Introduction

With cyber threats escalating, the NIS2 Directive (Directive (EU) 2022/2555) represents the most significant shift in European cybersecurity governance in a decade. It moves beyond the original NIS Directive, not only expanding the scope to cover essential and important entities but, critically, transforming compliance into an executive-level priority. A change that raises the bar for cybersecurity governance across Europe.

The main goal is to raise the overall level of cybersecurity for networks and information systems and to harmonize how member states deal with cyber risks, incidents, and critical services.

This article focuses on what NIS2 compliance really means in practice – and how to build a scalable cybersecurity framework that is audit-ready, repeatable, and integrated into daily operations.

For an introductory overview of the directive itself, affected sectors, and key components, see our main NIS2 overview page.

What NIS2 Compliance Really Means

NIS2 compliance involves implementing governance structures, risk-management, proportional technical and organizational controls, as well as the reporting processes and supervisory requirements required under the Network and Information Systems Directive (EU 2022/2555).

In practice this includes the following points:

  • Clear management accountability for cybersecurity, including oversight of controls, risk-based decision making, and required participation in cybersecurity training.

  • A risk-based security framework for all relevant network and information systems.

  • Incident handling and reporting within strict timelines.

  • Business continuity and operational resilience, including crisis management, recovery planning, and backup strategies.

  • Supply-chain and third-party risk management, with contractual security requirements and continuous vendor oversight.

  • Documentation, evidence, and cooperation with supervisory authorities.

NIS2 applies to most medium-sized and large entities across essential and important sectors (energy, transport, healthcare, digital infrastructure, manufacturing, food, and more) in Europe – and indirectly to many smaller suppliers in their ecosystem with critical services.

NIS2 vs NIS1: What Has Changed?

While many organizations are familiar with the original NIS-Directive (EU) 2016/1148 (=NIS1), NIS2 (Directive (EU) 2022/2555) introduces broad changes in terms of scope, responsibilities and enforcement. To understand why NIS2 represents a significant shift, it helps to compare it directly with its predecessor. The table below highlights the key differences between NIS1 and NIS2 at a glance.

NIS1 NIS 2
Scope & Sectors Limited to a small set of essential service operators and a few digital service providers. Expanded to many more essential and important entities across additional sectors (e.g., manufacturing, food, waste, digital infrastructure).
Size Criterion No standardized size-based criteria; inclusion mainly depended on sector-specific designation. Applies to all medium and large entities of sectors in scope through size-cap rule – with additional inclusion of smaller entities for certain high-impact services.
Governance & Management Operational security focus with limited management obligations. Explicit board-level responsibility, mandatory oversight, and cybersecurity training for management bodies.
Risk Management Duties General requirement for “appropriate and proportionate” security measures. Detailed set of required technical and organizational measures (e.g., risk analysis, incident handling, BCM, supply-chain security, encryption).
Incident Reporting Single reporting step within 72 hours for significant incidents. Three-step reporting for significant incidents: early warning (24h), incident notification (72h), and final report (1 month).
Supervision & Sanctions Less harmonized national supervision and lower sanctions. Stronger, harmonized oversight and significantly higher fines (up to €10M or 2% of global turnover).
Supply-Chain Security Only indirectly addressed. Explicit obligations to assess and control ICT supply-chain and third-party risks.

Overview of the key differences between NIS1 and NIS2

Key NIS2 Requirements (and What They Mean in Practice)

NIS2 introduces a series of far-reaching security, governance, and operational requirements that apply to in-scope essential and important entities. The following are the core requirements areas and how they typically translate into organizational responsibilities in practice.

Governance & Accountability

NIS2 explicitly anchors cybersecurity responsibility at board and top-management level, introducing clear legal accountability. Leadership is now compelled to:

  • Approve and oversee systematic cyber risk management measures.
  • Ensure adequate resources, policies and training are in place.
  • Supervise implementation and take personal liability in cases of non-compliance.

This shifts cybersecurity from a pure IT topic to a governance and risk issue.

How ADOGRC helps:
A clear governance structure linking responsibilities to risks, controls and processes gives management real-time visibility and auditable evidence at all times.

Risk Management

To comply with the directive organizations are required to identify, assess, prioritize, and mitigate cyber and operational risks. This includes technical & organizational measures (TOMs), policies, asset inventories, and continuous reviews.

Put into practice, this consists of:

  • Maintaining asset inventories and critical mapping.
  • Running structured risk assessments and treatment plans.
  • Implementing and tracking technical and organizational measures (TOMs).

How ADOGRC helps:
Centralized cyber risks, clear overview of issues, likelihood, and impact, and linkage to relevant assets ensure consistent, data-driven risk management.

Incident Management & Response

NIS2 mandates a strict three-step reporting process: early warning within 24h, incident notification within 72h, and a final report within one month. Organizations must maintain a complete incident lifecycle: detection, analysis, containment, actions, evidence, and communication.

Practically, this requires:

  • Defined incident classification and severity criteria.
  • A structured incident lifecycle (detection → analysis → containment → recovery → lessons learned).
  • Clear roles, runbooks and evidence trails to support reports to authorities.

How ADOGRC helps:
Centralized risk repositories, automated workflows, and linked controls streamline assessments and ensure consistent, evidence-based risk management.

