NIS2 Compliance Across All Sectors: Challenges and Technical Solutions

Author: Abdulla Bagishev
Year: 2025
Subject: Cybersecurity Compliancy

NOTE: This paper is based on a school project I previously completed. The content was rewritten with the help of ChatGPT for personal reference and ease of review. The text was AI-generated to assist in organizing and clarifying the material.

1. Introduction to NIS2

The Network and Information Systems Directive 2 (NIS2) is the EU’s answer to rising cyber threats across vital sectors. Replacing the original NIS Directive (NIS1) from 2016, NIS2 came into force in January 2023 with a much broader scope and stricter demands. Its goal? To raise the cybersecurity baseline across Member States and minimize the fragmentation seen in previous laws. Under NIS2, 18 sectors—from energy to food supply, cloud providers to public administration—must now follow tighter rules. Organizations within scope need to manage risks proactively and report serious incidents fast. This isn’t just about ticking boxes; it’s about resilience.

Key Differences from NIS1: NIS2 introduces several important changes compared to its predecessor:

• Expanded Scope: NIS1 focused mainly on traditional critical infrastructure (energy, transport, banking, healthcare, etc.), but NIS2 broadens the scope to include many more sectors and types of entities. For example, digital service providers (cloud computing, online marketplaces, search engines), manufacturers of critical products, food supply, wastewater, public administration, and more are now in scope. This means far more organizations fall under NIS2 compliance requirements than under NIS1. NIS2 also classifies in-scope organizations as either “essential” or “important” entities, with essential entities (e.g. energy, health) facing stricter oversight.

• Risk-Based Approach: Unlike NIS1 which was more compliance-oriented, NIS2 emphasizes a risk management approach. Organizations must assess and mitigate cybersecurity risks continuously, tailoring security measures proportional to their risk exposure. This shift means entities should adopt practices like regular risk assessments and security controls based on the evolving threat landscape.

• Stricter Incident Reporting: NIS2 focuses significantly more on incident reporting obligations. Under NIS2, organizations must follow a shorter timeline for notifying authorities of cybersecurity incidents: an initial warning within 24 hours of becoming aware of an incident, an update or incident assessment within 72 hours, and a detailed final report within one month . This is a notable change from NIS1’s more lenient reporting timeline. Moreover, NIS2 standardizes reporting protocols (potentially via central platforms) to ensure swift information sharing. The stricter timelines underscore the urgency of incident response under NIS2.

• Enhanced Cooperation and Transparency: NIS2 aims to reduce legal confusion by introducing common criteria, strengthening cross-border cooperation, and supporting centralized crisis response via bodies like EU-CyCLONe.

• Stronger Enforcement and Accountability: NIS2 comes with tougher penalties and accountability requirements. Organizations that fail to comply can face substantially higher fines – up to €10 million or 2% of global annual turnover (whichever is higher) for essential entities. This is a significant increase from NIS1’s penalties and is designed to deter negligence. Uniquely, NIS2 also holds top management personally accountable for compliance. Company leadership (owners, directors, etc.) are explicitly obligated to oversee cybersecurity measures, and they can be held liable for failures. This elevates cybersecurity to a board-level issue, ensuring that executives take an active role in governance and allocate sufficient resources to meet NIS2 requirements.

In summary, NIS2 builds on NIS1’s foundation but raises the bar by a large margin through a broader scope, a risk-focused philosophy, stricter incident reporting, unified EU-wide practices, and more severe consequences for non-compliance. Its introduction reflects the EU’s recognition that growing cyber threats demand more robust and harmonized defenses across all critical sectors.

2. Challenges in NIS2 Compliance

Implementing NIS2 across diverse sectors presents several challenges, both technical and organizational. Companies must address an evolving threat landscape while meeting new regulatory demands. Key challenges include:

• Evolving Cyber Threats and Vulnerabilities: NIS2 was motivated by the surge in sophisticated attacks like ransomware, supply chain compromises, and advanced persistent threats. As noted by ENISA, “ransomware is [currently] the prime threat followed by malware and social engineering” . These threats can cause severe disruptions to essential services. Organizations may find it challenging to keep pace with attackers who constantly develop new exploits. NIS2 specifically calls for measures like vulnerability management and supply chain security to counter these threats , yet many companies lack mature processes in these areas. For example, the SolarWinds attack and other supply chain breaches revealed that even well-defended companies can be compromised via their suppliers – NIS2’s requirement for assessing supplier security aims to mitigate this, but implementing thorough third-party risk management is inherently complex.

• Regulatory and Operational Complexity: Complying with NIS2 can be daunting due to its breadth and the need to align with other regulations. One difficulty is the fragmented transposition across Member States. As of early 2025, only a handful of countries had fully enacted NIS2, while others are still drafting laws . This creates uncertainty for organizations operating in multiple EU countries: they must prepare for NIS2 without clear local guidance in some cases. Additionally, NIS2 compliance must be achieved alongside existing laws like GDPR. There is a need to align NIS2’s cybersecurity requirements with data protection obligations . For instance, NIS2 mandates extensive logging and incident reporting, which might involve processing personal data, but GDPR imposes strict limits on data retention and use. Companies must navigate potential conflicts (e.g., storing security logs for the required period vs. minimizing personal data retention) in a way that satisfies both sets of rules . This balancing act demands careful policy planning to avoid legal pitfalls.

• Backup and Recovery Challenges: NIS2 explicitly addresses business continuity by requiring up-to-date backups and disaster recovery plans . Many organizations, however, struggle with maintaining reliable, secure backups. Ensuring that backups are regularly performed, offline or immutable (to withstand ransomware), and quickly restorable is an operational challenge. Organizations that did not previously prioritize disaster recovery must now invest in resilient backup infrastructure. As one industry analysis notes, “backups must be up to date” and accessible during and after a security incident , which implies rigorous backup procedures. For companies with complex, distributed IT systems, implementing centralized and secure backup processes (and testing them frequently) can be a significant undertaking.

• Logging and Monitoring Requirements: To meet NIS2’s incident detection and reporting obligations, organizations need robust logging, monitoring, and auditing capabilities. NIS2 effectively requires that logs of relevant security events be collected and retained for forensic analysis and compliance audits. In fact, the directive mandates storing logs from all systems in a tamper-proof manner for at least 18 months . This poses challenges in terms of data storage capacity, log management, and security. Companies must deploy centralized log management or Security Information and Event Management (SIEM) solutions to handle the volume and ensure logs are protected from alteration. Furthermore, analyzing these logs to detect intrusions (e.g., via continuous security monitoring or automated threat detection) demands skilled staff and tools. Many organizations face a shortage of cybersecurity talent and may find it hard to establish a 24/7 monitoring capability, yet NIS2’s emphasis on early incident detection makes it necessary.

• Incident Response and Reporting Readiness: NIS2’s tight incident reporting timeline (notification within 24 hours) means that organizations must have well-drilled incident response (IR) plans and teams. This is challenging for entities that are not used to formal IR procedures. They need to define clear roles, communication channels, and decision processes that kick in immediately when an incident is detected. Many businesses, especially newly covered “important” entities, are currently unprepared for structured incident response and unsure about reporting protocols . Preparing to comply with NIS2 involves training teams on how to handle incidents, what information to collect, and how to coordinate with national CSIRTs or authorities within the mandated timelines. Simultaneously, organizations must avoid “alert fatigue” – distinguishing significant incidents that must be reported from minor events. Getting this wrong (either failing to report, or over-reporting trivial issues) could have regulatory repercussions.

