Security operations · Guide
Ransomware in India: who to report to, how fast and how to recover.
CERT-In’s Directions require ransomware to be reported within 6 hours of noticing it, with what you know by then12. Sector regulators and, from 13 May 2027, the DPDP Rules add their own clocks3. A tested restore decides how fast you recover.
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The facts
Who has to report a ransomware attack in India, and how fast?
Ransomware often shows itself as files that will not open or servers that will not start. From that moment, Indian rules can start several clocks, and each needs a named person to file.
The first clock is CERT-In’s, set by its Directions of 28 April 2022 under section 70B(6) of the Information Technology Act, 20001. They apply to service providers, intermediaries, data centres, body corporates and government organisations1.
Each must report listed incidents “within 6 hours of noticing such incidents or being brought to notice about such incidents”1. Reports go to incident@cert-in.org.in, or by phone on 1800-11-49491.
Annexure I lists 20 incident types1. Ransomware is named in item (v), malicious code attacks. Unauthorised access to IT systems or data is item (iii), and data breach and data leak are items (xi) and (xii)1.
CERT-In’s FAQ uses the IT Act’s definition of “body corporate”: “any company”, including a firm or a sole proprietorship2.
The facts
When does the six-hour clock start, and what if you know little?
The clock runs from noticing. The FAQ repeats the words: within 6 hours “of noticing the incident or being brought to notice about such incident”2. Neither text ties the clock to the end of an investigation12.
You do not need the full picture to file. Entities “may provide information to the extent available at the time of reporting”, and more “may be reported later within reasonable time”2.
Question 13 of the FAQ asks whether a business and its outsourcing partner can agree by contract who reports2. CERT-In’s answer is that any entity which notices the incident shall report it, and the obligation “is neither transferrable nor indemnified or dispense with”2. The FAQ adds that it is not a legal document2.
The Directions also require logs of all ICT systems, kept for a rolling 180 days within Indian jurisdiction and given to CERT-In with the report1. System clocks must sync to National Informatics Centre (NIC) or National Physical Laboratory (NPL) time servers, or ones traceable to them1. Each organisation names a Point of Contact for CERT-In1.
The facts
Which sector regulators and other rules add a clock?
Regulated firms file more than once. The table uses each instrument’s own trigger where it gives one.
| Who | Reports to | Within | Clock starts at | Instrument |
|---|---|---|---|---|
| Body corporates, service providers, intermediaries, data centres and government organisations | CERT-In | 6 hours | Noticing the incident, or being told of it | CERT-In Directions, 28 April 20221 |
| Insurers, insurance intermediaries and the Insurance Information Bureau | CERT-In, with a copy to IRDAI and other concerned regulators | 6 hours | Noticing the incident, or being told of it | IRDAI Information and Cyber Security Guidelines, 2026, section 2.10, clause 3.64 |
| SEBI-regulated entities | SEBI: an email to mkt_incidents@sebi.gov.in, then the Incident Reporting Portal | 6 hours by email; 24 hours on the portal | Not restated in the 2026 circular | SEBI circular of 24 August 2026, citing its cyber resilience framework5 |
| Commercial banks; NBFCs other than base-layer NBFCs under ₹500 crore and core investment companies | RBI on its DAKSH platform, as well as the CERT-In report | 6 hours | Detection | RBI Cybersecurity, Technology: Risk, Resilience and Assurance Framework Directions, 2026: paragraph 182 for banks, paragraphs 28 and 141 for NBFCs67 |
| Data Fiduciaries, for a personal data breach, from 13 May 2027 | Each affected person, and the Data Protection Board | Without delay; a detailed report to the Board within 72 hours | Becoming aware of the breach | DPDP Rules, 2025, Rule 73 |
IRDAI’s 2026 Guidelines, issued on 6 April 2026, also ask for ICT logs kept for 180 days in India4. SEBI’s portal takes reports in stages, from initial to final5.
RBI’s Directions of 31 July 2026 repealed its earlier IT directions for banks and NBFCs67. The NBFC version keeps housing finance companies reporting to NHB rather than RBI7.
The Board’s 72-hour report has six parts, from updated details of the breach to a report on the notices given to affected people3.
A listed company may also owe the stock exchanges a disclosure. After a ransomware incident on 23 June 2026, Bajaj Auto reported to CERT-In and informed the exchanges8. It called the disclosure a matter of good governance8.
The facts
How do ransomware attacks on Indian organisations start and end?
The India figures come from Sophos’s State of Ransomware survey: 240 IT and security leaders whose organisations were hit in the past year9. The organisations had 100 to 5,000 employees, and the survey ran from January to March 20269.