Supply Chain & Third-Party Security

NIS2 strengthens obligations around suppliers, service providers, and ICT dependencies. Organizations must assess third-party risks, maintain transparency of dependencies, and ensure contractual security controls.

Organizations need to:

  • Assess,document, and map dependencies on critical suppliers and service providers.
  • Evaluate supplier security practices and contractual safeguards.
  • Include security and continuity clauses in contracts and monitor compliance.

How ADOGRC helps:
Supplier dependencies and risk assessments, and remediation tracking allow organizations to manage supply-chain exposure within a single integrated platform.

Business Continuity & Crisis Management

NIS2 explicitly requires organizations to establish robust cyber risk management practices, including Business Continuity Management, secure backup and disaster recovery measures, and effective crisis management capabilities.

This typically includes:

  • Identifying critical services and processes (e.g. via BIA).
  • Defining MTPD, RTO, RPO and continuity strategies.
  • Maintaining and testing recovery and crisis plans.

How ADOGRC helps:
Linked BIAs, recovery metrics, and continuity plans ensure operational resilience and compliance across all critical processes.

Hint: Discover ADOGRC’s integrated solution for Business Continuity Management.

Compliance Oversight & Supervision

NIS2 differentiates between essential and important entities, with stricter ex-ante and ex-post supervision for essential entities. Therefore organizations must:

  • Maintain documentation and evidence of risk management measures.
  • Monitor the implementation of measures for full transparency
  • Be prepared for audits, inspections, and corrective orders from authorities
NIS2 Compliance Cycle

NIS2 requirements visualized in the compliance cycle

Through its compliance library, ADOGRC maps all applicable company-specific requirements to risks, measures, controls and owners. Real-time status dashboards and reports support audits, inspections, and documentation obligations for both essential and important entities.

Simplify your NIS2 compliance with the integrated solution of ADOGRC.

Common Challenges When Implementing NIS2

Even with a well-defined framework, implementing NIS2 can be tougher than expected. Here are typical challenges you may encounter:

  • Fragmented National Execution
    Member states implement NIS2 via their own national laws and timelines, which creates uncertainty and variation in details such as sector lists, supervisory practices, and deadlines.

  • Limited Resources & Budget
    Medium-sized entities and public institutions often lack specialized cyber staff, tools, or budget to build manual governance frameworks. The requirements of NIS2 quickly exceed spreadsheet-based approaches.

  • Governance Gaps & Lack of Management Involvement
    Many organizations still see security as an IT topic. Since NIS2 shifts responsibility to the board and requires proper training, governance structures and reporting lines need to be revised.

  • Supply Chain Complexity & SME Impact
    Even organizations not directly in scope will feel NIS2 via contractual requirements from customers. Suppliers must demonstrate controls, incident reporting capabilities, and continuity arrangements to remain part of critical value chains.

  • Overlapping Frameworks
    NIS2 rarely exists in isolation. Many entities are already working with ISO 27001, DORA (for financial entities), NIST CSF, or BSI IT-Baseline.

Without a central view, organizations risk duplicated work and inconsistent controls.

Instead of rebuilding a framework from scratch, a mapping approach supported by a structured compliance library helps align NIS2 requirements with your existing frameworks. This allows you to identify overlaps, reduce duplication, and manage compliance more easily within your current processes.

5 essential Steps to Achieve NIS2 Compliance

This section outlines a practical, implementable approach to achieving NIS2 readiness.

Step 1: Assess Exposure and Maturity
Identify whether NIS2 applies to your organization, conduct a gap assessment, and review current governance and risk posture.

Step 2: Define Governance, Roles & Controls
Clarify responsibilities, formalize policies, assign owners, and introduce a structured control framework aligned with NIS2.

Step 3: Map NIS2 Requirements to Existing Frameworks
Reuse controls where possible to avoid duplication and strengthen auditability.

Step 4: Implement Continuous Monitoring & Incident Handling
Set up dashboards, KPIs, reporting cycles, and structured incident workflows.

Step 5: Report, Audit & Improve
Maintain complete documentation, run audits, and integrate lessons learned into the security framework.

Turning NIS2 Into an Advantage

While NIS2 brings new obligations, it also offers a clear opportunity to modernize how cybersecurity is governed and operated:

  • Improved visibility & ownership – map risks, incidents and controls to accountable stakeholders so everyone knows who is responsible and why.
  • Faster response – define processes, playbooks and measurable KPIs to shorten detection and recovery times.
  • Stronger trust – customers, partners and regulators gain confidence from a transparent, risk-based approach.
  • Aligned risk & resilience — connect cyber risks with enterprise risk management and resilience initiatives so security decisions directly support broader business objectives.

Organizations that embed NIS2 within their broader GRC strategy turn compliance into a strategic differentiator rather than a cost.

Conclusion

NIS2 redefines cybersecurity governance for organizations across the EU. Organizations are now required to follow a more structured and risk-based approach to safeguard their key assets. To build a resilient security foundation, companies must align responsibilities, strengthen incident management, and ensure supply chain continuity in line with NIS2.

A clear governance framework and consistent documentation enables NIS2 to become a driver of transparency, trust, and resilience. ADOGRC  supports implementing these requirements in a connected and efficient way – by bringing together risks, incidents, continuity measures, and supplier monitoring in one unified platform.

Simplify NIS2 compliance and boost your cyber resilience with ADOGRC

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