WorkflowSecurity Compliance Automation (SOC 2, ISO 27001, NIS2)

Cyber Incident Reporting

Cyber incident reporting requirements, answered from one cited set of facts, with the General Counsel deciding

Every regulator clock met, from one cited set of facts the committee signed.

See one case, screen by screen ↓
demo7clocksone per regulator for the sample ransomware incident, each counted from its own trigger
demo24factsfrom 13 updates, each with when it happened and when it was known
demo4disagreementsbetween the notices and the facts, found by a blind re-read before sending
target< 1hourto draft every notice from one set of facts
In short

What is Cyber Incident Reporting?

Cyber Incident Reporting helps the General Counsel and CISO work through each cyber incident reporting requirement — SEC Form 8-K Item 1.05, NIS2, DORA and GDPR — from one cited set of facts. Seven agents map who reports to whom, keep a timeline of what was known and when, weigh materiality on a scale where every factor cites its source, draft each notice and re-check them against each other. The disclosure committee votes, the General Counsel records the determination and named signers submit.

How to choose AI solutions for back-office and enterprise work →

Updated

The problem

Why one cyber incident becomes four notices that disagree

One incident at a US-listed group with EU businesses starts several legal clocks, each from a different trigger. NIS2 runs from awareness of a significant incident: a 24-hour early warning, a 72-hour notification and a one-month final report. DORA runs from classifying the incident as major at a financial entity. GDPR runs from awareness of a personal-data breach. Form 8-K Item 1.05 is due four business days after the company determines the incident is material — and that determination is the General Counsel's to make and defend.

Meanwhile the facts arrive piecemeal from the forensic firm, the plants and finance, and they keep changing. The disclosure committee argues materiality from a slide deck, the basis of the decision is rarely recorded, and four authors write four notices from four versions of the facts. A German notice says no data was taken, and two hours later forensics confirm 412 GB left the network. In October 2024 the SEC penalised four companies for describing known breaches more softly than the facts they had.

typical4business daysto file Form 8-K Item 1.05 after the materiality determination
typical24hoursfor a NIS2 early warning from awareness, 72 for the notification
typical$7Min SEC penalties in all, on four companies in October 2024, for downplaying known breaches
Where an incident's reporting hours goestimated
By hand43 days
With the solution7.5 days
  • Working out which entity reports to which regulator6 → 0.5 d
  • Keeping the facts straight as forensic updates arrive10 → 2 d
  • Building the materiality case for the committee8 → 2 d
  • Drafting the 8-K, NIS2, DORA and GDPR notices12 → 1 d
  • Checking the notices against each other and the facts4 → 0.5 d
  • Sign-off, submission and keeping the receipts3 → 1.5 d

Estimated split for one significant incident at a listed group with EU entities, by hand and with the solution.

How it works

How an incident becomes every regulator's notice

Seven agents map, keep the facts, weigh, draft and re-check blind; the committee votes and the General Counsel decides.

What comes in
Incident data inSOC cases, forensic updates · plants, finance, playbook
Agents at work
Triage agentwho reports to whom
Facts agentwhat was known, when
Then
Classification agentNIS2 · DORA · GDPR
Materiality agentweighs the scale
Then
Drafter agentone fact set
Then
Consistency agentre-reads blind
Clock keeperevery deadline
A person decides
Disclosure committee and General Counselvote, record, sign, submit
What comes out
Recorded determination
Notices on time
Decision file
One case, step by step

One ransomware incident, from the forensic update to a recorded determination

Friday night, ransomware encrypts the plant servers at Ghent, Genk and Duisburg and production stops for 41 hours; a directory outage takes down the merchant portal of the group's Dutch payment institution. By Monday afternoon the early warnings are sent, forensic update 7 says 412 GB were copied out, and the disclosure committee has voted. Here is the afternoon, screen by screen, in the working solution.

