Six Steps On The Road To NIS2 Compliance

Uploaded on 2024-10-01 in TECHNOLOGY--Resilience, FREE TO VIEW, BUSINESS-Services-Law

NIS 2 is the EU’s most stringent cybersecurity Directive to date, and member states have until 17th October to ratify it into national law. Every organisation striving for NIS 2 compliance will have its own journey based on its current cybersecurity maturity level, risk management, and what constitutes “appropriate and proportionate,”.

However, there are six common steps that can be applied across the board to help make the journey as smooth as possible, explains Martin Davies, Audit Alliance Manager at Drata.

Why The Revised Directive?

Before diving into our key steps, it’s worth asking how we got here and what has changed. The original NIS Directive has its flaws concerning a lack of specificity about who was affected and a lack of consistency in application across EU member states. NIS 2 is designed to clarify these issues and make the Directive more enforceable.

In more detailed terms, NIS 2 delivers more clearly defined governance and oversight, expanded scope, more stringent cybersecurity and risk management requirements, mandatory reporting requirements, tougher enforcement and penalties, cross-border information sharing, and vulnerability disclosure. As such, organisations will have their hands full trying to comply ahead of the 17th October date. We can make that process easier by laying out six steps to help prepare for NIS 2.

1. Understand The Scope
As with any new compliance plan, the first step is to wrap your head around its scope. This involves a comprehensive look at its sectoral coverage, the critical industries in-scope, and the obligations it imposes. It is worth noting that NIS 2 expands the sectors that fall under its regulations. The original NIS Directive focused on specific critical sectors like energy, transport, and finance. NIS 2 extends to a wider range of sectors, including healthcare, public administration, food, digital infrastructure, space, and postal services. It is also important to make the distinction between "essential" and "important" entities, as stricter supervisory activity will apply to essential entities, reflecting their critical role in maintaining societal functions.

2. Reach Out To Your Competent Authority
The extent of the impact of NIS 2 on your organisation will be decided by your Competent Authority, a designated body or organisation within an EU member state responsible for overseeing the implementation, enforcement, and compliance of the NIS 2 Directive. Member states may choose to have a single national authority or multiple sector-specific ones. As the primary interface between the government and affected entities, it is vital to establish communication lines early on to confirm your classification type, discover how to report incidents, and find out how to ask for clarification. Demonstrating early engagement is a quick win in terms of showing your commitment.

3. Complete A Gap Analysis
Now that you understand the requirements, it is time to explore where the gaps in your business lie:

Assess your current cybersecurity posture: review existing policies, evaluate technical controls and check compliance.

Map NIS 2 requirements to current frameworks and controls: create a requirements matrix and assess maturity levels.

Identify and categorise gaps: classify as high, medium or low priority based on factors like regulatory risk, business impact, and the potential for fines.

Develop a remediation plan: prioritise remediation activities, define specific actions and assign responsibilities.

4. Establish New & Updated Policies
This is one of the most important steps in making compliance a reality. Knowing where your gaps are and where your organisation stands is a great start, but it could still take many months to reach a point where you enjoy functional and compliant controls and governance. Deploy controls based on best practices, such as the ISO 27001 standard; document every aspect of the process so you show evidence of compliance to regulators and Competent Authorities; and seek clarification whenever necessary to keep on the right track.

5. Train Relevant Staff
NIS 2 will pull more and more personnel into its orbit, who may not have been previously involved with cybersecurity or compliance issues. Begin by customising training by role, setting learning objectives and developing the right content. Training can often feel like an extra burden for busy employees so try to incentivise the process to make it worthwhile. Training is also an ongoing process, so regular updates and refreshers are key to maintaining compliance and resilience.

6. Track Your Progress & Demonstrate Compliance
Organisations with an established cybersecurity and compliance programme probably already have an in-house system for tracking and auditing. However, if NIS 2 is your first major initiative, it is worth considering implementing a continuous compliance platform to design, implement, maintain, and evidence a fully NIS 2-compliant cybersecurity and risk management programme. It is not strictly necessary, but it will make tracking controls, policies and procedures much easier.

The advent of NIS 2 is daunting for companies of all sizes; however, following these simple steps will help reduce the stress and make your journey to compliance seamless.

Martin Davies is Audit Alliance Manager at Drata

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