The First 72 Hours: What CIRCIA Means for Firm Leaders
- Samuel Kader
- 18 minutes ago
- 7 min read
When a cyber incident happens, most organizations do not have days or weeks to figure out what went wrong.
The first few hours are often chaotic. Systems may be down. Employees may not know what to do. Clients may be calling. Leadership may be asking whether data was accessed, whether operations can continue, and whether anyone needs to be notified.
Now, with the Cyber Incident Reporting for Critical Infrastructure Act (CIRCIA), that pressure is becoming even more serious.
CIRCIA requires the Cybersecurity and Infrastructure Security Agency (CISA) to develop rules requiring covered entities to report certain cyber incidents and ransomware payments. Under the law, covered cyber incidents must be reported within 72 hours after the organization reasonably believes the incident occurred, and ransom payments must be reported within 24 hours. The final rulemaking process is still underway, but the direction is clear: cyber incident response is becoming a regulatory and leadership responsibility, not just an IT concern.
For CPA firms, law firms, and business leaders, the question is no longer just, “Can we prevent a cyberattack?”
The better question is:
Would we know what to do in the first 72 hours?
Why the First 72 Hours Matter
In a cyber incident, time matters. The actions an organization takes in the first 72 hours can determine how much damage is done, how quickly operations recover, how clients are impacted, and whether the organization can meet reporting, insurance, legal, or contractual obligations.
This is especially important for firms that handle sensitive client data. CPA firms, law firms, and professional service organizations often hold financial records, tax documents, legal files, payroll information, business records, personally identifiable information, and confidential communications.
That makes them attractive targets for cybercriminals. If a ransomware attack, business email compromise, unauthorized access event, or data theft incident occurs, firm leaders may need to answer critical questions very quickly:
What happened?
When did it happen?
Which systems were affected?
Was client data accessed or stolen?
Are backups available and reliable?
Who needs to be notified?
Is this incident reportable?
What documentation do we have?
Who is authorized to make decisions?
Without a plan, these questions are often answered under stress, with incomplete information and unclear responsibilities. That is where risk increases.
CIRCIA Changes the Conversation
CIRCIA is important because it reinforces a larger shift in cybersecurity expectations.
Cybersecurity is no longer only about technology tools. It is about preparedness, governance, documentation, escalation, and accountability.
For many organizations, the biggest weakness is not that they have no cybersecurity tools at all. It is that they do not have a clear response process when something goes wrong.
They may have antivirus protection, firewalls, backups, or monitoring in place. But if an incident happens, leadership may not know:
Who calls the IT provider?
Who contacts cyber insurance?
Who speaks with legal counsel?
Who communicates with employees?
Who communicates with clients?
Who determines whether reporting is required?
Who documents the timeline of events?
CIRCIA makes these questions more important because covered organizations will need the ability to identify and report qualifying incidents within specific timeframes. Even organizations that are not directly covered should pay attention, because cyber insurance carriers, regulators, clients, and business partners are increasingly expecting this level of readiness.
Why CPA Firms and Law Firms Should Pay Attention
CPA firms and law firms may not always think of themselves as “critical infrastructure,” but they often serve clients in highly regulated or critical industries. They may support healthcare organizations, financial institutions, government contractors, manufacturers, retailers, or businesses that fall under more complex cyber and compliance obligations. That means a cyber incident at the firm could create ripple effects for clients, vendors, and other stakeholders.
For law firms, a cyber incident may involve confidential client communications, litigation documents, contracts, intellectual property, or privileged information.
For CPA firms, an incident may involve tax returns, Social Security numbers, payroll files, bank account information, business financials, and client records.
In both cases, the impact can go far beyond a temporary IT outage. A cyber incident can affect client trust, professional reputation, regulatory obligations, insurance claims, and business continuity. That is why firm leaders should not wait until the final details of CIRCIA are fully in effect to start preparing.
What Should Happen in the First 72 Hours?
Every organization is different, but the first 72 hours after a cyber incident should not be improvised. A strong response typically includes several key steps.
Hour 1–12: Identify and Contain the Incident
The first priority is understanding what is happening and stopping additional damage.
This may include:
Disconnecting affected systems
Disabling compromised accounts
Preserving logs and evidence
Engaging IT and cybersecurity support
Determining whether ransomware, unauthorized access, or data theft may be involved
At this stage, speed matters — but so does discipline. Acting too quickly without preserving evidence can make it harder to understand what happened later.
Hour 12–24: Escalate to the Right Decision-Makers
Once an incident is suspected, the right people need to be involved.
