Recently, organizations across Europe have been scrambling to comply with the NIS2 Directive, which imposes cybersecurity and information security obligations on companies that were previously exempt. To avoid financial penalties and ensure compliance, many organizations are turning to expert firms to guide them through the process. One of the first steps towards compliance is undergoing a Gap Assessment Audit to identify any areas of non-compliance.
The main driving force behind organizations seeking NIS2 compliance is the desire to steer clear of fines. Unfortunately, many leaders lack a full understanding of information security and see compliance as a one-time activity rather than an ongoing commitment. It is crucial for organizations to shift their mindset towards creating long-term value and reducing the risks posed by constantly evolving cyber threats. Providing training opportunities for leaders and employees is essential to raise awareness and lay the groundwork for this change in perspective.
During the audit process, it is common for personnel within organizations to struggle with grasping the requirements of control measures, resulting in misunderstandings. Clear communication and education are key to ensuring that all parties involved in the audit understand the why behind each requirement and how they are interconnected. Pre-audit education for organizations new to NIS2 compliance can help streamline the process and ensure that everyone knows how to provide evidence-based answers to audit inquiries.
For many organizations that are now subject to NIS2 compliance, outsourcing IT operations has been a common practice. However, these IT service providers may lack the necessary information security skills, posing challenges when addressing identified deficiencies. Audits should not only focus on control compliance but also emphasize the conditions required to maintain compliance from an IT operations and information system perspective.
In-house IT staff in organizations that do not outsource their IT operations often face a shortage of skilled personnel. This reliance on a few key individuals can pose a significant risk, particularly if critical knowledge is not documented and resides solely in the minds of these IT professionals. Establishing support staff who can document controls and create an auditable Information Security Management System (ISMS) is crucial for achieving NIS2 compliance.
One common issue organizations face is a lack of documentation for processes, information systems, and related policies and procedures. This absence of documentation makes it challenging to conduct thorough audits and address deficiencies effectively. Providing recommendations for establishing appropriate regulatory frameworks in audit reports can assist organizations in achieving compliance.
Audited parties often struggle to understand the necessity of certain controls and how they relate to their specific activities. Pre-audit training can help clarify that not all controls apply universally and that some may be irrelevant based on the organization’s operations. Addressing these misunderstandings is crucial for ensuring comprehensive compliance with NIS2 requirements.
To prevent system failures and data breaches, organizations must prioritize IT security and information security beyond the minimum necessary conditions for operation. Lack of attention to security measures can lead to severe consequences and potentially devastating incidents. Organizations must invest in security measures to mitigate risks and protect sensitive data effectively.
In conclusion, audit experiences reveal that many organizations are ill-prepared for NIS2 compliance, posing significant challenges. Conducting audits is essential for organizations to understand their current standing, identify areas for improvement, and allocate resources accordingly to address deficiencies and tackle cybersecurity threats effectively.
Zsolt Baranya, a Senior Information Security Auditor at Black Cell Ltd., emphasizes the importance of proper education and preparation for NIS2 compliance to navigate the increasingly complex cybersecurity landscape successfully. His expertise in information security and compliance has equipped him to guide organizations through the process of achieving and maintaining NIS2 compliance.