• Resource Constraints and Skills Gap: Achieving NIS2 compliance requires investments in new technologies, processes, and personnel. For many organizations, particularly medium-sized ones, budget and resource allocation is a major hurdle. Complying with the myriad NIS2 mandates (from technical safeguards to training programs) often demands “fresh investments in training, technology upgrades, and perhaps additional personnel” . Justifying and securing these resources can be difficult, especially if cybersecurity was previously underfunded. Additionally, there is an industry-wide cybersecurity skills shortage – finding qualified experts to lead compliance efforts, manage security operations, and carry out risk assessments can be challenging. Companies may need to rely on external consultants or managed security services, which introduces its own management challenges.

• Operational Integration and Legacy Systems: Implementing NIS2 controls in environments with legacy systems or operational technology (OT) (common in sectors like manufacturing, energy, transport) can be problematic. Older systems may not support modern security controls or logging, and upgrading them is costly or impractical. Integrating new security solutions (for access control, monitoring, etc.) with existing infrastructure can feel like “a jigsaw puzzle”, potentially causing disruptions . Ensuring compatibility and minimal downtime while overhauling security architecture requires careful planning. Moreover, OT systems in critical sectors often cannot be easily patched or taken offline, which complicates vulnerability management and incident response preparations under NIS2.

Despite these challenges, NIS2’s requirements also drive improvements in cybersecurity practices. Organizations are compelled to identify and remediate gaps in their defenses that they might not have addressed otherwise. The following sections discuss technical solutions and best practices to overcome these challenges and achieve NIS2 compliance.

3. Technical Solutions for NIS2 Compliance

To meet NIS2 requirements, organizations should implement a range of technical and organizational measures. NIS2 does not prescribe specific technologies, but it outlines areas where controls are expected . A practical approach is to adopt recognized cybersecurity frameworks and best practices that align with these areas. Below, we cover key technical solutions and measures – from high-level frameworks to specific security controls – that help fulfill NIS2 obligations across all sectors.

3.1 Implementing Cybersecurity Frameworks and Policies

A foundational step toward NIS2 compliance is adopting a structured cybersecurity framework that provides a comprehensive set of controls and management processes. NIS2 itself calls for policies on risk analysis and information security management , and encourages considering “state-of-the-art” standards . Many organizations choose to implement frameworks such as ISO/IEC 27001 or the NIST Cybersecurity Framework (CSF) as a way to organize their security program. These frameworks are well-aligned with NIS2’s risk-based approach and cover most of its technical areas. For example, ISO 27001 establishes an Information Security Management System (ISMS) with continuous risk assessment, controls for asset management, access control, incident management, business continuity, compliance, etc., which map closely to NIS2 measures. By instituting such a framework, companies ensure there are formal policies and procedures guiding their cybersecurity efforts (e.g., an information security policy, acceptable use rules, risk assessment methodology), which is exactly what Article 21 of NIS2 expects .

Concretely, organizations should:

• Conduct Risk Assessments: Follow a formal methodology to identify assets, threats, vulnerabilities, and the likelihood/impact of potential incidents. NIS2 requires an “all-hazards” risk analysis approach . Use tools or standards (like ISO 27005 or NIST SP 800-30) to perform these assessments regularly, and use the results to prioritize security improvements.

• Define Security Controls: Based on risk, implement appropriate controls across domains: physical security, network security, identity and access management, maintenance of systems, cryptography, etc. Ensure that these controls cover the minimum baseline measures NIS2 expects (which we detail in subsequent subsections). Developing a security architecture document or control catalog can be useful.

• Document Policies and Procedures: Create or update formal policies for key areas such as access control, data protection, incident response, backup, and vendor security. Clear policies help demonstrate compliance and guide employees. For instance, a policy on cryptography usage (covering encryption standards for data at rest and in transit) and an access control policy (defining account management, least privilege, etc.) are explicitly cited in the directive .

• Training and Awareness: A framework like ISO 27001 also highlights the importance of training. Under NIS2, basic cyber hygiene and employee cybersecurity awareness are required measures . Establish ongoing training programs so staff can recognize phishing attempts, follow secure practices, and understand their role in compliance. This addresses one of the common challenges (employee awareness) and is a technical control in the sense of operational security.

By grounding their program in a reputable framework and associated policies, companies create an organized path to compliance. It provides a checklist against which to measure progress and ensures no major category (like incident handling or supply chain security) is overlooked.

3.2 Secure Backup Strategies and Disaster Recovery

Backup management and disaster recovery (DR) are explicitly mandated by NIS2 as part of business continuity measures . The goal is to ensure that essential services can continue or rapidly resume in the event of a cyber incident (such as ransomware, data corruption, or system outage). Technical solutions and best practices in this area include:

• Regular, Redundant Backups: Follow the classic “3-2-1” backup rule – keep at least 3 copies of data, on 2 different storage media, with 1 offsite (or offline) copy . This guarantees data availability even if primary systems are compromised. Backups should be taken frequently (incrementally multiple times per day) for critical data to minimize data loss . Modern backup software can automate frequent snapshots of systems and databases.

• Geographic and Logical Separation: Store backup copies in a separate infrastructure or cloud than the primary systems. Using a vendor-independent cloud or offsite storage protects backups from being affected by the same incident that hits production (e.g., a fire, or a hacker who gains access to the primary network) . Air-gapped backups (completely offline or in cold storage) provide additional security against ransomware that tries to encrypt or delete backups .

• Immutability and Encryption: Ensure backup data is immutable (cannot be altered or deleted by anyone except under strict conditions) and encrypted. Immutability (via write-once-read-many storage or object-lock features) is crucial to prevent attackers from wiping out backups during a breach . Encryption (both in transit and at rest) protects the confidentiality of backup data, which is important if backups include personal or sensitive information . These measures align with NIS2’s emphasis on data integrity and protection.

• Documented Disaster Recovery Plan: Maintain a detailed DR plan that outlines the procedures to restore systems from backups and keep critical operations running during various incident scenarios. As quoted from the NIS2 directive, organizations must have “a plan for ensuring access to IT systems and their operating functions during and after a security incident” . This plan should define RTO/RPO (Recovery Time and Point Objectives) for services, responsible personnel, failover processes, and communication steps. Regularly review and update the plan as systems and threats evolve.

• Regular Testing of Backups and DR Process: Simply having backups is not enough; organizations need to routinely test them. Conduct scheduled restore tests (e.g., monthly or quarterly) to verify that backups can be successfully recovered and that systems can be rebuilt within the expected time frame . Also perform DR exercises or simulations (like disaster scenario drills) to practice the full recovery process. Testing provides assurance that backups are effective and identifies any gaps in procedures before a real incident occurs.

Implementing these backup and DR strategies ensures compliance with NIS2’s business continuity requirements and dramatically improves resilience. In a ransomware attack, for example, an organization with isolated, up-to-date, encrypted backups and a practiced recovery plan can avoid paying ransom and quickly restore operations – aligning with NIS2’s objective of minimizing incident impact on service recipients .

