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Marius Laurusevicius's avatar

Europe already has the reporting skeleton this comparison points at. Article 23(4) of Directive (EU) 2022/2555 gives essential and important entities a 24-hour early warning to the CSIRT, a 72-hour incident notification carrying an initial severity assessment and any indicators of compromise, and a final report within one month. My view is that the weak joint is not the timetable but the trigger: the duty attaches to a significant incident, and implementing acts define significance service by service. An in-scope firm without dedicated security staff can hit every deadline and still be guessing whether the threshold was crossed. The AML analogy fits there too, since suspicion thresholds were the hard part.

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