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Start with the National Cyber Security Centre (NCSC) Report a Cyber Incident service, but do not treat that report as a substitute for legal notifications. Use the NCSC’s Cyber Incident Signposting Service to obtain UK cyber-response guidance and share intelligence. At the same time, assess whether the event is a personal-data breach requiring notification to the Information Commissioner’s Office (ICO), an incident covered by Network and Information Systems (NIS) duties, a matter for a sector regulator, or suspected criminal conduct requiring Report Fraud or Police Scotland.
If the incident may have compromised your network, complete the NCSC form from a separate, trusted system. Preserve prompts, inputs, model and application versions, outputs, tool calls, access records, audit logs, timestamps, affected data and containment actions before routine cleanup destroys them.
Which UK route should you use?
An AI-related cyber incident can trigger several reporting routes at once. The correct recipient depends on what happened, what services or data were affected, and the organisation’s regulated status. The organisation remains responsible for notifying every applicable authority, insurer and contractual party; filing with one body does not automatically notify the others.
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| NCSC Report a Cyber Incident/Cyber Incident Signposting Service | A cyber incident, suspected compromise or significant vulnerability needs UK cyber-response guidance or intelligence sharing | Submit promptly; the service is monitored 24/7 and the form takes about 15 minutes | Provides cyber-response signposting, potential technical support and intelligence sharing; it does not replace statutory or contractual notifications |
| Information Commissioner’s Office | Personal data was exposed, lost, altered or accessed unlawfully and the breach is notifiable under UK GDPR | Without undue delay and, where applicable, within 72 hours of becoming aware | Fulfils a data-protection notification duty; investigate and update the ICO as facts develop |
| NIS competent authority or sector regulator | Your organisation is a relevant digital service provider or operator of an essential service and the incident meets the applicable NIS threshold | Use the deadline set by the applicable NIS or sector rules | Fulfils a regulatory duty tied to service impact and the organisation’s regulated role |
| Report Fraud | The incident may involve criminal activity in England, Wales or Northern Ireland | Report as soon as practical; preserve evidence while investigating | Records suspected fraud or cybercrime for law-enforcement purposes |
| Police Scotland | The organisation or affected activity is in Scotland and the matter may be criminal | Report promptly through the Scottish police route | Provides the appropriate criminal-reporting channel for Scotland |
National significance, cross-border effects, customer harm, supplier involvement and insurance terms can add further notification duties. Check the incident plan, contracts and regulatory contacts before deciding that one submission is sufficient.
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What counts as an AI cyber incident?
Reportable events include more than a stolen model file. Treat an incident as an AI cyber incident when an attacker or failure affects the confidentiality, integrity or availability of an AI model, its data, its prompts, its tools or a connected business service.
Prompt injection and malicious inputs
A prompt-injection attack manipulates instructions supplied to a model so it ignores its intended rules, reveals protected context, follows attacker-chosen commands or misuses connected tools. Preserve the exact malicious prompt, the surrounding conversation, system and developer instructions, retrieved content and the model’s responses. A single harmful output is not proof of compromise, but a repeatable bypass, unauthorised data access or tool action should be handled as a security incident.
Data poisoning and retrieval compromise
Poisoned training, fine-tuning or retrieval data can alter model behaviour or insert hidden instructions. Record which dataset, document store, embedding index or external source was used, when it changed, who could write to it and which model versions consumed it. If a connected retrieval source was compromised, isolate it without deleting the affected records.
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Model, dataset and credential theft
Unauthorised copying of model weights, training data, prompts, API keys or service credentials can create both cyber and intellectual-property consequences. Capture access events, download volumes, token or key use, identity information and the systems reached with the stolen credentials.
Unauthorised tool use and autonomous actions
An AI agent that sends messages, changes records, executes code, makes purchases or alters infrastructure without approved authority may have caused a cyber incident even when the underlying model was not modified. Preserve the tool-call sequence, arguments, approval checks, account used, resulting actions and rollback or containment steps.
Compromise of connected business systems
An AI service can be the entry point to ordinary network, endpoint, identity or cloud compromise. Investigate it alongside conventional threats: suspicious authentication, privilege escalation, malware, unusual data transfer and persistence. NCSC identifies prompt injection and data poisoning as AI risks that sit alongside ordinary cyber threats.
How to submit the NCSC report safely
The NCSC Report a Cyber Incident/Cyber Incident Signposting Service is the practical UK starting point for a cyber event. Its online form has six sections, normally takes about 15 minutes and is monitored around the clock. The report can be made while the investigation is still developing; submit the reliable facts you have and provide updates as they are confirmed.
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- Activate your incident plan. Name an incident lead, legal or privacy contact, technical investigator and communications owner. Establish a secure coordination channel that is not dependent on the potentially compromised environment.
- Use a separate system. If the organisation’s network, identity provider or endpoints may be compromised, access the NCSC form from a known-clean device and connection. Do not assume that a familiar workstation, corporate email account or shared drive is trustworthy.