3.3 Data Privacy Protection Measures (Encryption, Access Control, Data Minimization)

Protecting the confidentiality and integrity of data is a core aspect of both cybersecurity and privacy compliance. NIS2 requires policies on the use of cryptography and encryption , as well as strong access control mechanisms and asset management . At the same time, organizations must heed data protection principles (like GDPR’s data minimization). Key technical measures include:

• Encryption of Data at Rest and in Transit: Deploy encryption to safeguard sensitive information. For data at rest (in databases, file storage, backups), use strong encryption algorithms and key management practices so that if attackers steal files or disks, the data remains unreadable. For data in transit (moving across networks), enforce TLS/SSL or VPN tunnels to prevent eavesdropping. NIS2 encourages cryptographic controls and “appropriate use of encryption” as a risk mitigation . Modern systems should use industry-standard encryption (e.g., AES-256 for storage, TLS 1.2+ for communications). Also consider end-to-end encryption for particularly sensitive communications, which aligns with best practices in secure communications.

• Identity and Access Management (IAM): Implement strict access control policies that follow the principle of least privilege. This includes user authentication mechanisms and authorization controls. Concretely: require multi-factor authentication (MFA) for all remote access and for any access to critical systems, as explicitly recommended by NIS2 . MFA greatly reduces the risk of account compromise by adding an extra verification step. Manage user accounts and permissions through a centralized IAM system, ensuring that when employees change roles or leave, their access is promptly adjusted or revoked (de-provisioning). Use role-based access control (RBAC) so that users only have the permissions necessary for their job. Additionally, enforce strong password policies or, where possible, use modern authentication like single sign-on and certificate-based or passwordless methods to enhance security.

• Monitoring and Anomaly Detection for Access: Technical solutions like privileged access management (PAM) can monitor and control the use of admin-level accounts, providing session recording or just-in-time access to reduce abuse of high privileges. Similarly, user and entity behavior analytics (UEBA) tools can spot abnormal access patterns that might indicate a breach (tying into continuous monitoring, see section 3.5). NIS2’s risk management measures implicitly require detecting misuse of accounts (insider threats or stolen credentials).

• Data Minimization and Segregation: From a privacy perspective, store and retain only the data that is necessary for business operations. Although NIS2 mandates long log retention for security (18 months) , organizations should still apply techniques like masking or pseudonymizing personal data within logs when possible (so that logs used for security are less privacy-intrusive). Segment personal data from operational data; for example, keep customer personal information in a secure database separate from system telemetry. This way, security measures (like logging and monitoring) can focus on system events without unnecessarily exposing personal data.

• Integrity Protection: Use hashing and integrity-checking mechanisms to ensure data isn’t tampered with. For critical files or records, implement digital signatures or at least checksum comparisons so that unauthorized modifications can be detected. Some organizations deploy file integrity monitoring (FIM) tools on servers that alert if critical configuration or program files change unexpectedly (which could indicate malware).

• Regular Access Reviews: A procedural but important control is to conduct periodic reviews of user access rights to critical systems and data repositories. This ensures that any excess privileges are revoked and that dormant accounts are removed, reducing the attack surface.

By encrypting sensitive data, tightly controlling access to it, and minimizing unnecessary data collection/storage, companies not only comply with NIS2’s technical measures (cryptography, access control) but also uphold privacy laws. These measures significantly lower the risk of data breaches and limit the impact if a breach occurs (since encrypted or pseudonymized data is less useful to an attacker).

3.4 Incident Response Planning and Continuous Monitoring

Effective incident detection and response is at the heart of NIS2’s requirements. The directive expects organizations to have capabilities for incident handling and to rapidly react to minimize damage . In practice, this means putting in place both the technology for continuous threat monitoring and the processes for responding to incidents. Key solutions and practices include:

• Security Information and Event Management (SIEM): A SIEM or similar centralized log management and analysis system is crucial for continuous monitoring. These systems aggregate logs and security events from across the IT environment (firewalls, servers, endpoints, applications, etc.) and use correlation rules and analytics to identify signs of possible cyber incidents. As one expert notes, combining log management with SIEM enables “proactive detection of cyber threats, alerting on malicious patterns and anomalies, [and] centralized observability” across systems . SIEM alerts the security team in real time if suspicious behavior is detected (for example, a user logging in from an unusual location, or a spike in network traffic that could indicate data exfiltration). Under NIS2, having such detection mechanisms is essential to meet the early warning obligation and to catch incidents that preventive controls might miss .

• Intrusion Detection/Prevention Systems (IDS/IPS) and Endpoint Detection and Response (EDR): These specialized monitoring tools complement a SIEM. Network IDS/IPS sensors can inspect network traffic for malicious signatures or abnormal patterns, blocking attacks like exploits or malware downloads. EDR agents on endpoints (workstations, servers) monitor for suspicious processes or behaviors (e.g., a process attempting to encrypt many files, which might indicate ransomware). Deploying IDS/IPS and EDR enhances an organization’s ability to detect incidents at various points in the kill chain, feeding useful data into the central SIEM as well.

• Incident Response Plan and Team: Develop a formal Incident Response Plan (IRP) that defines the step-by-step procedures when a security incident occurs. This plan should outline incident triage, containment, eradication, recovery, and post-incident review steps. It must also include communication plans (who needs to be informed, including management and external authorities, and when). NIS2’s reporting clock (24 hours) starts once an organization is aware of an incident, so the IR plan should ensure that within that window the incident is assessed and the required information is gathered for notification. Organizations should designate an incident response team or coordinator (which could be internal, or an external incident response service provider if the company is small). Conduct training and periodic drills (simulated incidents) so that the team can practice the plan. Being well-prepared is critical since NIS2 expects swift and coordinated incident handling .

• Automated Alerting and Playbooks: Utilize automation where possible to speed up response. For example, if the SIEM detects a probable malware infection, it can trigger a SOAR (Security Orchestration, Automation, and Response) workflow to automatically isolate the affected host from the network, or to disable a compromised user account. While humans will make the final decisions, such automated playbooks can contain incidents faster, which is aligned with minimizing incident impact as NIS2 requires . Automated alerting ensures that the on-call responders are paged immediately when high-severity events occur, regardless of the time of day.

• Continuous Vulnerability Monitoring: Part of avoiding incidents is identifying weaknesses before attackers do. Implement continuous vulnerability scanning of systems and applications, and subscribe to threat intelligence feeds (or the NIS Cooperation Group alerts) to learn of new vulnerabilities. NIS2 includes vulnerability handling and disclosure processes as a required measure . So, a technical solution is to deploy a vulnerability management system that regularly scans for missing patches or misconfigurations and tracks remediation. Additionally, where feasible, engage in penetration testing or red-team exercises periodically to test defenses and response capabilities.

• Establishing Metrics and Reporting: Continuous monitoring extends to compliance monitoring. Use metrics such as mean time to detect (MTTD) and mean time to respond (MTTR) for incidents, number of detected intrusion attempts, system patch levels, etc., to gauge the effectiveness of your security operations. Tools can dashboard these metrics. NIS2 doesn’t explicitly mandate specific metrics, but having these will help in the continuous improvement of the security program. It also aids in reporting to executives and regulators that the organization is actively managing and improving its cyber defense posture.

