In a world where cyber threats are constantly evolving and becoming more complex, information system security has become a major concern for organizations. Faced with this reality, the European Union adopted the NIS 2 Directive (Network and Information Security 2) to strengthen cybersecurity across Europe. This new regulation, which replaces the 2016 NIS Directive, significantly expands its scope and imposes stricter obligations on covered entities. In this context, it is essential for businesses to understand the fundamental pillars of NIS 2 compliance to ensure their protection and avoid penalties. Much like GDPR compliance, a structured and methodical approach is required to meet the requirements of this directive.
Cybersecurity Governance: The Foundation of NIS 2 Compliance
Cybersecurity governance is the first essential pillar of NIS 2 compliance. It establishes the organizational framework needed to effectively deploy security measures within a company. This governance is built on several key elements that must be implemented to ensure effective compliance.
Direct Involvement of Management Bodies
The NIS 2 Directive explicitly requires that the management bodies of covered entities be directly involved in overseeing cybersecurity measures. This obligation marks a significant shift from the first version of the directive, as it places responsibility at the highest level of the organization. Specifically, board members and executives must:
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Approve cybersecurity policies
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Oversee their implementation
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Assume legal responsibility in case of non-compliance with the directive’s requirements
This top-level involvement ensures that cybersecurity is no longer seen as merely a technical issue but as a strategic priority for the organization. Companies that already outsource their DPO in Paris or other regions can draw inspiration from this approach for their NIS 2 compliance.
Staff Training and Awareness
Ongoing training for employees is another fundamental aspect of cybersecurity governance under NIS 2. The directive requires covered entities to implement tailored training programs for all staff members, including management. These programs should cover:
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Cyber risks the organization faces
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Best practices in cybersecurity
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Procedures to follow in case of an incident
Staff awareness is crucial, as studies show that human error remains one of the leading causes of security incidents. By investing in training, organizations strengthen their first line of defense against cyberattacks.
Establishing Robust Security Policies
NIS 2 requires the development and implementation of comprehensive security policies covering all of the organization’s information systems. These policies must be documented, regularly updated, and communicated to all employees. They should include:
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Clear rules for accessing information systems
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Procedures for managing information assets
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Mechanisms for controlling privileged access
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Processes for managing security updates
Formalizing these policies is essential evidence in case of audits by competent authorities, demonstrating the organization’s commitment to a structured approach to protecting its information systems.
Risk Management: A Systematic Approach to System Protection
The second pillar of NIS 2 compliance is cyber risk management. The directive requires covered entities to adopt a risk-based approach to determine and implement appropriate security measures. This methodology, similar to that required for conducting a data protection impact assessment (DPIA), ensures resources are allocated to the most significant risks first.
Risk Analysis and Assessment
The first step in this approach is to conduct a thorough and documented risk analysis. This analysis should identify:
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The organization’s critical assets (systems, data, infrastructure)
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Threats that could affect them
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Existing vulnerabilities
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Potential impacts of a security incident
This assessment must be conducted regularly and systematically, accounting for changes in the technological landscape and emerging threats. It forms the foundation of the organization’s cybersecurity strategy.
Implementing Appropriate Technical Measures
Based on the risk analysis, NIS 2 requires the implementation of technical security measures proportionate to the identified risks. These measures should cover various aspects of information system security, including:
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Network and IT system security
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Access and identity management
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Encryption of sensitive data
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Regular backups of critical data
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Detection solutions for security incidents
The directive does not prescribe specific technical solutions but requires that measures align with state-of-the-art practices and address each organization’s unique risks. This flexibility allows businesses to tailor their approach based on their size, sector, and risk exposure.
Supply Chain Security
A major innovation of NIS 2 is its emphasis on supply chain security. Organizations must now assess risks related to their suppliers and partners, particularly those with access to their information systems or providing critical services. This approach aligns with broader corporate ethics and responsibility.
Measures in this area may include:
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Incorporating security clauses in supplier contracts
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Regularly assessing the security levels of critical providers
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Implementing controls for third-party access to information systems
This dimension of risk management is especially important as supply chain attacks multiply, posing serious threats to many organizations.
Incident Reporting: A Strengthened Obligation
The third pillar of NIS 2 compliance concerns incident management and reporting. The directive significantly tightens organizations’ obligations in this area, with strict requirements on timelines and reporting content.
Early Detection of Incidents
The ability to quickly detect security incidents is a prerequisite for timely reporting. NIS 2 requires covered entities to implement effective detection systems capable of identifying significant incidents affecting their networks and information systems. These systems may include:
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Intrusion detection solutions
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Monitoring tools for suspicious activity
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Behavioral analysis tools to identify anomalies
Investing in these detection technologies is crucial for rapid response and minimizing potential impacts. This approach aligns with best practices recommended under DORA (Digital Operational Resilience Act) for the financial sector.
