The NIS2 Directive mandates that businesses and public authorities take responsibility for their cybersecurity by implementing both technical and organizational measures to address risks that threaten their systems. It also introduces stringent requirements for leadership accountability and supply chain security across regulated sectors.
Below, we outline the steps your organization needs to follow to ensure compliance. With the right mindset, NIS2 compliance becomes more than just a regulatory obligation—it’s an opportunity to assess current security measures and cultivate a robust security culture organization-wide.
NIS2 compliance starts at the top
Compliance with NIS2 begins with active leadership involvement. Cybersecurity must be embedded as a core element of your organization's strategy, with clear prioritization in operations and long-term goals. Leadership must proactively identify and mitigate risks, allocate necessary resources, and foster a culture where cybersecurity is integral to decision-making.
The directive emphasizes leadership accountability, with senior executives personally responsible for ensuring compliance. Failure to meet NIS2 requirements could lead to fines, disqualification from leadership roles, or, in severe cases, legal liability for individual board members.
Beyond leadership accountability, NIS2 outlines several technical and organizational requirements, including:
- Incident management
- Backup and crisis management
- Supply chain security
- Employee training
- Encryption policies
ALSO READ: NIS2 Compliance: What does the NIS2 directive require?
Risk assessment of critical assets
With leadership onboard, the first step is to identify the organization’s critical assets to conduct an effective risk assessment. Think broadly—consider data, processes, hardware, software, employees, and physical locations.
Once critical assets are identified, assess potential threats based on their likelihood and potential impact. Depending on the risk level, appropriate measures should be taken under the strategic direction of leadership to mitigate these threats.
Gap analysis and action plan
Following the risk assessment, perform a gap analysis to identify discrepancies between your current security measures and NIS2 requirements. This involves systematically comparing your organization’s controls and policies with the directive's demands. Key steps include:
- Identifying NIS2 requirements
- Mapping existing controls
- Comparing and identifying gaps
- Prioritizing gaps
- Developing an actionable plan
The action plan should align with a realistic security ambition, reflecting your organization’s risk profile, technological capacity, and specific challenges. Remember, a gap analysis is not a one-time task—it’s an ongoing process that should evolve with your organization’s risk landscape.
Integrating NIS2 into existing compliance efforts
Effective NIS2 implementation requires integrating its requirements into your existing compliance frameworks and processes. Many organizations already use frameworks like ISO 27001, CIS18, or GDPR, which can serve as a foundation for meeting NIS2 standards.
For instance, both NIS2 and GDPR mandate clear procedures for handling data breaches. By consolidating requirements into a unified incident management plan, you can ensure efficient compliance with both regulations.
Steps towards integrating NIS2
1) Mapping existing processes
Review and document your current information security and compliance measures, including policies, procedures, and controls.
2) Identifying overlaps
Pinpoint areas where NIS2 requirements align with existing frameworks, such as GDPR or CIS18, to maximize efficiency.
3) Adapting current frameworks
Leverage frameworks like ISO 27001 to guide the implementation of NIS2 requirements.
4) Implementing new controls
Address gaps with new measures, such as incident management procedures, supplier management, and regular risk assessments.
Embedding NIS2 into your culture
NIS2 compliance isn’t a one-time project—it’s a continuous process that must be integrated into your organization’s daily operations and culture. Beyond technical measures, it’s about fostering a mindset that prioritizes security across the board.
To make NIS2 a part of your culture, establish consistent procedures for risk assessment and incident management. This includes:
- Regular risk assessment cycles
Ensure all departments routinely evaluate their security measures and identify potential threats. - Incident response readiness
Train employees to quickly identify and respond to security incidents.
Employee awareness is critical to successful NIS2 implementation. Consider:
- Ongoing awareness programs
Move beyond standard e-learning modules with workshops and tailored training for specific departments. - Encouraging open dialogue
Promote a culture where employees feel safe reporting risks or concerns without fear of reprisal.
Additionally, as cyber threats evolve, so must your defense mechanisms. Stay proactive with:
- Regular testing and updates
Use penetration tests, audits, and policy reviews to ensure security measures remain effective. - Dynamic policy updates
Quickly adapt to changes in threat landscapes and regulatory requirements.
NIS2 isn’t just about compliance; it’s an opportunity to assess and improve your security measures, foster a strong security culture, and establish a cycle of continuous improvement. By embracing cybersecurity as a strategic priority, your organization can stay resilient in the face of evolving threats.