By integrating these technologies and processes, companies can swiftly identify and contain threats – a necessity to meet the tight NIS2 reporting deadlines and limit damage. Centralized monitoring with SIEM and robust IR plans directly address NIS2’s requirements for incident handling . Indeed, without such capabilities, an organization would struggle to even know an incident occurred in time to report it. Moreover, the logs and data collected play a dual role: not only do they help in real-time defense, they also form the evidence for post-incident analysis and regulatory compliance.

3.5 Network Security and Segmentation

A strong network security architecture is another pillar of NIS2 compliance. The directive implies that organizations should secure their networks to prevent unauthorized access and contain incidents (though it’s not explicitly spelled as a separate item, it is inherent in points like access control and system security) . Best practices for network security and segmentation include:

• Network Segmentation: Divide your network into security zones and tightly control traffic between them. For example, isolate critical servers (production databases, industrial control systems, etc.) in a high-security zone that only specific services or users can reach, and separate them from the corporate IT network. By implementing internal firewalls or VLAN segmentation, even if one segment is breached, the attacker cannot easily move laterally to more sensitive areas. NIS2’s emphasis on limiting impact of incidents aligns with containing breaches via segmentation. In practice, define network segments such as: corporate user LAN, data center network, OT network, DMZ for external-facing services, etc., each with tailored security rules.

• Perimeter Defense and Zero Trust: Deploy next-generation firewalls at key network chokepoints to filter traffic based on IP, port, and content. Use intrusion prevention features to block known malicious patterns. However, traditional perimeter security is not sufficient on its own (especially with remote work and cloud services). Embracing a Zero Trust model – which treats every network connection as untrusted – can greatly enhance security. This means requiring authentication and authorization for every lateral movement (implementing Network Access Control (NAC) and software-defined perimeters). Essentially, no user or system should be able to access a resource just because they are “inside” the network. This approach was not explicitly stated in NIS2 but is a modern best practice to satisfy its goals of preventing unauthorized access and breaches.

• Secure Remote Access: Many sectors rely on remote connectivity (for maintenance of systems, remote work, etc.). Use secure VPNs with MFA for remote access into internal networks. Even better, consider software-defined perimeter (SDP) solutions that hide applications from the internet and require device posture checks before granting access. Limit remote desktop protocols and similar services unless absolutely needed, and monitor them closely. NIS2 came at a time when remote work surged, so ensuring remote access is locked down is critical.

• Network Monitoring and Anomaly Detection: As part of continuous monitoring (section 3.4), ensure you have network-level visibility. Use tools like network traffic analysis (NTA) or anomaly detection systems that can create a baseline of normal network behavior and alert on deviations. For example, a sudden large data transfer from a server to an external site might indicate data exfiltration – detecting this quickly allows a response before too much damage is done. These tools complement host-based monitoring and align with the requirement to detect incidents promptly.

• Secure Network Device Management: Ensure that the network infrastructure itself (routers, switches, firewalls) is securely configured. Use dedicated management networks or channels for device administration, with strong authentication. Keep device firmware updated (network gear can have vulnerabilities too), and restrict who can access network device consoles. Apply access control lists (ACLs) to limit which systems can talk to critical servers. For Wi-Fi networks, use strong encryption (WPA3) and isolate guests from internal resources.

• Segmentation in OT/ICS: For organizations in sectors like energy, manufacturing, or transport that have Operational Technology (industrial control systems), segmentation is vital to protect safety-critical systems. Follow the ISA/IEC 62443 or similar guidelines to segment the OT network from the enterprise IT network, with only a minimal and monitored interface between them if needed. This prevents general malware from spilling into factory floors or power grid controls. NIS2’s inclusion of these sectors means these legacy OT systems must be considered in the security architecture.

By securing network boundaries and internal connections, companies reduce the risk that an attacker can penetrate and roam freely. For example, if a phishing email leads to an endpoint compromise, a segmented network might prevent that compromised machine from accessing crown jewel servers. NordLayer summarizes such best practices as “dividing networks into secure zones, restricting unauthorized access, and managing remote connections” . These measures directly support NIS2’s requirement for access controls and system security throughout the lifecycle , and they create a more robust environment that can fend off attacks or at least confine them to a small blast radius.

3.6 Secure Supply Chain Management

Recognizing that an organization’s security is only as strong as the weakest link in its supply chain, NIS2 puts new emphasis on secure supply chain management . This means entities must address cybersecurity not just within their own walls, but also consider the security of suppliers, service providers, and software vendors. Key practices and solutions include:

• Supplier Security Assessment: Develop a process to evaluate the cybersecurity posture of suppliers and partners. For critical suppliers (those whose compromise could disrupt your operations or lead to a security breach), conduct due diligence. This can involve questionnaires, requesting audit certifications (like ISO 27001 or SOC 2), or even on-site assessments. NIS2 requires taking into account the specific vulnerabilities of each direct supplier and the quality of their cybersecurity practices . For example, if you rely on a cloud service provider, you should ensure they have robust security controls and incident response capabilities of their own. Some organizations implement a vendor risk management tool to track supplier compliance and risk scores, and mandate minimum security requirements in contracts.

• Supply Chain Security Policies: Establish policies governing procurement and use of third-party components. This might include guidelines like: preferring vendors with certain security certifications, requiring software vendors to follow secure development practices, and avoiding or closely scrutinizing vendors from high-risk regions (similar to how some governments treat telecom equipment, for instance). The policy should also cover open-source software usage – ensuring that open-source components are vetted and kept updated, since they are part of the software supply chain.

• Secure Development and Procurement: For internally developed software or when commissioning software, integrate supply chain considerations by using trusted libraries and dependencies. Employ tools for software composition analysis (SCA) to detect vulnerable third-party libraries in your applications. Additionally, maintain an inventory (bill of materials) of software components and their versions, to quickly identify if a new vulnerability (like Log4Shell) affects your systems. NIS2’s supply chain measure (Article 21(d)) ties in with vulnerability disclosure as well – organizations should have a way to be informed by suppliers about vulnerabilities (and vice versa, share info with them). Encourage your suppliers to have a vulnerability disclosure program or join information-sharing communities.

• Contractual Clauses and Collaboration: Use contracts to enforce security: include clauses that require suppliers to adhere to certain cybersecurity standards, report incidents to you promptly, and even allow audits or evidence of compliance. Under NIS2, essential entities will likely flow down some incident notification requirements to their providers. Also establish communication channels with key providers – know who to contact in case you detect a breach that might involve them or if they need to alert you. Supply chain security is a two-way street of information sharing, which is something NIS2’s cooperation mechanisms promote.

• Monitoring Third-Party Services: When using third-party services (like SaaS or cloud), configure security monitoring on those as well. Many cloud services offer logs and alerts (e.g., CloudTrail for AWS, or CASB solutions for SaaS apps) – integrate those into your central monitoring so that an attack through a third-party service is not missed. For instance, if an attacker breaches a managed service provider that has access to your network, you want to detect any abnormal activity coming through that channel.

By actively managing supply chain risk, companies adhere to NIS2’s expanded scope of cybersecurity risk management beyond the enterprise boundary. In practice, this could mean, for example, discovering that a small IT support contractor has weak security – under NIS2, you would work with that contractor to improve their practices or limit their access until they do (because a single compromised contractor could be a stepping stone into a hospital or bank’s core network). The directive essentially pushes organizations to “assess the vulnerabilities specific to each supplier and consider their cybersecurity quality” . Implementing these measures reduces the likelihood that an attacker can exploit trust relationships in the supply chain to bypass your defenses.