Reporting Timelines and Procedures
NIS 2 establishes a strict framework for reporting significant incidents to competent authorities. Covered entities must:
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Submit an early alert within 24 hours of becoming aware of a significant incident
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Provide an initial report within 72 hours, including a preliminary assessment
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Submit a final detailed report within one month of the incident
These tight deadlines require organizations to establish clear and efficient incident management procedures, with well-defined responsibilities and pre-established communication channels. For companies already using an external DPO in Lyon or elsewhere, coordination between the DPO and cybersecurity teams will be essential.
Stakeholder Communication
Beyond reporting to authorities, NIS 2 may also require, in some cases, notifying affected users of an incident. This communication must be:
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Clear and transparent
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Proportional to the incident’s severity
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Accompanied by recommendations on protective measures users can take
This aspect of incident management underscores the importance of a holistic crisis communication strategy involving all relevant stakeholders.
Practical Implementation of NIS 2 Compliance
Achieving compliance with the NIS 2 Directive is a significant challenge for many organizations. A methodical, step-by-step approach—leveraging best practices and available tools—is recommended for a successful transition.
Using Dedicated Tools and Solutions
To facilitate NIS 2 compliance, many organizations rely on dedicated technological solutions. These tools, similar to GDPR management software, automate aspects of compliance and maintain up-to-date documentation of implemented measures.
These solutions may cover:
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Mapping of information assets
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Cyber risk management
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Security incident tracking
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Compliance reporting
Investing in such tools can save considerable time and effort, especially for organizations with complex information systems.
The Importance of Audits and Continuous Improvement
NIS 2 compliance is not a one-time effort but an ongoing process. The directive requires organizations to implement regular audit mechanisms for their security measures, similar to GDPR audits already conducted by many businesses.
These audits should:
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Assess the effectiveness of implemented measures
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Identify gaps in meeting the directive’s requirements
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Implement corrective actions
Documenting these audits and improvement actions serves as critical evidence of the organization’s commitment to sustained compliance.
Leveraging External Expertise
Given the complexity of NIS 2 requirements, many organizations turn to external experts for compliance support. These professionals, akin to external DPOs for GDPR, can provide:
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In-depth knowledge of regulatory requirements
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Proven methodologies for compliance
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An external perspective on organizational practices
This approach is particularly valuable for organizations lacking in-house resources or expertise.
Synergies Between NIS 2 and Other Regulations
NIS 2 compliance should not be approached in isolation but as part of a broader regulatory framework. Significant synergies exist with other regulations, enabling organizations to optimize compliance efforts.
Links with GDPR
NIS 2 requirements align closely with the General Data Protection Regulation (GDPR). In both cases, organizations must:
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Adopt a risk-based approach
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Implement appropriate technical and organizational measures
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Report significant incidents to authorities
These similarities allow organizations already GDPR-compliant to build on existing measures. Companies with GDPR support in French Guiana or elsewhere can extend these efforts to meet NIS 2 requirements.
Alignment with Sector-Specific Regulations
Beyond GDPR, NIS 2 must also align with sector-specific cybersecurity regulations, such as DORA for finance or rules for critical infrastructure operators.
This alignment requires a comprehensive view of applicable regulatory obligations and effective coordination between compliance initiatives. An integrated approach avoids duplication and ensures consistency across implemented measures.
Conclusion: Toward a Strategic Approach to NIS 2 Compliance
The NIS 2 Directive represents a major evolution in the EU’s cybersecurity regulatory framework. By focusing on three core pillars—governance, risk management, and incident reporting—it aims to significantly enhance the cyber resilience of European organizations against increasingly sophisticated threats.
For covered entities, NIS 2 compliance should not be seen merely as a regulatory burden but as an opportunity to strengthen their security posture and protect their most valuable assets. A strategic, methodical approach—using best practices and available resources—can turn this obligation into a competitive advantage.
In this context, My Data Solution is a trusted partner to guide organizations through compliance, leveraging proven expertise in related areas like GDPR. Our team, available across France—including for GDPR support in Toulouse and other regions—is ready to help you meet this regulatory challenge with confidence and efficiency.
Ultimately, NIS 2 compliance is part of a broader responsible digital transformation, where information system security becomes central to corporate strategy. Organizations that integrate this dimension into their growth will be best positioned to thrive in tomorrow’s digital economy while maintaining the trust of customers and partners.