  1. 01Monday afternoon

    What needs her, in four lines from the agents

    Maria Lindqvist · General Counsel

    Maria's home screen says it plainly: 1 incident needs her decision, the CCB notification is due in 9 h 12 m, and 4 disagreements between notices are waiting. Below it, each agent that ran overnight and this morning has left one message with its proposal, its citation and one button — open the scale, review the four fixes, open the CCB notice, review the triage of a new phishing case.

    Materiality agent: “INC-2026-0917 leans material, 12 to 6. The committee voted 4 of 4 ‘material’ at 13:40. Your determination starts the SEC clock.”

  2. 02The scale

    Is this incident material? Twelve to six, and why

    Materiality agent

    Above the scale, seven clocks — one per regulator, each from its own trigger. The SEC clock reads “Starts at the decision”; the CCB 72-hour notification shows 9 h 12 m; the BSI notification says “Update needed”. On the scale, operations, data taken, customers, public attention and regulators weigh 12 towards material; revenue, cost, containment and payments weigh 6 against. The agent explains: on the numbers alone it would not be material — $8.2M is 0.36% of group quarterly revenue — but the qualitative factors decide it.

    “The SEC asks for both kinds of factor.”

  3. 03One click

    Every weight opens the passage it rests on

    Maria Lindqvist · General Counsel

    She clicks Data taken. The weight is 3, heavy, and it rests on three facts from forensic update 7: 412 GB copied out from Ghent file server GNT-FS-02, personal data of 6,180 employees in Belgium and Germany, and engineering drawings belonging to two customers. The passage is highlighted. A weight can be changed here, but only with a reason, and the change goes on the record.

    Materiality agent: “Personal data and customers’ drawings; a reasonable investor would want to know. Weight 3.”

  4. 04She asks back

    “What if no data had been taken?” — the scale moves

    Materiality agent

    Maria asks the question her board will ask. The agent takes Data taken off the scale and the beam re-tilts to 9 to 6: still material, on operations and customers. Without the leak-site claim as well, it would be 7 to 6, close to balanced, and the agent would advise “not yet determinable”. Nothing is saved; the what-if resets.

    “This what-if is not saved; reset it any time.”

  5. 05As of 09:40

    What was known, and when

    Facts agent

    The facts agent keeps 24 facts from 13 updates, each with when it happened and when it was known, its source and its status; an early estimate of 2,900 merchants is marked superseded by the confirmed 3,420. Maria replays the case as of 09:40 Monday, when the BSI notice went out, and every fact learned later fades. It is how she will show, a year from now, what the company knew when it decided.

    “Replay. Showing the case as it was known at Mon 12 Oct 09:40. Facts learned later are faded.”

  6. 06Drafted at 12:20

    Four notices from one set of facts

    Drafter agent

    The 8-K Item 1.05, the CCB 72-hour notification, the BSI update and the DORA intermediate report are drafted from fact set v9. Every sentence carries a chip for the fact it rests on. The 8-K draft waits for the determination; when it is recorded, the drafter adds the date and the SEC clock starts. The GDPR notice is the privacy team's and stays read-only.

    Drafter agent: “I write; I never submit. Each notice goes to its named signer.”

  7. 07Re-read blind

    Four disagreements, both passages side by side

    Consistency agent

    The consistency agent re-read 5 notices without seeing who wrote them, against each other and the 24 facts. Two are high: the BSI notice says “There is no indication of data exfiltration at this stage” while forensic update 7 says 412 GB were copied out, and the 8-K names the remote-access gateway and its unpatched flaw, detail Item 1.05 Instruction 4 says need not be disclosed. Two are medium: the 8-K says operations were “temporarily disrupted” where the CCB notice says “stopped for 41 hours”, and the DORA draft counts 3,240 merchants where the facts say 3,420. Each comes with a proposed fix to accept or reject, with a reason.

    “A softer description in the SEC filing than in an EU notice is the pattern the SEC penalised in October 2024.”