- Describe the event in operational terms. State when the first suspicious activity was observed, which AI application or supplier was involved, what behaviour changed and which systems, users or datasets may be affected. Distinguish confirmed facts from working hypotheses.
- Record containment already taken. Note disabled keys, isolated hosts, suspended tools, blocked retrieval sources, revoked sessions or other actions. Include the time of each action and any effect on service availability.
- Provide a safe contact path. Give an incident contact who can receive follow-up questions without relying on a potentially compromised mailbox. Keep the submission reference and a copy of what was sent in the incident record.
- Request assistance when needed. Explain where specialist technical support or further signposting would help. Continue investigating; an NCSC submission does not transfer responsibility for regulatory, contractual or criminal notifications.
Do not wait for a perfect root-cause report before contacting NCSC. Early reporting can preserve options for assistance and intelligence sharing, while later submissions can add indicators, affected assets and confirmed impact.
When the ICO must be considered
Ask whether the AI incident exposed, lost, altered or unlawfully accessed personal data. Personal data can appear in prompts, chat transcripts, uploaded files, training or fine-tuning datasets, retrieval stores, model outputs, logs, tool arguments and support tickets. Data may be affected even when the model itself was not stolen.
Apply the UK GDPR awareness clock
A qualifying personal-data breach must be reported to the ICO without undue delay and, where applicable, within 72 hours of awareness. The clock is tied to the organisation becoming aware of the breach, not to the date on which the investigation is complete. If the facts are incomplete, report the known information early and send updates as the scope, categories of data and consequences become clearer.
Make the threshold decision explicitly
Document what personal data was involved, whose data it was, how it was exposed or changed, the likely consequences and the measures taken to reduce harm. If the organisation concludes that notification is not required, record the reasoning and the evidence available at the time. Revisit the decision if new logs, supplier information or affected data are discovered.
Coordinate privacy and technical investigations
Security teams may focus on model behaviour while privacy teams need to establish data subjects, data categories and likely effects. Use one dated decision log so both investigations share the same timeline. Restrict copied prompts and outputs to authorised investigators because incident evidence can itself contain personal data.
NIS duties and sector regulators
NIS obligations depend on the organisation’s regulated role and the effect on a relevant service. A digital service provider must assess whether the incident meets the applicable NIS threshold. Operators of essential services should use their sector competent authority rather than assuming that the general cyber-reporting route is enough.
Information to assemble for a qualifying digital-service incident
The ICO’s guidance for relevant digital service providers requires incident reporting to cover the time, duration, nature, impact and cross-border effects. Build those facts from system and service records:
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- Time: when the incident began, when it was detected and when key changes occurred.
- Duration: the period of unauthorised access, degraded service, incorrect model behaviour or data exposure, including any uncertainty.
- Nature: the attack or failure mechanism, such as prompt injection, poisoned data, stolen credentials or a compromised supplier.
- Impact: affected services, users, availability, integrity, confidentiality and recovery actions.
- Cross-border effects: countries, overseas customers, processors, cloud regions or suppliers involved.
Confirm which authority is competent for the organisation’s service before submitting. NIS reporting is a regulatory duty when its threshold is met; an NCSC report does not discharge it.
Criminal reporting: Report Fraud or Police Scotland
If the facts suggest fraud, extortion, unauthorised access, theft, malicious interference or another offence, consider a criminal report in parallel with cyber and privacy notifications. Organisations in England, Wales and Northern Ireland can use Report Fraud. Organisations in Scotland should use Police Scotland.
Preserve original evidence and avoid actions that could overwrite it. Keep a record of who collected each item, when it was collected, how it was stored and any transformation used for analysis. A criminal report does not replace NCSC, ICO, NIS, sector, insurer or contractual notifications.
Evidence to preserve after an AI compromise
AI investigations fail when teams retain only screenshots of the final answer. Preserve the inputs, execution context and downstream effects that allow another investigator to reproduce what happened.
Model and application context
- Model name, provider, version, deployment identifier and configuration at the time of each event.
- Application release, orchestration code, system and developer instructions, safety policies and feature flags.
- Fine-tuning, retrieval, evaluation or policy changes made before and after the incident.
Prompts, outputs and tool activity
- Exact user, system and developer prompts, including hidden or retrieved instructions.
- Raw model outputs, refusal messages, safety-filter decisions and any transformed or post-processed output.
- Tool names, arguments, permissions, approval decisions, return values and the order in which calls occurred.
- Conversation, request and trace identifiers that connect model events to user or service actions.
Identity, access and infrastructure logs
- Authentication events, token issuance and revocation, privilege changes, API-key use and administrative actions.
- Application, gateway, cloud, endpoint, network, database and storage audit logs covering the affected period.
- Indicators of compromise such as suspicious IP addresses, hashes, domains, processes, accounts or unusual data transfers.
Data and impact records
- Affected prompts, datasets, retrieval indexes, documents, personal-data fields and model artefacts.