3.7 Logging and Audit Trail Management

Proper logging and audit trail management is crucial for both detecting incidents and demonstrating compliance with NIS2. The directive compels organizations to log relevant security events and maintain their integrity for analysis and reporting . Technical solutions and practices in this domain include:

• Centralized Log Management: Deploy a centralized log management system (often part of a SIEM, as discussed) to collect logs from all critical systems, network devices, security tools, and applications. Centralization ensures logs are in one place for correlation and makes it easier to secure and back them up. According to NIS2, logs from all systems and IT infrastructure should be stored in an unalterable form for at least 18 months . Achieving immutability can be done by writing logs to append-only storage or using cloud logging services that support write-once retention policies. Systems like Elasticsearch with auditing, or WORM (Write-Once-Read-Many) storage appliances, can enforce that logs cannot be modified or deleted prematurely.

• Log Integrity and Access Control: Treat log data as sensitive – it should be protected from tampering and unauthorized access. Use hashing or digital signing of log records to detect any changes. Limit access to logs to a small number of analysts or administrators, and use audit logs to record if someone reads or exports logs (preventing illicit use). This ensures compliance with both NIS2 and privacy requirements (logs often contain personal data like user IDs or IP addresses, so access should be on a need-to-know basis).

• Comprehensive Audit Trails: Ensure that key activities are logged with sufficient detail. This includes: authentication attempts (successful and failed), privilege use (e.g., when an admin account is used or when roles are changed), data access events for sensitive data, configuration changes on systems, and of course any security alerts or events. As part of compliance, organizations might face security audits or inspections by authorities . Having complete logs will be crucial to demonstrate what happened before, during, and after an incident. For example, log records should show the timeline of an incident: when it started (e.g., time of initial compromise, which could be inferred from system logs), how it was detected, what actions were taken, and when it was resolved .

• Meeting Reporting Requirements: Because NIS2 imposes tight reporting deadlines, logging systems should facilitate quick retrieval of relevant information. In practice, this means your log management solution should support fast search and analysis, so that within hours of detecting an incident you can extract details like the affected systems, the nature of the attack, and the initial impact. Effective log management “ensures the storage of logs about activities across the IT environment, thus helping to cover the reporting and auditing obligations required by NIS2” . It also provides the data needed for forensic investigation after an incident, which will feed into the final incident report required within one month.

• Retention Policies and Compliance: Set your log retention policy to at least 18 months (or longer if national transposition requires). But also consider other regulations – for example, GDPR might not allow indefinite retention of user-related logs unless justified by security. The 18-month mandate is a balance to ensure logs exist for incident investigation even if an incident is discovered long after it occurred. Make sure to also archive logs securely (perhaps in cold storage or a secure cloud archive) once they are no longer actively used, and have a method to restore archived logs if needed for an audit or historical analysis.

• Audit Logging of Non-IT Systems: If you are in an industry with operational technology (like SCADA systems in utilities or medical devices in healthcare), ensure those systems produce audit logs too. You may need special connectors or agents to pull logs from proprietary equipment. Even physical security systems (badges, facility access) can provide useful logs during an incident (e.g., correlating a cyber incident with a physical entry can reveal insider threats).

By mastering log management, an organization strengthens its security posture and is well-prepared to comply with NIS2’s oversight. Comprehensive and well-preserved logs serve as the memory of all significant actions in the network and are indispensable for incident response and compliance demonstration. In fact, centralized log management and SIEM are often highlighted as key enablers of NIS2 compliance, since they provide the evidence for detection and the details needed for regulatory reports . In summary, logging is not just a technical formality – it’s a strategic tool for both security and accountability under NIS2.

4. Methodologies for Assessing NIS2 Compliance in Companies

Achieving NIS2 compliance is not a one-time project but an ongoing process. Companies should start by assessing their current cybersecurity posture against NIS2 requirements, then address any gaps, and continually monitor their compliance. Here we outline methodologies and steps for assessing and maintaining NIS2 compliance:

1. Conduct a Compliance Audit and Gap Analysis: Begin with an internal audit of your existing security controls and policies in relation to NIS2. This involves reviewing how your current practices stack up against each obligation in the directive. Many organizations struggle at this initial stage because it requires a holistic evaluation of IT governance and security measures . A systematic approach is to create a checklist or use a framework mapping NIS2 requirements to controls (for example, using the list of measures in Article 21 as a reference). Identify where you meet the requirement, partially meet it, or not meet it at all. Common checkpoints include: do you have an incident response plan? Is multi-factor authentication in place? Are backups tested? Document these findings as the “current state.” The gap analysis will highlight areas of non-compliance – those are the gaps that need remediation. For accuracy, it often helps to involve multiple stakeholders (IT, security, compliance, operations) and, if possible, use external experts or established tools/questionnaires to ensure you’re interpreting NIS2 correctly. The output should be a report or matrix showing each NIS2 control area and whether the company is compliant, partially compliant, or non-compliant.

2. Perform Risk Assessment and Prioritize Risks: Alongside the gap analysis, perform a cybersecurity risk assessment focusing on the gaps identified. Not all gaps carry equal risk; for example, lacking an incident response plan is critical, whereas a minor shortfall in documentation might be less urgent. NIS2 expects a risk-based approach, so evaluate the likelihood and impact of non-compliance in each area. For instance, if you have no intrusion detection, how likely is a breach to go unnoticed and what impact could that have? This assessment helps in prioritizing which compliance gaps to fix first based on risk severity. Many organizations integrate this with existing enterprise risk management frameworks. The risk assessment also ensures that any additional controls you plan to implement are appropriate to your specific threats and business context (avoiding a purely box-ticking exercise). A good practice is to align this with NIS2’s requirement of proportional measures “appropriate to the risks posed” .

3. Define an Action Plan for Remediation: Using the results of the gap analysis and risk assessment, develop a remediation roadmap. This is essentially a project plan to achieve compliance. It should list the required actions (e.g., “Implement centralized log management”, “Draft an incident reporting procedure”, “Conduct employee awareness training”), assign ownership to specific teams or individuals, and set deadlines. Prioritize actions that close high-risk gaps or those that are fundamental to compliance. For example, if incident reporting is completely absent, that might be a top priority because it’s a legal obligation. Some actions might be quick wins (enabling MFA on all accounts), while others are longer projects (deploying a new backup solution). Ensure to include policy and documentation tasks as well, not just technical fixes – NIS2 compliance will be judged not only on what technology is in place but also on having proper documentation (policies, incident report templates, etc.). At this stage, management support is crucial because some remediation may require budget or process changes. A clear action plan with executive buy-in helps coordinate efforts across the organization.

4. Execute and Track Remediation Efforts: Implement the changes according to the plan. It may involve purchasing tools (like a SIEM or backup system), configuring systems (segmenting networks, setting up logging), creating documents (policies, procedures), and training staff. As you execute, track progress and maintain documentation of changes. It’s useful to keep an evidence folder for compliance – e.g., copies of new policies, screenshots of security settings, records of training sessions – so that you can easily show auditors or regulators what has been done. If obstacles arise (for example, a planned measure isn’t feasible on a legacy system), update the plan with alternative solutions or compensating controls. Regular project meetings or reports on NIS2 readiness can help ensure momentum. Many companies treat this like preparing for a certification audit, where each control is verified.

