Compliance Briefing — September 16, 2024
One month before the NIS2 Directive transposition deadline, EU operators of essential and important entities must finalise risk management policies, incident reporting playbooks, and board oversight structures to meet incoming national laws.
Executive briefing: Member States must transpose Directive (EU) 2022/2555 (NIS2) by October 17, 2024. Organisations operating in energy, transport, health, financial market infrastructures, digital infrastructure, and other designated sectors should expect updated national cybersecurity laws mandating risk management measures, 24-hour early warning reports, and executive accountability.
Key compliance checkpoints
- Risk management measures. Article 21 requires policies covering incident handling, supply chain security, vulnerability disclosure, encryption, and asset management.
- Incident reporting. Operators must deliver an early warning within 24 hours, an initial assessment at 72 hours, and a final report one month after incident resolution.
- Governance. Management bodies must approve cybersecurity risk management and can be held liable for non-compliance; mandatory training is required.
Control alignment
- Map to ISO/IEC 27001 and NIST CSF. Align existing frameworks to NIS2’s Annex I/II sector scope and Annex IV controls to speed compliance.
- Supply chain oversight. Extend risk assessments and contractual clauses to critical suppliers, including cloud and managed services providers.
- Board reporting. Establish board dashboards tracking incident metrics, remediation status, and training completion to evidence oversight.
Enablement moves
- Coordinate with national CSIRTs and competent authorities to confirm reporting portals, templates, and contact points.
- Run incident response exercises covering early warning and 72-hour updates, including cross-border escalation.
- Review insurance coverage and contractual liability clauses in anticipation of heightened supervisory enforcement.
Sources
- Directive (EU) 2022/2555 on measures for a high common level of cybersecurity (NIS2)
- European Commission NIS2 implementation guidance
Zeph Tech delivers NIS2 readiness roadmaps tying incident response, supplier governance, and executive accountability to the Directive’s October 2024 enforcement milestone.