CyberCQR Top 10 · Ransomware
Ransomware preparedness: ten actions before an attack
Ransomware is now as much about stolen data as locked systems. These are the ten things a board should make sure are in place before an attack, with the evidence behind each one.
Summary
The point for boards. Ransomware is not only an IT recovery problem. When data has been stolen, a backup gets your systems back but not your data. The decisions that set the final cost, such as whether to pay, what to restore first and who to tell, are board decisions. The time to make them is before the attack, not during it.
What has changed
Ransomware has grown and changed shape. Black Kite counted 7,551 victims named on criminal leak sites in the twelve months to March 2026, the fourth record year in a row, spread across 127 active criminal groups, 61 of them new [1]. One group, Qilin, accounted for 1,358 victims on its own [1].
Most attacks are never made public. In 2025, BlackFog recorded 1,174 publicly disclosed attacks against 7,079 victims named only on leak sites, which means about 86% were never reported in public [3]. The UK accounted for 42 of the disclosed attacks [3]. What appears in the news is a small part of the total.
The attack itself has changed too. In the first quarter of 2026, data was stolen in 96% of attacks, and the average ransom demand in disclosed attacks was $1,028,214 [2]. Stealing data first gives the attacker a second lever: pay, or see your clients' and staff's data published.
The cost to UK organisations in 2025 was severe. The attack on Jaguar Land Rover was estimated to have cost the UK about £1.9 billion and affected around 5,000 organisations, most of which were never attacked themselves [5]. Marks & Spencer expected a hit of about £300 million to its operating profit from its own attack [6]. The National Cyber Security Centre (NCSC) handled 204 nationally significant incidents in the year to August 2025, up from 89 the year before [7].
About the figures. Black Kite and BlackFog are security companies. Their counts come from criminal leak sites and public disclosures, cover different periods, and are mostly outside the UK, so they show direction rather than the risk to any one firm. Where a UK source exists, this page uses it.
The ten actions
1. Agree the board's position on paying a ransom, before an attack
Why it matters. During an attack, the pressure to decide quickly is intense, and the decision has legal, regulatory and ethical sides. Law enforcement does not encourage, endorse or condone paying [8]. Paying does not reduce enforcement action by the Information Commissioner's Office (ICO), although early engagement with the NCSC is taken into account [9]. Paying a group that is subject to UK financial sanctions can be a breach of sanctions law, and the Office of Financial Sanctions Implementation (OFSI) can impose penalties even where the payer did not know [10].
What to do.
- Record the organisation's position: whether it would ever pay, and on what conditions.
- Name who can authorise a payment, and their deputies, so the decision cannot stall.
- Require legal advice on sanctions, insurance and reporting before any payment.
- Minute the position and review it every year.
The government plans to ban ransom payments by the public sector and regulated critical national infrastructure, and to make reporting compulsory. At the time of writing these proposals were not yet law, and most private firms would not be covered by the ban [11].
2. Keep backups an attacker cannot reach, and prove they restore
Why it matters. Attackers look for connected backups and destroy them before they lock anything else. The NCSC recommends several copies in different places, at least one of them offline, and regular restore tests [8][17]. Backing up is common: 95% of medium and 90% of large UK businesses do it [4]. Restoring a critical system after an attack is a different test, and the one that counts.
What to do.
- Keep at least one copy that cannot be changed or deleted from the network: offline, or locked so it is immutable.
- Back up the systems that control access and configuration, not only the files.
- Restore a critical system end to end at least twice a year, time it, and report the result to the board.
3. Read the cyber insurance policy, not the summary
Why it matters. Malware and ransomware made up 51% of UK cyber insurance claims in 2024, up from 32% the year before, and insurers paid £197 million in total [12]. A policy is only as good as the answers on the proposal form: if the controls you declared are not really in place, the claim is at risk.
What to do.
- Read the exclusions and conditions, for example those covering multi-factor authentication (MFA), backups and patching.
- Check that what the proposal form said is still true, before every renewal.
- Know the claim process and which specialists the insurer will send.
4. Choose specialist help before you need it
Why it matters. Finding an incident response firm, specialist lawyers and crisis communications support in the middle of an attack costs days. The NCSC runs an assured Cyber Incident Response scheme for exactly this purpose [18], and many insurers have their own panel.
What to do.
- Choose an incident response firm, from the NCSC-assured scheme or your insurer's panel, and agree how to engage it at short notice.
- Choose specialist legal advice for breach notification and regulatory response.
- Arrange crisis communications support.
- Know how to report: to the NCSC, and to Report Fraud, which replaced Action Fraud as the national reporting service [19].
- Keep every contact somewhere that works when your own systems do not.
5. Know your critical systems and the order to restore them
Why it matters. Not every system matters equally. Arguing about what to restore first, during an attack, wastes the days that matter most. The NCSC advises identifying critical assets as part of planning for an attack [8].