  8. 0812:30–13:40

    Four votes, each in the member's own words

    Disclosure committee

    Five voting members, quorum four, Maria in the chair. Rachel Thornbury: “Small against the group's revenue, but the customer penalties and the drawings are not small.” Henrik Aalto, Luis Ferreira and Nadia Brecht vote material too, each with a comment the minutes keep; outside counsel's memo is marked privileged, and the agents have no access to it. The drafter writes the minutes, and decision record D-0917-01 waits for the General Counsel.

  9. 0914:05

    She records the determination, and signs

    Maria Lindqvist · General Counsel

    Three outcomes are offered — material, not material (no Item 1.05 filing; she may disclose under Item 8.01) or not yet determinable, with a next review. She chooses material with reason codes M1 operational disruption, M2 data taken and M3 customer and contract impact, and a note for the record. She ticks the statement and signs. The SEC clock starts: the 8-K is due Fri 16 Oct, 17:30 ET.

    “I, Maria Lindqvist, General Counsel, record this determination for Kestrel & Vane Group on the facts known at 14:05.”

  10. 10Due tonight

    Each named signer submits, and the receipt is kept

    Clock keeper

    The filings screen lists every notice with its regulator, portal, signer, due time and receipt: the CCB and BSI early warnings, the DORA initial notification, the GDPR notification and the BSI notification, five sent, every one on time. The CCB notification is ready for Henrik Aalto's signature with 9 h 12 m left; the 8-K, now determined material, is due Fri 16 Oct, 17:30 ET, and three open items are watched for the 8-K/A. The clock keeper reminds and escalates, but never submits.

    “7 regulator clocks, none missed · 5 notices sent, every one on time · agents never submit: the named signer does.”

Who it’s for

Built for everyone who answers for the disclosure.

The same incident, seen by five of the people who carry it — what the first days looked like, and what they look like now.

ML
Maria LindqvistGeneral Counsel · chairs the disclosure committee
General Counsel
Before
Owns the materiality determination and the 8-K while three regulators and the board want answers the same morning, and the basis of the decision lives in a slide deck.
Now
Records the determination on a scale where every weight cites its source, with reason codes and her signature, and can replay what was known at that moment.
HA
Henrik AaltoGroup CISO · NIS2 contact for the Belgian entity
Group CISO
Before
Runs the response, briefs the committee and retypes the same facts into four portals, with four different answers.
Now
Signs the CCB notice drafted from the same facts as the 8-K, already checked against every other notice, with the receipt kept on the filing.
RT
Rachel ThornburyCFO · disclosure committee member
Chief Financial Officer
Before
Signs off the quantitative impact and is asked to vote on materiality from a slide.
Now
Sees the numbers on both sides of the scale, where each one came from, and casts her vote with a comment the record keeps.
JM
Joelle MartensHead of Incident Response · Industrial segment, Ghent
Head of Incident Response
Before
Takes the forensic firm's updates every few hours and tries to keep the facts straight while the notices fall behind them.
Now
Confirms or disputes each fact the agent reads in, with when it happened and when it was known, and sees which notices a new fact affects.
EV
Eleanor VossInternal audit · read-only
Internal audit
Before
Reconstructs after the fact who knew what, who decided and when, from e-mail and meeting notes.
Now
Reads every action by people and agents in one trail that cannot be edited, and exports the decision file.
Built on the engine

7 agents. Each with one job, and hard limits.

Seven agents map, keep the facts, weigh, draft and re-check blind; the committee votes and the General Counsel decides.

Triage agent

Reads each SOC case, finds the affected legal entities from the entity register and tests which reporting regimes may apply — SEC, NIS2 per country, DORA, GDPR — with the reason and the clock for each.

