Preliminary Steps for NIS2 Compliance
Assess whether your organization qualifies as an Essential or Important Entity under Article 2.
Essential Entities: Healthcare, Energy, Transportation, and other critical infrastructure sectors.
Important Entities: Digital Services, Manufacturing, and additional critical sectors.
Review and modify internal policies (Article 18) to ensure existing security policies and business processes align with requirements.
Notes:
Consider newly included sectors under Article 3, some sectors and services were not covered under the original NIS Directive and your organization may now be affected.
Administer a gap analysis to evaluate current organizational cybersecurity policies, technologies, processes and measures against Article 21 requirements.
Modify workflows to include necessary security controls.
Update supply chain security practices to ensure your supply chain meets requirements and aligns with Article 19 of the NIS2 directive.
Designate management level individual (Article 5), such as a Chief Information Security Officer (CISO) or similar role, to oversee compliance efforts.
Invest in continuous employee training (Article 22) covering the technical aspects of cybersecurity and legal and compliance requirements through top-down leadership.
Implementing NIS2 Directive
The appointed team should establish governance structures in alignment with Article 21 to manage cybersecurity risks, ensure regular reporting, and facilitate accountability throughout the organization.
Have the team complete a compliance roadmap to prioritize and address identified gaps.
Develop and formalize a robust cybersecurity risk management framework tailored to your organization’s specific operations (Article 18).
Include documented cybersecurity policies that address key areas such as access controls, encryption, system updates, and network protection tools like firewalls and intrusion detection systems.
Leverage recognized frameworks such as ISO 27001, NIST CSF, or SOC 2 to implement detailed controls and align with international security standards as recommended under Article 18 of NIS2.
Ensure regular reviews and updates to adapt to evolving cyber threats in accordance with Article 21.
Create and implement a comprehensive incident response plan (Article 23) that includes processes for detecting, classifying, and resolving cybersecurity incidents.
The plan should cover containment, eradication, and recovery steps.
Regularly test this plan (Article 18) through tabletop exercises or simulations to ensure readiness.
Comply with NIS2’s strict incident reporting requirements (Articles 23-24) by notifying relevant authorities within 24 hours of detecting a major incident.
Include follow-up reports that provide detailed analyses and corrective measures.
Ensure all employees, from executives to frontline staff, receive regular cybersecurity awareness training.
Focus on topics such as phishing prevention, secure password practices, and incident reporting procedures.
Tailor the training to address the specific needs and risks of different roles within the organization.
Track participation and effectiveness through assessments.
Periodically adjust the program based on emerging threats.
Ensure your organization has documented business continuity and disaster recovery plans to maintain critical operations during disruptions.
These plans should define recovery time objectives (RTOs) and recovery point objectives (RPOs) for essential services.
Regularly test the plans through simulations and update them as necessary to reflect changes in your operational environment or threat landscape.
Preparing for the External Audit
Keep detailed records of all activities related to compliance, including:
Risk assessments
Incident responses
Policies and training logs
Vendor evaluations
Cybersecurity policies
Response actions
Keep records organized, up-to-date, and readily accessible for regulatory audits or requests from national authorities.
Notes:
Comprehensive documentation supports transparency and accountability.
Use tools such as Security Information and Event Management (SIEM) systems, as outlined in Article 18, to analyze network traffic, user activity, and system logs in real-time.
Implement advanced monitoring and reporting workflows to improve the detection of vulnerabilities, threats, and unusual activities within your network.
Regularly report and share cybersecurity performance metrics, vulnerabilities, and compliance status to relevant national authorities and internal stakeholders in alignment with Article 24 of the NIS2 Directive. This proactive approach helps demonstrate your organization’s commitment to compliance.
Identify critical third-party providers and dependencies in your supply chain.
Conduct due diligence on vendor’s cybersecurity capabilities to ensure they meet NIS2 standards.
Include specific cybersecurity clauses in contracts that obligate vendors to adhere to these requirements.
Continuously monitor their performance and conduct regular audits to address potential risks. Consider adopting GRC tools that enhance visibility into supply chain vulnerabilities.
Engaging in the Certification Audit & Maintaining Compliance
Conduct internal and external audits to ensure ongoing compliance with NIS2 requirements
Internal audits should focus on evaluating the effectiveness of implemented controls and identifying areas for improvement.
External audits conducted by third-party experts objectively assess your compliance posture.
Use the findings from audits to refine your cybersecurity strategies and address gaps promptly to refine organizational security measures.
Engage with national and sector-specific authorities to stay informed about evolving updates to threat intelligence, best practices, and updates to the NIS2 guidelines according to Article 25.
Participation in industry forums and information-sharing initiatives can provide valuable insights and enhance your organization’s ability to respond to emerging threats.
Stay updated on changes to the NIS2 Directive and other relevant regulations.
Monitor the threat landscape for new risks that may impact your organization and adjust compliance strategies accordingly in alignment with Article 21 of the NIS2 Directive.
Establish a dedicated team or partner with cybersecurity firms to provide regular updates and recommendations for staying compliant and secure.
Keys to Success
By aligning with NIS2 requirements, organizations can strengthen their defenses, mitigate risks, and build trust with stakeholders, customers, and partners.
Implementing a robust compliance framework, staying informed about evolving NIS2 regulations, and leveraging modern tools are critical steps in safeguarding your organization’s infrastructure and data.
Regular training and employee engagement is essential for NIS2 Directive compliance.
Continuous improvement through audits and real-time monitoring is a key part of remaining compliant.