5. Compliance Auditing and Testing: Once you believe all major gaps are addressed, conduct a compliance audit or test. This can be an internal audit or a dry-run assessment mimicking what a regulator might check. It could also be a third-party audit by consultants familiar with NIS2. The goal is to verify that the implemented measures are effective and meet the requirements. For example, test that an incident alert actually triggers the internal escalation as per your procedure, or simulate an authority notification to ensure you can gather required info quickly. If any requirements were missed or if implementations are found lacking, treat those as new gaps to fix. This phase gives confidence that the organization can formally attest to being compliant.

6. Continuous Monitoring and Compliance Management: Compliance is not a one-off state; it requires ongoing monitoring and improvement. NIS2 will be an evolving directive (with potential updates, and certainly evolving threats). Establish a process for continuous compliance monitoring: assign a person or team (such as a compliance officer or CISO) to oversee NIS2 compliance efforts regularly. Use Key Performance Indicators (KPIs) or metrics to track compliance posture – for example, percentage of staff that completed security training, number of incidents reported within the required time, time taken to apply critical patches, etc. Regularly review these and ensure they meet set targets. It is recommended to incorporate NIS2 compliance checks into your existing governance, risk, and compliance (GRC) program or tools if you have them. As one guide suggests, “continuously monitor compliance efforts using key performance indicators and conduct regular reviews to ensure effectiveness of implemented measures” . Additionally, keep an eye on updates: since Member States may refine certain obligations (e.g., specific reporting mechanisms or additional guidelines), staying informed through the NIS Cooperation Group publications or national cybersecurity agency advisories is important.

7. Periodic Re-assessment and Updates: At least annually (if not more often), repeat a scaled-down version of the compliance assessment. Business changes (new IT systems, new partnerships, etc.) might introduce new compliance challenges. Also, lessons learned from any incidents or near-misses should feed back into improving controls – this embodies the continuous improvement principle. Document any changes in your compliance scope (for instance, if your company grows and now qualifies as a large entity whereas before it was medium, ensure you meet any stricter expectations that might accompany that). Moreover, be prepared for external audits or inspections. Competent authorities under NIS2 may conduct audits or request evidence of compliance, especially for essential entities . Having gone through internal assessments will make these external evaluations much smoother.

In summary, assessing NIS2 compliance is an iterative process: assess -> gap analysis -> remediate -> monitor -> repeat. By following a structured auditing framework and risk-based gap analysis, companies can systematically move towards full compliance. Importantly, these steps should be integrated into organizational processes – for instance, any new project or system deployment should include a NIS2 compliance check as part of its rollout. This way, compliance becomes a continuous discipline rather than a scramble at the end of a deadline.

5. Comparison of NIS2 and ISO 27001

NIS2 and ISO/IEC 27001 are both frameworks aimed at improving information security, but they differ in nature and scope. Understanding their alignment and differences can help companies leverage existing ISO 27001 certifications to meet NIS2 obligations and integrate both into a cohesive strategy.

Alignment and Overlap: There is a strong alignment between NIS2 requirements and the controls in ISO 27001 (especially the updated ISO 27001:2022 and its reference controls in ISO 27002:2022). Both emphasize a risk management approach, requiring organizations to identify risks and implement appropriate controls. Many of the specific measures in NIS2 (Article 21’s list) have direct counterparts in ISO 27001’s Annex A controls. For example, ISO 27001 mandates access control, cryptography, operational security, secure development, supplier security, incident management, business continuity, and compliance – all of which map to NIS2 measures. Because of this, achieving ISO 27001 certification puts a company well on the way to NIS2 compliance. In fact, experts estimate that ISO 27001 covers about 70% of NIS2 requirements . The core philosophy of continuous improvement (Plan-Do-Check-Act cycle in ISO) also complements NIS2’s expectation of ongoing risk management and updating of measures .

Key Differences: Despite the overlap, there are important differences between NIS2 and ISO 27001:

• Legal Mandate vs. Voluntary Standard: NIS2 is an EU law (Directive) that imposes mandatory requirements on in-scope entities, enforced by national authorities with potential penalties for non-compliance. ISO 27001, on the other hand, is a voluntary international standard – organizations choose to adopt and certify against it mainly for best practice or customer assurance. ISO 27001 by itself does not carry legal penalties for non-adoption. As one source puts it, “ISO 27001 does not require legal compliance; however, NIS2 imposes specific legal obligations on organizations…” . This means under NIS2, compliance is not optional and is subject to regulatory oversight.

• Scope of Applicability: ISO 27001 is generic and can apply to any organization, of any size, in any industry – it’s up to the organization to define the scope of its ISMS (Information Security Management System). NIS2, conversely, targets specific sectors and sizes (medium and large enterprises in critical sectors, plus some smaller ones if criticality is high). So NIS2 might not apply to a small tech startup, whereas ISO 27001 could if that startup chose to implement it. Also, ISO allows an organization to exclude parts of its business from the scope of certification, whereas NIS2 covers the entity’s relevant systems for providing essential services as defined by law (one cannot simply scope out certain systems from compliance if they are part of delivering the service).

• Incident Reporting Obligations: One of the starkest differences is that NIS2 includes external incident reporting requirements to authorities (and possibly to service users or other stakeholders), with defined timelines (24 hours, etc.) . ISO 27001 does require incident management internally, but it does not mandate reporting incidents to regulators or the public. A comparison notes: “NIS2 includes incident reporting requirements to relevant authorities, while ISO 27001 does not have a mandatory reporting element” . This means an organization could be fully ISO 27001 compliant and still not meet NIS2 if it hasn’t set up procedures to report incidents to the national CSIRT/authority as NIS2 demands. Companies should augment their ISO-aligned incident response processes with this reporting step when in NIS2 scope.

• Governance and Accountability: NIS2 explicitly holds top management accountable and requires a level of board oversight that ISO 27001 only implies. ISO 27001 does call for management commitment, but NIS2 goes further by threatening penalties or disqualifications for managers in case of serious non-compliance . In practice, this difference means NIS2 might drive more direct involvement from executives than an ISO project might, because of the personal liability aspect.

• Certification vs. Regulatory Compliance: ISO 27001 leads to a certification issued by accredited bodies, which is a form of third-party assurance usually valid for 3 years (with surveillance audits). NIS2 compliance, however, is not “certified” in the same way; it’s a continuous obligation and might be verified through regulatory audits, reporting, or if an incident occurs. Being ISO 27001 certified can serve as evidence of serious cybersecurity posture, but authorities may still scrutinize specific NIS2 aspects that ISO audits might not emphasize (like timely incident notification, or specific national requirements from NIS2 transposition).

• Content Focus Differences: There are a few areas NIS2 touches that ISO 27001 historically did not emphasize as much. For example, NIS2’s focus on supply chain security and vulnerability disclosure has become more prominent recently. The latest ISO 27002:2022 does include controls for ICT supply chain security and secure development, so the gap is closing. Another example is secure communications for emergency (NIS2 mentions secured voice/video communications for crisis situations ), which is quite specific and not explicitly covered by ISO controls except in a broad sense. However, these differences are relatively minor and can be bridged with a few additional controls or procedures on top of ISO.

