Incident Response Plan (IRP) — written, tested annually, and includes a cyber-specific playbook

Trigger

When this rule fires

No documented IRP; IRP not tested in last 12 months; IRP does not cover cyber incident scenarios; FSCA notification procedure not included in IRP

Applicability gate

Confirm the entity's role before treating this as a duty

This is a readiness rule mapped to JS2 themes. Its presence in the library does not establish that JS2 applies directly to the firm.

• Insurance Broker: Most independent non-life Category I brokers are not directly in JS2's defined scope. A broker may be directly in scope if it separately meets a listed category, and may face contract or oversight requirements from an in-scope institution. Third-party provisions impose duties on the in-scope financial institution. They do not themselves make every supplier or intermediary directly subject to JS2.
• Uma Binder Holder: UMA or binder-holder status is not itself listed in JS2's definition. Direct scope depends on another listed capacity; insurer contracts and oversight may create evidence requirements. JS2 paragraph 3.3 concerns juristic persons structured under an insurer or designated insurance group; it is not a blanket rule for every independent UMA or intermediary.
• Insurer: An insurer as defined in the Insurance Act is directly in scope of JS2 from 1 June 2025. Apply proportionality and distinguish the insurer's own duty from requirements it places on third parties.

Citation

Mapped source

This control maps to the public instruments below. The mapping does not establish entity applicability.

Section

Joint Standard 2 of 2024 — paragraph 7.5 (incident response and management) / POPIA s.22

Legislation

• Joint Standard 2 of 2024
• POPIA s.22

Remediation

How to close the gap

Develop a cyber-specific IRP using the NIST incident response framework (Identify → Protect → Detect → Respond → Recover). Include regulator notification procedures (FSCA, Information Regulator, ASISA/SAIA CSIRT). Conduct an annual tabletop exercise and document findings.

Evidence required

Evidence to prepare if this control applies

• Current IRP document with version date
• Tabletop exercise records (scenario, participants, findings, last 12 months)
• IRP distribution list (all relevant staff)
• FSCA / POPIA notification procedure within IRP
• Contact list for key stakeholders (lawyers, forensics, PR, insurers)