What to do.
- List the five to ten systems the business cannot run without, and the data that would cause most harm if published.
- Set a target restore time for each: hours, days or weeks.
- Separate the most critical systems on the network so an attack does not reach them easily.
- Have the board agree the order.
6. Rehearse with the board every year
Why it matters. Plans look complete until someone has to use them. The government's Cyber Governance Code of Practice asks boards to gain assurance that the incident plan is exercised at least once a year, with lessons fed back into the plan [13]. The NCSC assures firms that run exercises under its Cyber Incident Exercising scheme [20].
What to do.
- Run a tabletop exercise where data is stolen as well as systems locked.
- Include the payment decision, the regulator notice and the message to clients.
- Record what was unclear, fix it, and repeat next year.
7. Prepare who you tell, and when
Why it matters. An attack starts several clocks at once. Where personal data is at risk, the ICO must be told within 72 hours of the organisation becoming aware [16]. Regulators such as the Financial Conduct Authority (FCA) and the Solicitors Regulation Authority (SRA) have their own expectations. Yet only 40% of UK businesses reported their most disruptive breach to anyone outside the organisation [4].
What to do.
- List who must be told, by when: the ICO, your sector regulator, insurers, the NCSC and Report Fraud, clients and staff.
- Draft template messages now, and have them checked by your lawyers.
- Name one spokesperson.
- Plan how to communicate if email and the intranet are down.
8. Control administrator access
Why it matters. An attacker with an administrator account can switch off backups and security tools and spread across the network. The NCSC advises MFA at every remote access point [8]. In March 2025 the ICO fined a software provider £3.07 million after a ransomware attack that began through an account without MFA [14].
What to do.
- MFA on email, remote access and every administrator account, using phishing-resistant methods such as passkeys or security keys for administrators.
- Separate administrator accounts, used only for administration.
- Grant administrator rights when needed and for a limited time, not permanently.
- Review who holds administrator rights every quarter.
9. Fix exposed weaknesses quickly, and detect what gets through
Why it matters. Exploited software flaws were the way in for 20% of breaches in Verizon's 2025 data [15]. Many victims stay exposed even after an attack: when Black Kite rescanned them, 43.5% still had a critical vulnerability and 30.8% still had a flaw known to be actively exploited [1]. Encryption is usually the last stage of an attack; the earlier stages are when it can still be stopped.
What to do.
- Keep a list of every internet-facing system and patch known flaws in them straight away, as the NCSC advises [8].
- Run endpoint detection and response (EDR) on every laptop and server.
- Make sure someone watches alerts out of hours, in-house or through a provider.
- Agree in advance who may isolate a device or cut a connection without waiting for sign-off.
10. Keep the playbook where you can reach it offline
Why it matters. All of the above is useless if it sits on systems that have just been locked. The board needs the essentials on paper and on devices outside the corporate network.
What to do.
- A one-page card for each director: who to call, who decides, and the first three steps.
- A short playbook with the payment position, contact lists, notification deadlines and message templates.
- Copies held off the network, in print and on personal devices.
- Review it every quarter, and after every exercise.
- Ask your lawyers whether incident reports should be prepared under legal privilege.
A 90-day plan
| When | Actions | Usually owned by |
|---|---|---|
| Weeks 1 to 4 | 1. Payment position · 3. Insurance check · 5. Critical systems and restore order | Chair, chief executive, finance director, general counsel |
| Weeks 5 to 8 | 2. Offline backups and a restore test · 4. Specialist help · 7. Who you tell | Head of IT or security, general counsel, communications |
| Weeks 9 to 12 | 8. Administrator access · 9. Patching and detection · 10. Offline playbook | Head of IT or security, company secretary |
| Within six months, then yearly | 6. Board exercise, with lessons fed back into the plan | Full board and executive team |
Table 1. A suggested order. Firms with some actions already in place can move faster.
Five questions for your next board meeting
- Have we agreed, and minuted, our position on paying a ransom and who can authorise it?
- When did we last restore a critical system from a backup an attacker could not have reached, and how long did it take?
- Is everything we told our insurer on the proposal form still true today?
- If our systems were locked tonight, who would we call first, and where are their numbers kept?
- When did the board last rehearse a ransomware attack, and what did we change afterwards?
Glossary
| Term | Meaning |
|---|---|
| Double extortion | Stealing data before locking systems, then threatening to publish it unless paid. |
| Endpoint detection and response (EDR) | Software on each device that spots suspicious behaviour and can isolate the device. |
| Immutable backup | A backup copy that cannot be changed or deleted for a set period, even by an administrator. |
| Leak site | A website run by a criminal group where it names victims and publishes stolen data. |
| Multi-factor authentication (MFA) | Signing in with something beyond a password, such as an app prompt or a security key. |
| Phishing-resistant MFA | Sign-in methods, such as passkeys and security keys, that a fake website cannot capture and reuse. |
| Sanctions | Legal restrictions on dealing with named people or groups, enforced in the UK by OFSI. |
| Tabletop exercise | A rehearsal where people talk through how they would handle a realistic incident, step by step. |
Table 2. Terms used on this page (alphabetical).