Leveraging ISO 27001 for NIS2 Compliance: For companies already certified or following ISO 27001, leveraging that foundation is a smart strategy. ISO 27001 provides a well-documented set of controls and an auditable trail of implementation – this can be shown to regulators to demonstrate a proactive security stance. As DataGuard experts noted, obtaining ISO 27001 certification is “an excellent first step towards NIS2 compliance” covering about 70% of requirements . To leverage ISO, companies should:

• Map ISO 27001 controls to NIS2 requirements to identify what is already covered and what needs additional work . For instance, ISO requires incident response planning (A.17 in ISO 27002:2013, or new reference in 2022 version), which aligns with NIS2, but ISO doesn’t require notifying a government entity – so that piece would be an add-on procedure.

• Use ISO’s documentation (risk assessment reports, Statement of Applicability, policies, training records) as evidence for NIS2 compliance. In case of an audit or inquiry, having these ready can simplify demonstrating compliance.

• Leverage the continuous improvement process from ISO. NIS2 compliance will benefit from the ISMS cycle of regular internal audits and management reviews. The issues raised in those internal audits can be cross-checked with NIS2 obligations to ensure nothing is missed.

Integration Strategies for Both Frameworks: Companies aiming to comply with NIS2 and possibly get ISO 27001 certified (or maintain certification) can integrate the efforts by:

• Unified Risk Management: Perform one unified risk assessment that satisfies ISO’s requirements and feeds into NIS2’s risk-based measures. Avoid doing parallel processes.

• Single Set of Policies and Controls: Develop security policies that reference both frameworks. For example, an incident management policy can state compliance with ISO standards and include the 24-hour notification workflow for NIS2 – thus one document covers both needs.

• Audit and Certification Timing: Some organizations might schedule their ISO 27001 audits to precede key NIS2 deadlines. The ISO audit findings can be used to fix any gaps before regulators potentially review them. Also, achieving ISO 27001 certification can be communicated to regulators as part of compliance status.

• Leverage overlap with other regulations: If an organization is in a sector with other regulations (like the financial sector has DORA in the EU, or others have GDPR for breach notifications), coordinate the compliance work. ISO 27001 often serves as a superset that can address multiple regulatory requirements at once when tailored properly.

In essence, ISO 27001 provides the management system and broad control set, while NIS2 provides specific targets and legal impetus. When used together, they can reinforce each other – ISO brings maturity and structure, NIS2 brings focus and mandatory enforcement. Many businesses find that aligning with ISO 27001 greatly simplifies NIS2 compliance, leaving only a few delta requirements (like external reporting and perhaps some sector-specific nuances) to address separately . Conversely, for an organization starting due to NIS2, pursuing ISO 27001 certification as part of the compliance journey can be beneficial, as it provides an external validation of their security program and can increase trust with clients and partners.

6. Specific Measures for NIS2 Compliance

Beyond broad strategies and frameworks, companies should implement specific measures that are explicitly or implicitly required by NIS2. These measures ensure the practical fulfillment of the directive’s provisions. Below are key specific measures, along with their justification under NIS2 and best-practice recommendations:

• Data Protection and Backup Requirements: NIS2 mandates robust measures for data security and availability. This includes using encryption to protect data and managing backups for continuity . Companies should encrypt sensitive data both at rest and in transit (e.g., using TLS for communications and disk/database encryption) to prevent unauthorized access or data breaches. At the same time, they must maintain regular, secure backups of critical systems and databases, stored offline or in an immutable format. The directive explicitly calls for “business continuity” measures such as backup management and disaster recovery planning . To comply, organizations should ensure backups are performed frequently, tested for restorability, and stored for a sufficient period. Encrypting backup data and protecting backup repositories (with access control and offline copies) is also essential so that backups themselves are not compromised if attackers strike. In practice, this measure means having a documented backup policy (specifying backup frequency, retention period, storage location) and using reliable backup solutions that support encryption and immutability.

• Secure Authentication and Identity Management: Strong authentication is a critical requirement under NIS2’s risk management measures. The directive specifically highlights the use of multi-factor authentication (MFA) or continuous authentication for access, as well as secure communication systems . Companies should enforce MFA for all users who access sensitive systems or remotely access the network. This could involve SMS/email one-time codes, authenticator apps, hardware tokens, or biometric factors in addition to passwords. Additionally, implement an identity and access management system to centrally control user accounts and permissions, ensuring least privilege access. Include measures like account lockout policies (to mitigate brute-force attacks) and regular password changes or password complexity requirements if password-based auth is used. Furthermore, monitor user logins and access logs to quickly detect suspicious login attempts (tying into logging and monitoring). For privileged or administrative accounts, consider even stricter controls such as privileged access workstations and session recording. These steps satisfy NIS2’s call for strong access control and authentication policies to prevent unauthorized system access . Secure identity management also means promptly removing or adjusting access when an employee leaves or changes role, to avoid accumulation of unnecessary privileges.

• Secure Development and Vulnerability Management: NIS2 places importance on security in system development and the handling of vulnerabilities . Organizations should integrate security into their software development lifecycle (SDLC) – often referred to as DevSecOps. This includes performing threat modeling and code reviews, using static and dynamic application security testing (SAST/DAST) tools to catch vulnerabilities in code, and deploying updates through secure pipelines. Establish a process for vulnerability management: keep all software and systems updated with security patches (especially critical patches should be applied within a defined short timeframe). Maintain an inventory of assets and their software versions so you can track what needs updating. NIS2 also refers to vulnerability disclosure, so companies should have a vulnerability disclosure policy (VDP) or participate in information-sharing mechanisms, allowing security researchers or partners to report flaws responsibly. Additionally, employing penetration testing periodically can help uncover weaknesses in a controlled manner. For existing systems (including COTS software and operating systems), use vulnerability scanning tools regularly and remediate findings according to a risk-based priority (critical vulnerabilities possibly within 2 weeks, medium within a month, etc., as a guideline). By systematically managing vulnerabilities and applying secure development practices, an organization fulfills the NIS2 requirement to address “security in network and information systems acquisition, development and maintenance, including vulnerability handling and disclosure” . This measure is crucial to reducing the attack surface and preventing known exploits from being effective.

• Business Continuity Planning under NIS2: Beyond backups, NIS2 requires organizations to ensure operational continuity in the face of incidents (point (c) of Article 21 covers business continuity and crisis management) . A specific measure here is to develop a Business Continuity Plan (BCP) and Disaster Recovery Plan (DRP) that account for cyber incidents. This involves identifying critical business processes and figuring out how to keep them running during different scenarios (e.g., ransomware causing IT outage, DDoS attack on online services, etc.). Companies should conduct a Business Impact Analysis (BIA) to determine priorities for recovery. The BCP should include manual workarounds or alternative procedures if IT systems are down (especially important in sectors like healthcare or transport to avoid safety risks). The DRP, on the other hand, deals with restoring IT infrastructure – aligning with the backup strategies discussed earlier. Under NIS2, it’s also important to incorporate crisis communication in these plans – how to communicate with employees, customers, partners, and authorities during a major cyber crisis. The directive highlights having “secured emergency communication systems” where appropriate , which could mean out-of-band communication methods (like an alternate email or phone tree if corporate email is compromised). Testing the BCP/DR plans via drills or tabletop exercises is another measure to ensure readiness. Ultimately, an organization should be able to demonstrate that if a significant incident occurs, they have predetermined steps to continue serving customers and a timeline for recovery – meeting the NIS2 objective of minimizing impact on service recipients .