This may include:
Firm leadership
IT or managed service provider
Cybersecurity response team
Legal counsel
Cyber insurance carrier
Compliance or risk management contacts
Communications decision-makers
For ransomware payments, CIRCIA’s reporting timeline is especially short. The law includes a 24-hour reporting requirement for ransom payments by covered entities. That means organizations need to know in advance who has authority to evaluate, approve, reject, or report these decisions.
Hour 24–48: Determine Scope and Business Impact
The organization then needs to understand the scope of the incident.
Key questions include:
Which users, systems, or applications were affected?
Was sensitive data accessed, copied, encrypted, or deleted?
Are backups clean and usable?
Can the business continue operating?
Are clients impacted?
Are third-party vendors involved?
Are there contractual, insurance, or legal reporting requirements?
This is where documentation becomes critical. A clear timeline of events can support legal review, insurance claims, internal decisions, and any required reporting.
Hour 48–72: Prepare Reporting and Communication Decisions
By this stage, leadership should be working from facts, not assumptions.
If the incident is potentially reportable, the organization needs enough information to support the reporting process. If clients, employees, vendors, regulators, or law enforcement need to be contacted, communications should be accurate, coordinated, and reviewed carefully.
The wrong message at the wrong time can create confusion, reputational damage, or legal risk. The right preparation before an incident makes this process far easier.
The Problem With Waiting Until an Incident Happens
Many organizations believe they can figure out their response plan when something happens.
That is a risky assumption. During a cyber incident, leaders are under pressure. Employees are anxious. Systems may be unavailable. Clients may be affected. Critical information may be incomplete. Vendors may need to be contacted. Insurance requirements may need to be followed. Legal questions may come up immediately.
This is not the time to decide who is responsible for what. Organizations that wait until an incident occurs often lose valuable time because they are trying to build a response process while also managing the crisis.
A documented cyber incident response plan helps eliminate guesswork.
What Firm Leaders Should Do Now
CIRCIA is a reminder that cyber readiness needs to be addressed before a cyber incident occurs. Firm leaders should consider the following steps:
1. Create or Update an Incident Response Plan
Your organization should have a written plan that defines what happens when a cyber incident is suspected.
This plan should include:
Internal points of contact
External vendors and advisors
Escalation procedures
Decision-making authority
Communication steps
Documentation requirements
Backup and recovery procedures
2. Review Cyber Insurance Requirements
Many cyber insurance policies require specific actions after an incident. Some require immediate notification, approved vendors, or specific documentation. Understanding these requirements before an incident can help avoid problems during a claim.
3. Identify Critical Systems and Data
Firm leaders should know where sensitive data lives, which systems are essential to operations, and what downtime would mean financially and operationally. You cannot protect or recover what you have not identified.
4. Test Backup and Recovery Procedures
Backups are only useful if they work. Organizations should regularly test backup restoration and confirm that backups are protected from ransomware or unauthorized access.
5. Train Employees
Many cyber incidents begin with phishing, stolen credentials, or social engineering.
Training employees to recognize suspicious activity and report it quickly can reduce damage and speed up response.
6. Conduct a Cyber Readiness Assessment
A Cyber Readiness Assessment can help identify gaps before an incident occurs. This includes reviewing policies, tools, vulnerabilities, response procedures, employee awareness, and recovery capabilities.
The goal is not just to check a compliance box.
The goal is to know whether your organization is prepared to respond when it matters most.
CIRCIA Readiness Is Business Readiness
CIRCIA may sound like another cybersecurity regulation, but it points to something bigger.
Organizations are now expected to take cybersecurity seriously at the leadership level. That means having plans, documentation, response processes, and decision-makers in place before an incident happens.
For CPA firms, law firms, retailers, and business leaders, this is about protecting more than technology.
It is about protecting clients, operations, reputation, and long-term trust.
The first 72 hours after a cyber incident can shape the entire outcome.
The time to prepare is now.
About Shield IT Networks
Shield IT Networks helps businesses strengthen their cybersecurity posture through proactive IT management, cybersecurity strategy, risk assessments, and compliance-focused technology solutions.
We work closely with law firms, CPA firms, professional service organizations, and retailers to help reduce cyber risk, improve operational resilience, and prepare for evolving security and compliance requirements.
Our goal is simple: help organizations stay secure, prepared, and operational in an increasingly complex threat landscape.
Is Your Firm Ready for the First 72 Hours?
A cyber incident is not the time to discover gaps in your response plan. Shield IT Networks offers Cyber Readiness Assessments designed to help organizations identify vulnerabilities, evaluate risk exposure, and strengthen their ability to respond to modern cyber threats and evolving compliance expectations.
Schedule your Cyber Readiness Assessment today and take the first step toward building a more secure and resilient organization.
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