  • Never closes an incident or records it not reportable
  • Never contacts a regulator
  • Every row of the reporting map carries its reason
Facts agent

Reads forensic, operations, finance and threat-intelligence updates and keeps one timeline of facts, each with when it happened, when it was known, its source passage and its status; a fact that replaces another marks the old one superseded.

  • No fact without a source passage
  • Estimates are marked as estimates
  • Privileged material stays in the privileged workspace
Classification agent

Tests NIS2 significance per entity and country, DORA major per financial entity under RTS 2024/1772, and GDPR personal-data breaches, and starts each clock from its own trigger.

  • Never classifies without showing the criteria met
  • Never moves a deadline
Materiality agent

Weighs the quantitative and qualitative factors on the scale with the company's materiality playbook, SEC guidance and anonymised comparable filings, cites the facts for each weight, and states its confidence and which single fact would change the result.

  • Proposes; the General Counsel records the determination
  • Shows the factors that point the other way
  • Weights move only with a person's reason
Drafter agent

Drafts the 8-K Item 1.05, the NIS2 notices, the DORA reports, the committee minutes and the final reports from one set of facts, says plainly what is not yet determined, and cites the fact behind every sentence.

  • Never submits or files
  • No sentence without a fact
  • Drafts stay drafts until signed
Consistency agent

Re-reads every notice blind against the others and the timeline, finds contradictions, numbers that drifted, softer wording in one notice than another and detail that would impede remediation, and proposes a fix.

  • Proposes only; a person accepts or rejects with a reason
  • Never edits a signed notice
  • Every disagreement shows both passages
Clock keeper

Keeps one clock per regulator and notice, reminds the owner at 50%, 75% and 90%, escalates to the General Counsel and the CISO 6 hours before a due time, and starts the 8-K/A clock when an open item is answered.

  • Never extends, pauses or moves a clock
  • A delay request goes to a person
General Counsel, CISO, disclosure committee

The committee votes; the General Counsel records; named signers submit. The agents propose; a named person decides.

Ask in plain words

Ask about any incident, fact, clock or notice

Ask in plain words, or tell the agents what to do. Every answer points to its source, and opens the screen it is about.

Why does the scale lean material?

On the qualitative factors, not the numbers. The $8.2M revenue impact is 0.36% of group quarterly revenue, inside the playbook's low band. What tips it: 412 GB taken, including two customers' drawings, production stopped 41 hours, and $1.1M of penalty rights reserved. Material 12, not material 6.

What changed since we sent the BSI notice?

The BSI notice went at 09:40 saying there was no indication of data exfiltration. At 11:52 forensic update 7 confirmed 412 GB copied out, including personal data of employees in Germany. The consistency agent drafted a correction for Jonas Albrecht to sign.

What will the 8-K say is not yet determined?

Three items, each watched for the 8-K/A: the full financial impact for Q4 (finance close), the total recovery cost net of insurance, and whether the copied drawings are published. When one is answered, the 8-K/A is due four business days later.

Remind Henrik 2 hours before the CCB deadline

Done. Henrik Aalto gets a reminder at 21:17 on e-mail and mobile, and you are copied. The CCB notification is due at 23:17; the draft is ready to sign.

Every screen

The working solution, as it ships.

13 screens from the working solution, on its sample data. Pick one to see it large.

