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What should I do in the first 6 hours after a data breach?

CERT-In requires Indian organisations to report listed incidents within six hours of noticing them or being brought to notice of them. Report what you know, not what you wish you knew: an initial filing at hour four naming the affected system, the closest Annexure I category, and the occurrence and detection timestamps is compliant. File on incident@cert-in.org.in or 1800-11-4949.

Key takeaways

  • CERT-In's 6-hour reporting window starts when you notice the incident or are brought to notice of it, not when you finish investigating it.
  • An initial filing at hour four with the affected system, the closest Annexure I category and both timestamps is compliant; certainty is not required.
  • CERT-In directions require 180 days of logs, so clock synchronisation on domain controllers, firewalls and servers decides whether you can prove when you knew.
  • Log out compromised accounts and revoke sessions in the first hour, because a live attacker session will destroy the evidence you need.
  • DPDP Rule 7 notification obligations commence from May 2027, and 83% of Indian organisations have not begun comprehensive DPDP implementation, so prepare the breach register now.

As of 24 October 2026: the service descriptions, prices and turnaround figures on this page are current.

How does the six-hour CERT-In rule actually work?

The rule is a hard deadline with a single trigger. Once you notice a listed incident, or you are brought to notice of one, six hours start running, and the report goes to incident@cert-in.org.in or on 1800-11-4949. Listed incidents include ransomware, data breaches, data leaks, and attacks on digital assets. Two consequences follow. First, the obligation is to report, not to complete an investigation, so a preliminary filing that states what is known is compliant and an accurate later update is expected. Second, because the clock is tied to notice rather than to certainty, the trigger is often earlier and vaguer than teams assume: a third-party supplier telling you that your data was exposed is a notice, and so is a researcher emailing you a copy of your customer table.

What should I include in the hour-four report?

Six elements, and nothing speculative. The date and time of the occurrence, or the best estimate of the breach window. The date and time of detection, and the date and time you were first notified if that is different. The affected system, named precisely, including the application, the host and the data category. The closest category in CERT-In's Annexure I, chosen as best fit rather than a perfect one. A description of the incident in plain terms, with the suspected cause where known. And a point of contact with a working phone number, because CERT-In calls back and an unreachable contact is a compliance failure. Keep the report short and factual. The 180-day log retention requirement means your own logs may be the evidence that supports or contradicts this filing.

Why does clock synchronisation decide whether you were in time?

Because the timestamps in your report are only credible if the systems that produced them agree. If a domain controller, a firewall and a database server are minutes apart, then the detection time you certify is a guess, and in a dispute the discrepancy is the argument. Time synchronisation across domain controllers, servers, firewalls and endpoints has to be configured and monitored, and the offset recorded, well before an incident. It is also what makes the 180-day log requirement usable: a log with wrong timestamps is evidence of nothing. This is a small control with a disproportionate effect on how defensible your 6-hour filing is, and it is the control most often missing when a filing is challenged.

What is the second clock, and what should you do about it now?

The second clock is the Digital Personal Data Protection Act 2023 and its Digital Personal Data Protection Rules. Rule 7 notification obligations commence from May 2027, and once in force they will require notification to the Data Protection Board and to affected data principals in addition to the CERT-In report. The two clocks are different in scope and will not align neatly, so build a single breach register now: a log of every incident with its occurrence, detection, notification and report timestamps, the data categories involved, and the containment steps. 83% of Indian organisations have not begun comprehensive DPDP implementation, so the organisations that build this register early will be ready to file both reports without reconstructing a timeline under pressure.

The first six hours after a data breach, in sequence
HourActionWhy it is at that point
0-1Isolate affected systems, revoke sessions, log out compromised accountsStops ongoing loss and preserves the access trail
1-2Preserve logs and volatile evidence, freeze logs and clock sources180-day logs are what prove your detection time
2-3Assess data categories and systems affected, identify the Annexure I categoryThe report needs a category, not a conclusion
3-4File the CERT-In report to incident@cert-in.org.in or 1800-11-4949An hour-four filing is compliant; hour thirty is late
4-5Involve legal, insurer and CERT-In empanelled incident responderNotification and insurance deadlines run in parallel
5-6Prepare affected-individual notification text and contact listDPDP Rule 7 applies from May 2027

What are the frequently asked questions?

What should I do in the first 6 hours after a data breach?
CERT-In requires Indian organisations to report listed incidents within six hours of noticing them or being brought to notice of them. Report what you know, not what you wish you knew: an initial filing at hour four naming the affected system, the closest Annexure I category, and the occurrence and detection timestamps is compliant. File on incident@cert-in.org.in or 1800-11-4949.
What counts as a listed incident for CERT-In?
Annexure I of the CERT-In directions covers seven categories including data breaches and data leaks, ransomware, and attacks on digital assets. A breach involving customer personal data falls squarely inside the list, and the category is what the report must name.
Do I need a completed investigation before I report?
No. The obligation is to report within six hours of notice, so an accurate preliminary filing with occurrence and detection timestamps is compliant. Investigations continue afterwards and updates follow.
What if the breach happened at a supplier?
Being brought to notice by the supplier starts your six-hour clock as well, so report it. You also need your supplier's facts: what data, which systems, when they noticed, and what they have remediated.
When do I have to tell my customers?
The CERT-In obligation comes first and runs in parallel. Under the DPDP Rules, Rule 7 notification obligations commence from May 2027, and after that you will have a separate obligation to notify the Data Protection Board and affected individuals.

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Call +91 98473 40580 and we will run the 6-hour CERT-In reporting checklist with you, starting with the affected system and timestamp.

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Last reviewed: 24 October 2026. Information on this page is general guidance, not legal advice. Prices are indicative bands for a typical scope and are confirmed in a written quote before any work begins.