Further reading
From CyberCQR
- Could we recover without paying? The interactive board self-assessment based on these ten actions.
- Would extortion still work on you? How ransomware moved from locking files to stealing data, and the part AI now plays.
- Third-Party and Supply Chain Ransomware. Attacks that reach you through your suppliers.
External
References
- [1]Black Kite Research Group, 2026 Ransomware Report (publicly disclosed victims, April 2025 to March 2026).
https://blackkite.com/reports/2026-ransomware-report - [2]BlackFog, Q1 2026 Ransomware Report, press release, 6 May 2026.
https://www.blackfog.com/blackfog-q1-2026-ransomware-report-press-release/ - [3]BlackFog, 2025 State of Ransomware Report, 12 February 2026.
https://www.blackfog.com/2025-state-of-ransomware-report-released/ - [4]Department for Science, Innovation and Technology and Home Office, Cyber Security Breaches Survey 2025/2026, 30 April 2026.
https://www.gov.uk/government/statistics/cyber-security-breaches-survey-20252026/cyber-security-breaches-survey-20252026 - [5]Cyber Monitoring Centre estimate, reported by City AM, £1.9bn price tag makes JLR Britain's most expensive cyber attack, 22 October 2025.
https://www.cityam.com/1-9bn-price-tag-makes-jlr-britains-most-expensive-cyber-attack/ - [6]The Register, M&S cyberattack disruption (full-year results), 21 May 2025.
https://www.theregister.com/2025/05/21/ms_cyberattack_disruption/ - [7]National Cyber Security Centre, Annual Review 2025: incident management.
https://www.ncsc.gov.uk/collection/ncsc-annual-review-2025/chapter-01-cyber-threat-to-the-uk/incident-management - [8]National Cyber Security Centre, Mitigating malware and ransomware attacks.
https://www.ncsc.gov.uk/guidance/mitigating-malware-and-ransomware-attacks - [9]Information Commissioner's Office and NCSC, joint letter to the Law Society on ransomware payments, July 2022.
https://ico.org.uk/media2/migrated/4020874/ico-ncsc-joint-letter-ransomware-202207.pdf - [10]RPC, Ransoms and sanctions and fines, on OFSI's Ransomware and Sanctions guidance (February 2023), 4 September 2023.
https://www.rpclegal.com/thinking/data-and-privacy/ransoms-and-sanctions-and-fines-oh-my/ - [11]Baker McKenzie, UK government responds to ransomware proposals (government response of 22 July 2025).
https://connectontech.bakermckenzie.com/uk-government-responds-to-ransomware-proposals/ - [12]Association of British Insurers, Nearly £200 million paid in cyber claims to help UK businesses recover, November 2025.
https://www.abi.org.uk/news/news-articles/2025/11/nearly-200-million-paid-in-cyber-claims-to-help-uk-businesses-recover/ - [13]Department for Science, Innovation and Technology, Cyber Governance Code of Practice: one-page summary, April 2025.
https://assets.publishing.service.gov.uk/media/67ffbb30b73354468d135556/Cyber_Governance_Code_of_Practice_-_one_page_summary.pdf - [14]Information Commissioner's Office, Software provider fined £3m following 2022 ransomware attack, 27 March 2025.
https://ico.org.uk/about-the-ico/media-centre/news-and-blogs/2025/03/software-provider-fined-3m-following-2022-ransomware-attack/ - [15]Verizon, 2025 Data Breach Investigations Report, April 2025.
https://www.verizon.com/business/resources/reports/dbir/ - [16]Information Commissioner's Office, Ransomware and data protection compliance.
https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/security/a-guide-to-data-security/ransomware-and-data-protection-compliance/ - [17]National Cyber Security Centre, Ransomware-resistant backups.
https://www.ncsc.gov.uk/collection/ransomware-resistant-backups - [18]National Cyber Security Centre, Cyber Incident Response scheme.
https://www.ncsc.gov.uk/schemes/cyber-incident-response/introduction - [19]City of London Police, Report Fraud service goes live, with full public launch in January 2026, December 2025.
https://www.cityoflondon.police.uk/news/city-of-london/news/2025/december/report-fraud-service-goes-live-with-full-public-launch-in-january-2026/ - [20]National Cyber Security Centre, Cyber Incident Exercising scheme: information for buyers.
https://www.ncsc.gov.uk/schemes/cyber-incident-exercising/information-for-buyers
Security is the outcome, not a solution.
CyberCQR is a UK cyber security advisory practice. We help boards prepare for ransomware with independent reviews, tabletop exercises and incident planning, without vendor commissions or product resale.