Email led the technical root causes: malicious email in 28% of attacks and phishing in 26%9. Compromised credentials came next at 19%, and exploited vulnerabilities fell to 11%, from 29% a year earlier9. Asked about identity, 79% confirmed the ransomware incident was the same event as their most significant identity attack9.
Where stolen credentials were the way in, MFA was usually in place. Across the global survey, 97% of victims whose attack began with compromised credentials had MFA enabled “in some capacity”10. One-time passwords (52%), push apps (51%) and passkeys (51%) were the most common methods10. Sophos suggests MFA may have been missing from some systems, and is not enough on its own10.
In Rapid7’s global incident response investigations in 2025, valid accounts with missing or lax MFA were the most common way in, at 43.9%11. Ransomware was involved in 42% of those investigations11.
Data was encrypted in 60% of Indian attacks9. Where it was, 67% used backups to recover it and 56% paid the ransom and got data back9. Some did both. Within a week, 58% had recovered; 10% took one to six months9. Mean recovery cost, excluding any ransom, was US$1.11 million9.
What it means
What does this change in the first six hours?
The first six hours hold two jobs: the CERT-In report and the start of recovery. Neither can wait for the other.
Filing starts when someone matches what they see to a type in Annexure I1. That person needs the authority to file without calling a meeting. The FAQ allows a short first report, so there is no need to wait for forensics2.
Outsourcing does not move the duty. If your service provider or SOC notices the attack first, the FAQ expects whoever notices to report2. Your contract should say how fast they tell you, so half your six hours are not gone before you hear.
Logs decide what the report can say. The Directions ask for 180 days of them in India, on synchronised clocks1. Firewall, VPN, identity and server logs that are missing or out of step leave holes in the timeline. From 13 May 2027, Rules 6(1)(e) and 8(3) require at least a year of logs for personal data processing3.
In the credential cases, having MFA was not enough10. CISA’s Scattered Spider advisory, AA23-320A, describes repeated push prompts until someone pressed Accept, and calls asking help desks to reset passwords or transfer MFA tokens12. It recommends FIDO/WebAuthn or PKI-based MFA, which resists phishing, push bombing and SIM swaps12.
After the report, recovery time sets the cost. Tata-owned Jaguar Land Rover shut production for nearly six weeks after its 2025 attack13. The independent Cyber Monitoring Centre put the loss to the UK economy at £1.9 billion, across more than 5,000 organisations13. Most of it was lost manufacturing output13.
From 13 May 2027, DPDP Rule 6(1)(d) names data backups as a measure for continued processing3. CERT-In’s blueprint of 25 May 2026, CISG-2026-02, is more specific: it lists immutable backups, restoration testing and isolated backup infrastructure among its controls14. It says organisations should run backup restoration validation alongside incident response and table-top exercises14.
What it means
What should be in place before the next incident?
Each step below leaves something you can show an auditor or a regulator.
- Name the person who decides an event is reportable and has the authority to file, plus a deputy for nights and leave.
- Write the decision rule against the 20 types in Annexure I, so the call is a lookup1.
- Put incident@cert-in.org.in, 1800-11-4949, your sector regulator’s route and a short report template in the runbook1.
- Send CERT-In your Point of Contact in the Annexure II format, and update it when people change1.
- List every log source: firewall, VPN, identity, email, servers, endpoints and cloud. Confirm each keeps 180 days in India1. From 13 May 2027, keep logs of personal data processing for at least a year3.
- Point every clock at NIC or NPL time, and check for drift1.
- Ask each provider that could notice an attack first how fast they will tell you, in writing2.
- Move administrators and remote access to FIDO/WebAuthn or PKI-based MFA first12. Require a call-back to a known number before the help desk resets a password or an MFA device.
- Each quarter, restore one critical system from backup into an isolated network. Record the date, the time taken, what was missing and who owns each gap.
- Rehearse the clock sheet below twice a year with the people named on it.
| Item | What to write down | Due |
|---|---|---|
| Reportability call | Who decides, their deputy and which Annexure I types apply to you | Before any incident |
| CERT-In report | Who files, from which mailbox, with which template | Within 6 hours of noticing1 |
| Sector regulator | The IRDAI copy, the SEBI email and portal filing, or the RBI report on DAKSH | 6 hours; SEBI portal 24 hours4567 |
| Data Protection Board | Who drafts the six-part report and who tells affected people | Within 72 hours of becoming aware, from 13 May 20273 |
| Stock exchanges | Who judges materiality and signs the filing | As your company secretary and counsel advise |
| Restore | Which system comes back first, from which copy and who leads | The last test date and the time it took |
Our view
Where would we put the effort first?
Decide reportability and who files before the incident, so the six hours go on facts and a short report.
There is a fair case for filing later: a report built on forensic findings is less likely to need correcting. We would still file early with what is known, because CERT-In’s FAQ lets the detail follow2. If counsel must review the wording, agree the template with them in advance.