- Users, customers, suppliers, systems and jurisdictions potentially affected.
- Service degradation, harmful autonomous actions, unauthorised changes and confirmed or suspected exfiltration.
Response and supplier records
- Containment commands, isolation times, key rotations, restored backups and validation results.
- Messages to and from model, cloud, security and data-processing suppliers, including their incident references and findings.
- Notification decisions, legal advice, regulator contacts, insurance notices and contractual communications.
Record timestamps with a consistent time zone and preserve the original format before analysis. Limit access to evidence, hash or otherwise integrity-protect exported files where your procedures support it, and maintain a chain-of-custody record.
A practical response sequence
- Declare and coordinate. Activate the incident plan, assign decision rights and create a secure channel independent of the suspected compromise.
- Contain without destroying evidence. Revoke exposed credentials, pause dangerous tools, isolate affected hosts or retrieval sources and preserve volatile logs before shutdown where safe.
- Scope the consequences. Identify personal data, regulated or essential services, customers, suppliers, cross-border processing and possible criminal conduct.
- Report to NCSC. Use a separate uncompromised system, complete the six-section form, request technical signposting if needed and retain the submission details.
- Make mandatory notifications. Submit an ICO notification when the UK GDPR threshold is met; notify the applicable NIS or sector authority; contact Report Fraud or Police Scotland when crime is suspected; notify insurers and contractual parties required by policy or agreement.
- Maintain a dated decision log. Record facts known, assumptions, decisions, owners, deadlines and changes. Send supplemental information as the investigation develops rather than waiting to assemble a perfect narrative.
- Remediate and learn. Review prompts, model and application versions, permissions, training or retrieval data, tool controls, monitoring and supplier safeguards. Feed lessons into the incident plan and vulnerability-disclosure process.
Monitoring and preparation for future incidents
NCSC guidance expects AI and machine-learning systems to have incident and vulnerability-management processes, a route for researchers or users to report vulnerabilities, trained responders and plans for AI-specific scenarios. Implement those controls before an incident rather than designing them during a crisis.
Log what investigators will need
Monitor inputs and outputs in a privacy-conscious way, retain model and application version identifiers, capture tool calls and approvals, and connect AI traces to identity and infrastructure logs. Define retention, access and redaction rules so evidence remains usable without creating an uncontrolled copy of sensitive data.
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Test the dangerous paths
Exercise prompt-injection bypasses, poisoned retrieval content, stolen credentials, unauthorised tool calls, harmful autonomous actions and compromise of connected business systems. Include a separate-system reporting drill and a 72-hour privacy-decision exercise so legal and technical teams can work from the same timeline.
Clarify supplier responsibilities
Contracts should identify who monitors the model or platform, who preserves logs, how quickly each party must notify the other, which party contacts regulators and how cross-border processing is handled. Keep current escalation contacts and test them; a supplier’s investigation does not remove the organisation’s own reporting duties.
Common mistakes and how to correct them
Reporting only to NCSC
Problem: The organisation assumes the cyber report covers privacy, NIS, criminal or contractual duties.
Correction: Run a parallel notification checklist for ICO, NIS or sector authorities, Report Fraud or Police Scotland, insurers and affected contractual parties.
Waiting until the investigation is complete
Problem: Teams delay an ICO decision while trying to determine the exact model failure.
Correction: Use the awareness time, submit known facts within the applicable period, and update as evidence improves.
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Correction: Report from a separate trusted system and establish an independent coordination channel.
Keeping only screenshots
Problem: Screenshots omit hidden prompts, version data, tool arguments and timestamps needed to reproduce the event.
Correction: Export raw prompts, outputs, traces, access logs, datasets and containment records with integrity and chain-of-custody controls.
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Problem: A harmful answer is investigated in isolation while credentials, retrieval sources or connected systems remain exposed.
Correction: Trace the complete path from input and identity through model, tools, data stores and downstream actions.
Ignoring cross-border and supplier effects
Problem: Cloud regions, overseas users or processors are omitted from the assessment.
Correction: Record jurisdictions and supplier roles early, then include cross-border effects in NIS and privacy assessments and follow contractual escalation terms.
Quick Recap
Key points to remember
- The NCSC Report a Cyber Incident/Cyber Incident Signposting Service is the practical UK cyber-reporting entry point. Its six-section form takes about 15 minutes, is monitored 24/7 and should be completed from a separate system if compromise is possible.
- NCSC reporting provides assistance and intelligence sharing; it does not replace ICO, NIS, sector, criminal, insurance or contractual notifications.
- A qualifying UK GDPR personal-data breach must be reported to the ICO without undue delay and, where applicable, within 72 hours of awareness.
- NIS and sector duties depend on the organisation’s regulated role and the impact on the relevant service.
- AI evidence includes prompts, model and application versions, outputs, tool calls, permissions, logs, datasets, indicators of compromise, containment actions and supplier communications.
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