• Reporting Obligations and Legal Responsibilities: NIS2 introduces strict incident reporting obligations and holds leadership legally responsible for compliance. Companies must put in place processes to meet these obligations. Specifically, create an incident notification procedure that details how to report to the relevant national authority or CSIRT within the required time frames (at least an initial report in 24 hours, intermediate report in 72 hours, and final report in 1 month) . This procedure should define what constitutes a reportable “significant incident” as per NIS2 criteria (typically incidents causing substantial service impact or financial loss) and include templates or forms to capture the necessary information (e.g., nature of incident, suspected cause, mitigation steps taken, impact assessment). Responsible persons should be designated – for example, the CISO or an incident response manager might be tasked with submitting the official reports. These reports should be comprehensive and honest, as regulators will expect follow-up and could investigate if details are insufficient.

In addition, organizations must acknowledge the legal responsibility of top management in NIS2 compliance. A concrete measure is to formally assign a NIS2 accountable officer or team at the executive level. Many companies are appointing a security compliance officer or expanding the role of the CISO to report directly to the board about NIS2 compliance status. Boards of directors should be briefed on NIS2 obligations, and minutes of such meetings should reflect their involvement. This could protect against personal liability by showing due diligence. Some Member State laws may even require naming a specific person as the NIS2 point of contact. Regardless, internal governance should be updated so that cybersecurity is a regular agenda item at high-level meetings. Training or awareness for management about what NIS2 entails is also a good step.

Finally, update incident response policies to include external reporting and align with any national guidelines. If multiple regulations apply (for instance, GDPR has personal data breach notifications within 72 hours to data protection authorities, which might overlap with a NIS2 incident if personal data is involved), streamline the process to handle both in one go to avoid confusion. Ensuring these reporting and accountability measures are in place will help avoid the hefty fines and sanctions that NIS2 allows. It also fosters a culture of transparency and responsibility. When an incident occurs, rather than a panicked scramble, the organization can calmly follow its predefined communication plan – notifying authorities, informing stakeholders as necessary, and handling public disclosure if required – thereby fulfilling its legal duties and maintaining trust.

By focusing on these specific measures – data protection (confidentiality), backups (availability), strong auth (integrity of access), secure development (integrity of systems), continuity planning (availability), and clear reporting/accountability (governance) – companies cover the practical aspects of NIS2 compliance. Each measure translates the high-level directive requirements into tangible actions and controls that can be implemented and audited. Adopting these not only ensures compliance but also substantially improves the organization’s overall cybersecurity robustness.

7. Conclusion

The NIS2 directive raises the cybersecurity bar for a wide range of industries, ushering in a new era of enhanced accountability and resilience across the EU. In this paper, we discussed the objectives and scope of NIS2, the challenges organizations may face in achieving compliance, and detailed technical solutions and best practices to meet its requirements. To summarize the best practices and immediate steps companies should consider:

• Elevate Cybersecurity to a Strategic Priority: Ensure that top management understands their role in NIS2 compliance and actively supports cybersecurity initiatives. A culture of security, from the boardroom to every employee, is crucial. Conduct awareness training at all levels – from executives (on governance and legal obligations) to staff (on cyber hygiene and incident reporting).

• Perform a NIS2 Gap Analysis and Risk Assessment Right Away: If not already done, evaluate your current state versus NIS2 requirements . Identify gaps in areas like incident response plans, logging, backup, etc. Use this to formulate a prioritized remediation roadmap. Many organizations have found it useful to align this with ISO 27001 or other frameworks to structure the effort. Address high-risk gaps immediately – for example, if you lack MFA or have unmonitored systems, deploy those controls as a matter of urgency.

• Implement Key Technical Controls and Policies: Focus on the core controls that NIS2 expects: enable multi-factor authentication for users , encrypt sensitive data , segment your networks, set up centralized logging and monitoring, and harden your systems by applying patches and secure configurations. Develop or update policies for incident response, access control, and acceptable use to clearly outline procedures and expectations. Introduce an incident response playbook and test it with drills so that your team is prepared to handle a real incident within NIS2’s timelines.

• Establish Robust Backup, Recovery, and Continuity Plans: Make sure you have reliable backups of critical data and that you can restore them quickly in an emergency . Document and test disaster recovery plans, and ensure business continuity strategies are in place for critical functions. These steps will not only comply with NIS2 but also mitigate the impact of ransomware or other destructive attacks that are rampant today.

• Engage in Continuous Monitoring and Improvement: Treat compliance as an ongoing process. Set up a compliance monitoring function or integrate it into your ISMS. Continuously track security events, and regularly review your posture against new threats and any updated guidance from regulators or the NIS Cooperation Group. Use audits (internal or external) to validate your readiness. Also, be sure to maintain the mandated log retention (18+ months) and document evidence of all your compliance efforts – this will be vital if you ever need to demonstrate your diligence to authorities .

• Leverage Frameworks and Certifications: Use established standards like ISO 27001 to streamline compliance work. As discussed, ISO certification can cover a majority of NIS2 requirements . If you already have it, map out the remaining gaps (like incident reporting procedures) and fill them. If you don’t, consider working towards it as part of your long-term strategy, since it will provide structure and can serve as evidence of a serious security program. Additionally, follow guidance from ENISA and national cybersecurity agencies; they often publish templates, tools, or sector-specific advice for NIS2.

Implementing NIS2 is certainly challenging, but it is also an opportunity. By complying, companies inherently bolster their cybersecurity defenses, which reduces the likelihood of devastating breaches. NIS2 essentially forces organizations to adopt “security best practices” that many should arguably have had anyway – such as good backups, incident response plans, and network segmentation. Those who proactively adapt will not only avoid penalties but also reap benefits like improved system uptime, customer trust, and potentially lower cyber insurance premiums.

Future Implications: NIS2 is part of a broader trend of increasing regulatory focus on cybersecurity. We can expect regulators to issue more detailed guidance and possibly even technical standards (as allowed by NIS2 for certain sectors ) in the coming years. Additionally, other EU initiatives like the Cyber Resilience Act (addressing product security) and DORA (for financial sector resilience) complement NIS2. This indicates that the bar will continue to rise – companies will need to integrate cybersecurity into every aspect of their operations and supply chain. Organizations should stay agile and keep an eye on these developments. Building a strong security foundation now will make adapting to future requirements easier.

In conclusion, NIS2 compliance is not just a box-ticking exercise – it’s about adopting a comprehensive, risk-based approach to cybersecurity across all levels of the business. By following the best practices outlined – from implementing technical controls to establishing governance and continuous improvement loops – companies can achieve compliance in a practical way. This will not only satisfy the directive, but more importantly, it will significantly enhance the organization’s resilience against cyber threats in an increasingly digital and interconnected world. The effort put into NIS2 compliance is ultimately an investment in the stability and trustworthiness of one’s own services and the broader digital ecosystem of Europe .

By taking immediate steps to assess gaps, strengthening key defenses, and embedding security into corporate strategy, organizations will be well-equipped to meet NIS2’s challenges and protect the critical networks and information systems that society relies upon. Compliance is a journey – but with the right approach, it will lead to a safer and more secure operational environment for years to come.