Next, judge backups by the restore. A backup job that completes proves the job ran. A timed restore of a whole system proves you can recover, and tells you how long it takes.
Spend identity money on factors that resist phishing. An MFA prompt that can be approved by mistake, or reset over a phone call, is weaker than it looks. Start with administrators and remote access, where one account opens most of the estate.
This order changes if most of your estate is SaaS. There, the restore test is a question for each vendor: ask for their last restore evidence, and test what you can export yourself.
Limits
What does this article not cover?
This article is not legal advice; applicability is for your counsel. Reportability, sector filings, exchange disclosures and any ransom decision sit with your counsel and compliance team. NetScale is not a CERT-In empanelled auditor; where a regulator requires an empanelled audit, we work alongside the auditor.
Where we fit
Who can check your six-hour readiness?
Our managed SOC and MDR service is built around these duties: logs kept in India, NIC or NPL time on every source and a runbook naming who reports what. Monitoring and response run in the windows agreed in writing. The SOC readiness review checks your log sources, retention and 6-hour reporting readiness. It is free, and the written findings are yours whether we work together or not.
Questions readers ask
Do we have to report a ransomware attack to CERT-In?
Can our IT vendor or SOC provider report on our behalf?
CERT-In’s FAQ says the reporting duty cannot be transferred: any entity that notices the incident shall report it2. Agree in writing how fast your provider tells you. How this applies to your contracts is for your counsel.
Is the DPDP 72-hour breach report in force now?
If we already have MFA, are we covered against ransomware?
References
- 1CERT-In, Ministry of Electronics and Information Technology. Directions under sub-section (6) of section 70B of the Information Technology Act, 2000 relating to information security practices, procedure, prevention, response and reporting of cyber incidents for Safe & Trusted Internet. 28 April 2022. cert-in.org.in (opens in a new tab)
- 2CERT-In, Ministry of Electronics and Information Technology. Frequently Asked Questions (FAQs) on Cyber Security Directions of 28.04.2022. May 2022. cert-in.org.in (opens in a new tab)
- 3Ministry of Electronics and Information Technology, Gazette of India (G.S.R. 846(E)). Digital Personal Data Protection Rules, 2025. 13 November 2025. meity.gov.in (opens in a new tab)
- 4Insurance Regulatory and Development Authority of India (circular IRDAI/GA&HR/CIR/MISC/51/4/2026, Annexure B). IRDAI Information and Cyber Security Guidelines, 2026. 6 April 2026. irdai.gov.in (opens in a new tab)
- 5Securities and Exchange Board of India (circular HO/(449)2026-ITD-5_DIV1/I/19448/2026). Alignment of SEBI’s Cyber Incident Reporting Portal with FIRE Format. 24 August 2026. sebi.gov.in (opens in a new tab)
- 6Reserve Bank of India (RBI/DoS/2026-27/410). Reserve Bank of India (Commercial Banks – Cybersecurity, Technology: Risk, Resilience and Assurance Framework) Directions, 2026. 31 July 2026, updated as on 1 October 2026. rbi.org.in (opens in a new tab)
- 7Reserve Bank of India (RBI/DoS/2026-27/461). Reserve Bank of India (Non-Banking Financial Companies – Cybersecurity, Technology: Risk, Resilience and Assurance Framework) Directions, 2026. 31 July 2026. rbi.org.in (opens in a new tab)
- 8Business Today. What Bajaj Auto ransomware attack says about cyber security risks for Indian automakers. 24 June 2026. businesstoday.in (opens in a new tab)
- 9Sophos. The State of Ransomware in India 2026. July 2026. assets.sophos.com (opens in a new tab)
- 10Sophos (survey by Vanson Bourne). The State of Ransomware 2026. 25 September 2026. assets.sophos.com (opens in a new tab)
- 11Rapid7 (news release). Rapid7 2026 Global Threat Landscape Report Shows Exploited High and Critical-Severity Vulnerabilities Surged 105% as Attack Timelines Collapsed. 18 March 2026. s29.q4cdn.com (opens in a new tab)
- 12Cybersecurity and Infrastructure Security Agency (CISA) and FBI (advisory AA23-320A). Scattered Spider. 16 November 2023, last revised 29 July 2025. cisa.gov (opens in a new tab)
- 13Business Today. JLR cyberattack led to £1.9 billion loss, impacted over 5,000 companies. 23 October 2025. businesstoday.in (opens in a new tab)
- 14CERT-In, Ministry of Electronics and Information Technology (CERT-In Security Guidelines CISG-2026-02). Blueprint for Reducing Exposure and Defending against AI-Assisted Vulnerabilities Exploitation in Digital Infrastructure. 25 May 2026. cert-in.org.in (opens in a new tab)
Changes
- First published.