Alessandro AleddaInsider Threat and Risk

What this event obliges

Every reporting act an instrument obliges for this type, the term on each, whom it is owed to, and the point it runs from. Choose a jurisdiction and a kind of organization above to see which reach yours.

Acts under DORA, where the organization is a financial entity

ActDoOwed toTermFromUnless
DORA art. 19(4)(a)Submit the initial notificationfinancialFour hours from classification, and no later than 24 hours from awareness. Where classified as major only later, four hours from that classificationClassification, capped from awareness
DORA art. 19(4)(b)Submit the intermediate reportThe same authority72 hours, and again without undue delay once regular activities have been recoveredThe initial notification
DORA art. 19(4)(c)Submit the final reportThe same authorityOne monthThe intermediate report, or the latest updated one
DORA art. 19(3)Inform the clients whose financial interests are affectedClientsWithout undue delayAwareness
DORA RTS art. 5(3)Tell the authority the term will be missed, before it expiresThe competent authorityBefore the term it will miss expiresKnowing the term will be missed

Acts under NIS2, where the organization is essential or important

ActDoOwed toTermFromUnless
NIS2 art. 23(4)(a)Submit the early warningcsirt24 hoursAwareness
NIS2 art. 23(4)(b)Submit the incident notificationThe same body72 hoursAwareness
NIS2 art. 23(4)(d)Submit the final reportThe same bodyOne monthThe incident notification

Acts under the Market Abuse Regulation

ActDoOwed toTermFromUnless
MAR art. 17(1)Disclose the inside information to the publicThe public. Through a means enabling fast access and complete, correct and timely assessment, and through the officially appointed mechanism where one appliesAs soon as possibleThe information being inside information. Nothing declares it, and no authority starts the clock
MAR art. 17(4)Delay the disclosure on the issuer's own responsibility, then explain itmarketThe written explanation is owed immediately after the information is disclosed to the publicThe disclosure, not the decision to delay
MAR art. 17(5) and (6)Where the issuer is a credit institution or a financial institution and the reason is financial stability, obtain the authority's consent before delayingmarketNone stated. The authority reviews at least weekly for as long as the delay lastsThe notification of the intention to delay
MAR art. 17(7)Where disclosure was delayed under 17(4) or 17(5), disclose the inside information to the publicThe public. The same disclosure that was delayedAs soon as possibleConfidentiality no longer being ensured
MAR art. 17(8)Where inside information has reached a third party, make complete and effective public disclosure of itThe publicSimultaneously where the disclosure was intentional, promptly where it was notThe disclosure to the third party

Acts under the General Data Protection Regulation

ActDoOwed toTermFromUnless
GDPR art. 33(1)Notify the supervisory authority of the breachdpa72 hoursAwarenessThe breach is unlikely to result in a risk to the rights and freedoms of natural persons
GDPR art. 33(4)Complete an earlier notification with what was not yet knownThe same authorityWithout undue further delayThe notification it completes
GDPR art. 34(1)Tell each person whose records were altered or destroyedEach person whose records were altered or destroyedWithout undue delayAwarenessThe risk is not high
GDPR art. 33(5)Record the breach, its effects, and what was done about itNobody, until askedNo termNo term, so no starting point

What every term runs from

  • Awareness. Establish and record the moment the organization is taken to know

ITER/T3Alteration or destruction of records

Type
T3  |  Alteration or destruction of records
Acts
17
Sources cited
6
Added
2 SEPTEMBER 2026
Updated
3 SEPTEMBER 2026

Type of insider event

An event can be more than one of these at once, and it then obliges what all of them oblige. This page opens on its own type; turning another on adds what that type requires, to the same timeline. Each type is set out in full on the framework page.

The jurisdiction

The instrument and the interval are European. Which body receives the report is national, and so is the act that may move the point the interval runs from.

Country

The obligation and the interval are set by the instrument and are the same in every Member State. The national act may move the point the interval runs from: twelve of the thirty read here do. The procedure is national in all of them: which body receives the report, on which platform, with which credential.

rows written outside the account

CyprusLiechtensteinLuxembourgMalta

The organization

Two facts decide which instruments reach it: the sector regime it falls under, and whether its instruments are admitted to trading. One regime displaces another.

Instruments in scope

Computed from the three facts stated above, and from nothing else on this page.

The premises

Not steps to take now. Three properties of the organization, each one fixing the moment every term below runs from, and each one either present or absent before the event happens.

The timeline

Every act the instruments above oblige, on one line, in the order its term expires. T0 is the moment this organization is taken to know: every term stated in hours runs from T0, or from the act before it. An act marked no hour stated runs from something else, and says what.


Decided cases on the two tests

Two acts above turn on a test the text does not settle: notify the authority unless the breach is unlikely to result in a risk, and tell the people where the risk is high. The record supplies no threshold of its own. The cases show where a body drew it, what followed, and what would have moved it.