TodayWhat needs the General Counsel: four clear numbers, one message from each agent with its proposal and citation, and every clock running.
The materiality scaleSeven regulator clocks above a balance scale of cited weights, with the materiality agent's reasoning and what would change its mind.
A weight and its sourceThe data-taken weight, the three facts it rests on and the forensic passage they came from; the weight changes only with a reason.
What if no data had been taken?The question asked in plain words, the factor taken off and the beam re-tilted to 9 to 6, with the agent's answer.
What was known, and whenUpdates received and 24 facts with happened-at and known-at times, replayed as of the moment the BSI notice was sent.
Notices from one fact setThe 8-K Item 1.05 draft with a chip for every fact, the other notices beside it, and the passages the consistency agent flagged.
Disagreements between noticesEach disagreement with both passages side by side, its severity and the proposed fix to accept or reject.
The disclosure committeeEach member's vote and comment, the decision record waiting for the General Counsel, the draft minutes and the committee pack.
Record the determinationMaterial, not material or not yet determinable, with reason codes, a note for the record and the signer's statement.
The SEC clock startsRecorded and signed at 14:05: the SEC clock shows 4 business days, with the 8-K due Fri 16 Oct, 17:30 ET.
FilingsEvery notice with its regulator, portal, signer, due time and receipt; open items for the 8-K/A; regulator requests.
Audit trailEvery action by a person or an agent, in order, filtered by people, agents, decisions or submissions; the decision file exports from here.
Your materiality playbookRevenue impact bands, default factor weights, the committee quorum and who records the determination — all settings.
Governance

Built for disclosure: cited, decided by people, on the record.

Every fact, weight and sentence cites its sourceEach fact cites the passage it came from, each weight on the scale cites its facts, and each sentence of every notice carries the fact it rests on.
The General Counsel records the determinationThe committee votes and the General Counsel records material, not material or not yet determinable, with reason codes, a note and a signature. That record, and nothing else, starts the SEC clock.
Agents propose; people decide, sign and submitAgents never decide materiality, sign or submit a notice, contact a regulator, edit a signed notice or move a clock. Each notice is submitted by its named signer, and the receipt is kept.
Changes only with a reasonA weight on the scale moves only with a person's reason, and every consistency fix is accepted or rejected with one. Permissions set who may record, vote, move a weight, sign, submit and export.
Privilege stays privilegedOutside counsel's memo is marked privileged and the agents have no access to it. The decision file lists privileged material but does not include it.
An audit trail that cannot be editedEvery action by a person or an agent is recorded in order, kept 7 years and tamper-evident. The decision file exports the timeline as of each decision, the scale, the votes, the signed record, every notice as sent and the receipts.
Configuration

Your playbook and your regulators, not ours

The materiality playbook, each regulator's clock rule with its legal source, and the reminders are settings, and every change goes on the audit trail.

SettingDefaultChoose from
Revenue impact bandsLow below 1% · review from 1% · high above 5%Set as a share of group quarterly revenue
Default weights of the qualitative factorsOperations 3 · Data taken 3 · Customers, public attention, regulators and litigation 21 · 2 · 3 for each factor
Committee quorum4 of 5 voting members3 of 5 · 4 of 5 · 5 of 5
Records the determinationGeneral CounselGeneral Counsel · Chief Financial Officer
SEC · Form 8-K Item 1.054 business days from the materiality determinationUS federal holidays; EDGAR 17:30 ET
NIS2 · CCB Belgium and BSI Germany24 h · 72 h · 1 month from awarenessCalendar hours, per country and entity
DORA · DNB Netherlands4 h from classification as major (at most 24 h from awareness) · 72 h · 1 monthWeekend rule for the initial notice
Reminders and escalationAt 50%, 75% and 90% of each clock; escalate 6 hours beforeEscalate 3 · 6 · 12 hours before; daily digest at 07:00 or 08:00
Connections

Works with the systems an incident already runs through

SIEM and SOARsecurity alerts, and the SOC cases that open incidents
EDR and IT service managementhost timelines and outage tickets
Forensic firm portalsecure, privileged upload of forensic updates
Finance close systemrevenue and cost figures for the impact estimate
Board portalcommittee packs and minutes
EDGAR filing agent and regulator portalsForm 8-K submission, the CCB form, the BSI and DNB portals
What it changes

The difference, in numbers.

Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.

target
7of 7
regulator clocks for the incident met, each counted from its own trigger
7 of 7
clocks met
target
0
notices left contradicting another: 4 of 4 disagreements caught and corrected
Four authors4 versions
With agents1 fact set
target
< 1h
to draft the 8-K, NIS2 and DORA notices from one set of facts, not a day per regulator

“demo” = seen in the working solution, on its sample incident · “target” = the design goal, measured in the live solution · “estimated” = our estimate · “typical” = published figures and rules (SEC Form 8-K Item 1.05, Release 33-11216 — four business days after the materiality determination; Directive (EU) 2022/2555 Art. 23 — NIS2 24-hour early warning and 72-hour notification; Regulation (EU) 2022/2554 (DORA) with Delegated Regulations (EU) 2024/1772 on classifying major incidents and (EU) 2025/301 on reporting time limits — the 4-hour initial notice; Regulation (EU) 2016/679 Art. 33 — GDPR 72 hours; SEC orders of 22 October 2024 — penalties of $4M, $1M, $995K and $990K). Companies, people, incidents and receipts named on this page are fictional — characters and sample data in the working solution.

Questions

What General Counsel and CISOs ask us.

What is Cyber Incident Reporting?

Cyber Incident Reporting helps the General Counsel and CISO work through each cyber incident reporting requirement — SEC Form 8-K Item 1.05, NIS2, DORA and GDPR — from one cited set of facts. Seven agents map who reports to whom, keep a timeline of what was known and when, weigh materiality on a scale where every factor cites its source, draft each notice and re-check them against each other. The disclosure committee votes, the General Counsel records the determination and named signers submit.

What are the cyber incident reporting requirements for a US-listed group with EU businesses?

Several clocks, each from its own trigger. Form 8-K Item 1.05 is due four business days after the company determines the incident is material. NIS2 asks for an early warning within 24 hours of awareness of a significant incident, a notification within 72 hours and a final report within a month. DORA asks a financial entity for an initial notice 4 hours after classifying an incident as major, no later than 24 hours after becoming aware of it, and GDPR asks for a notice to the data protection authority, where feasible within 72 hours of awareness of a personal-data breach.

How does it help with an 8-K Item 1.05 materiality assessment?

The materiality agent places each quantitative and qualitative factor — operations, data taken, customers, public attention, regulators, revenue, cost, containment — on a material or not-material side, with a weight from your playbook and the facts it rests on. It gives its confidence and says which single fact would change the result, and you can ask what-if questions and watch the scale move. It never makes the determination.

How does it keep the SEC, NIS2 and DORA notices consistent?

The drafter agent writes every notice from the same fact set, with each sentence citing its fact. The consistency agent then re-reads every notice blind against the others and the timeline, and flags contradictions, drifted numbers, softer wording in one notice than another and remediation-sensitive detail. A person accepts or rejects each proposed fix, with a reason.

Can we show later what we knew when we decided?

Yes. Every fact carries when it happened and when it was known, with its source passage, and superseded facts stay linked to the update that replaced them. The case replays as of any moment — NIS2 awareness, DORA classification, a notice sent, the committee meeting — and the decision file exports the timeline as of each decision.

Do people stay in control?

Yes. The agents read, propose and draft; they never decide materiality, sign or submit a notice, contact a regulator, edit a signed notice or move a clock. The committee votes, the General Counsel records the determination with reason codes and a signature, and each notice is signed and submitted by its named person.

What happens when new information arrives after the 8-K is filed?

The 8-K states what is not yet determined, and the clock keeper watches each open item — in the sample incident, the full Q4 impact, the recovery cost net of insurance and whether the copied drawings are published. When one is answered, it opens the 8-K/A, due four business days later, and the drafter writes it.

How long does it take to go live?

The Agentic Solution Engine builds and deploys it from your requirements and documents — your entity register, materiality playbook, committee and regulators — and it goes live once every quality gate has passed. First-time setup ends with a tabletop drill, so you see the clocks and drafts work before a real incident.

See it on
your last incident.

We'll run Cyber Incident Reporting as a tabletop drill on your own entities, playbook and a past incident.