GRC Answer

What should be on a NIS2 compliance checklist?

A NIS2 compliance programme comes down to a handful of things done properly: confirm whether you are in scope and as which tier, put in place the Article 21 risk-management measures, stand up incident detection and staged reporting, address supply chain security, and get the management body to approve and oversee it all. The checklist below covers the core areas any programme must address; it is not a substitute for your member state's transposed requirements, which add the specifics. Determine scope and tier: confirm whether you are in scope, in which Annex I or II sector, and whether you are an essential or an important entity. Register with your authority: meet the registration and information obligations your member state's transposition sets for in-scope entities. Implement the Article 21 measures: put in place the ten categories of risk-management measures, covering risk analysis and security policy, incident handling, business continuity and crisis management, supply chain security, security in acquisition and development, policies to assess effectiveness, basic cyber hygiene and training, cryptography, human resources and access control, and multi-factor authentication and secured communications. Stand up incident reporting: build the detection, classification, and staged reporting process required under Article 23, and know who your CSIRT or competent authority is. Address supply chain security: assess and manage the security of your direct suppliers and service providers, as Article 21 requires. Secure management-body approval and oversight: under Article 20, the management body approves the risk-management measures, oversees them, and can be held liable. Training for management is part of this. Maintain evidence: keep the records that show the measures are real and operating, because supervision, proactive for essential entities, will look for them.