FIELD NOTE 006 · 02 JUN 2025

72 Hours After You Pay: Ransomware Reporting Is Now Law

A 72-hour dial, 49 hours gone, 23 hours left to report.

On 30 May 2025, Part 3 of the Cyber Security Act 2024 came into force. For the first time, Australian businesses must tell the Government when they pay a ransom.12

What the law requires

The trigger is the payment, not the demand. If you do not pay, this obligation does not apply, although other notification duties may. Failing to report exposes the business to a civil penalty.1 The Act also limits how the Government can use what you report, which is meant to encourage candour.2

Why it matters to the board

Ransom decisions used to happen in a war room, under pressure, often over a weekend. Now they come with a statutory deadline and a record that regulators will know exists. Seventy-two hours is not long when the same people are also restoring systems, briefing insurers, notifying the OAIC and talking to customers.

The board does not need to decide in advance whether it would pay. It does need to decide in advance who decides, on what information, and who owns the report.

Three questions for your next board meeting

  1. Is our turnover above the threshold, and does any entity in the group hold critical infrastructure assets?
  2. Does our incident response plan name the person who files the ASD report, and is there a 72-hour clock in it?
  3. Have we rehearsed a ransom decision end to end, including legal, insurer and regulator notifications?

How we help

We write the ransom decision into your incident plan, run the tabletop that tests it, and sit in the war room when it is real. See Incident & Resilience on the Practice, or brief a CISO.

References

  1. Cyber Security Act 2024 (Cth), Act No. 98 of 2024, Part 3. Federal Register of Legislation. legislation.gov.au
  2. Department of Home Affairs, “Factsheet: Mandatory ransomware and cyber extortion payment reporting”. homeaffairs.gov.au
  3. Australian Signals Directorate, “Ransomware payment and cyber extortion payment reporting”. cyber.gov.au
  4. Department of Home Affairs, “Cyber Security Act”. homeaffairs.gov.au
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