The overlapping incident clocks
First-report deadlines of eight regimes, timed from awareness: DORA at 4 hours after classification to the AI Act and SB 53 at 15 days, in one incident record.
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One event can start several clocks. First reports, counted from awareness unless noted, as of 2026-09-24: DORA Art. 19, within 4 hours of classification as major and no later than 24 hours from awareness, or within 4 hours of a classification made after those 24 hours; NIS2 Art. 23, an early warning within 24 hours and a notification within 72 hours; the Cyber Resilience Act Art. 14, an early warning within 24 hours and a notification within 72 hours; California SB 53, within 15 days of discovery, or within 24 hours on an imminent risk of death or serious physical injury; EU AI Act Art. 73, no later than 2 days (widespread infringement or critical infrastructure), 10 days (death) or 15 days (other); the GPAI Code of Practice under Art. 55, 2, 5, 10 or 15 days depending on the harm; GDPR Art. 33, where feasible within 72 hours; the New York RAISE Act, within 72 hours of a determination, effective 1 Jan 2027. Follow-up and final reports, the deployer's duty under Art. 26(5), GDPR Art. 34 and the voluntary OECD framework are in the table. The engineering answer is one incident record that holds the facts once, with a timer per regime, and a pipeline that alerts on the nearest deadline.
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“The overlapping incident clocks” by Jorge García Aibar, aigovernanceengineer.com (https://aigovernanceengineer.com/figures/incident-clocks), v0.5.0. Licensed under CC BY 4.0 (https://creativecommons.org/licenses/by/4.0/).
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<img src="https://aigovernanceengineer.com/downloads/figures/incident-clocks-v0.5.0-light-1600.png" alt="First-report deadlines of eight regimes, timed from awareness: DORA at 4 hours after classification to the AI Act and SB 53 at 15 days, in one incident record." width="800" height="1133" loading="lazy">
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<a href="https://aigovernanceengineer.com/figures/incident-clocks">The overlapping incident clocks</a> by Jorge García Aibar,
aigovernanceengineer.com, v0.5.0.
Licensed under <a href="https://creativecommons.org/licenses/by/4.0/">CC BY 4.0</a>.
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*[The overlapping incident clocks](https://aigovernanceengineer.com/figures/incident-clocks) by Jorge García Aibar, aigovernanceengineer.com, v0.5.0. Licensed under [CC BY 4.0](https://creativecommons.org/licenses/by/4.0/).*