruptive cyber attack: immediate activities (2026)ncsc.gov.uk · accessed 23 October 2026
  6. NCSC UK — Recovering from a highly disruptive cyber attack: rebuild (2026)ncsc.gov.uk · accessed 23 October 2026
  7. NCSC UK — Mitigating malware and ransomware attacksncsc.gov.uk · accessed 23 October 2026
  8. ENISA — NIS2 Technical Implementation Guidance (June 2025)enisa.europa.eu · accessed 23 October 2026
  9. ENISA — Threat Landscape for Ransomware Attacks (July 2022)enisa.europa.eu · accessed 23 October 2026
  10. Europol — the launch of No More Ransom (25 July 2016)europol.europa.eu · accessed 23 October 2026
  11. Europol — No More Ransom at six: 136 free tools (26 July 2022)europol.europa.eu · accessed 23 October 2026
  12. CISA, FBI — advisory AA25-071A (revised 2026)cisa.gov · accessed 23 October 2026
  13. Law No. 48/2023 on cybersecurity (consolidated)legis.md · accessed 23 October 2026
  14. Government Decision No. 1028/2023 — Cybersecurity Agencylegis.md · accessed 23 October 2026
  15. Government Decision No. 562/2025 — security requirements and incident notificationlegis.md · accessed 23 October 2026
  16. ASC — “Report an incident”ncsc.md · accessed 23 October 2026
  17. Law No. 195/2024 on personal data protectionlegis.md · accessed 23 October 2026
  18. CNPDCP — personal data breach notificationdatepersonale.md · accessed 23 October 2026
  19. NBM — ICT regulation (Decision No. 29/2025)bnm.md · accessed 23 October 2026
  20. Emergency Ordinance No. 155/2024 (Romania), approved by Law No. 124/2025legislatie.just.ro · accessed 23 October 2026
  21. ANSPDCP — personal data breach notification formdataprotection.ro · accessed 23 October 2026
  22. Regulation (EU) 2016/679 (GDPR), consolidated versioneur-lex.europa.eu · accessed 23 October 2026
  23. EDPB — Guidelines 9/2022 on personal data breach notificationedpb.europa.eu · accessed 23 October 2026
  24. EDPB — Guidelines 01/2021, notification examples (including ransomware)edpb.europa.eu · accessed 23 October 2026
  25. 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.

The Pentest.md teamSecurity engineers holding CEH, CISSP, CISA and CISM certifications

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