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NIS2 Compliance Checklist

Download the Object First NIS2 checklist to navigate the compliance process and protect your operations from cyber threats.

If you think NIS2 is just administrative noise, look closer at Article 20: C-level executives are now personally liable for cybersecurity governance failures. This means liability isn’t limited to corporate fines—executives themselves can face sanctions, including bans from management roles.

This NIS2 compliance checklist is your operational defense. We strip away the bureaucracy to focus on the technical hard requirements of Article 21—specifically, the mandatory implementation of robust backup management and disaster recovery.

Master these requirements to validate that your data protection strategy will survive both an NIS2 audit and a ransomware attack.

Checklist guide cover titled 'Getting NIS2 Ready: Your 7-Step Checklist'

What Is NIS2?

The Network and Information Security Directive 2 (NIS2) is the European Union’s legislative framework for enhancing cyber resilience across its member states and the critical entities operating within them.

Passed in late 2022, the Directive set a deadline of October 17, 2024, for EU Member States to transpose it into national law. While not every country met that exact deadline, all are actively working toward implementation, and enforcement is rapidly commencing.

NIS2 is a direct response to the escalating frequency and sophistication of cyberattacks, particularly those targeting supply chains and essential services.

Its fundamental goal is to establish a high common level of security across the EU's single market, requiring organizations to adopt comprehensive technical, operational, and organizational risk management measures.

NIS vs. NIS2: The Technical Pivot

The original NIS Directive (NIS1) was a decentralized approach, leading to inconsistent implementation across the EU. NIS2 is an overhaul that forces standardization.

Its primary difference lies in the dramatic expansion of scope to cover new sectors (e.g., manufacturing, waste management, digital services) and a strict increase in accountability.

While NIS1 focused broadly on critical infrastructure, NIS2 clearly defines "Essential" and "Important" entities, standardizes the 10 minimum security measures (Article 21), and, most critically, introduced personal liability and massive financial penalties for C-level management.

Who Needs to Comply with NIS2?

NIS2 is designed to cast a wide and standardized net, eliminating the ambiguity of the original directive. It moves beyond just the "Critical Infrastructure" of the past and now targets any entity whose disruption could impact the functioning of the internal market.

The scope is fundamentally defined by two tiers, differentiated by their criticality and, consequently, their compliance oversight and fine potential: Essential Entities (EE) and Important Entities (IE).

Essential Entities (EE)

These organizations operate in sectors deemed critical to the economy and society. Their compliance obligations are the most stringent, including mandatory incident reporting within 24 hours.

You are classified as an Essential Entity if your business has over 250 employees and an annual turnover exceeding €50 million, and you fall under any of the following categories:

  • Digital Infrastructure

    E.g., Cloud Computing Services, Data Centre Providers, DNS Services.

  • Energy

    E.g., Electricity Suppliers, Oil and Gas Production, District Heating.

  • Finance

    E.g., Credit Institutions, Stock Exchanges, Central Counterparties.

  • Health

    E.g., Hospitals and Clinics, Pharmaceutical Manufacturers, EU Reference Laboratories.

  • Public Administration

    E.g., Central and Regional GovernmentBodies.

  • Space

    E.g., Satellite Navigation 
Providers.

  • Transport


    E.g., Airlines, Rail ManagementBodies, Port Authorities.

  • Water Supply

    Drinking & Wastewater 
Treatment and Distribution.

Important Entities (IE)

This new classification significantly broadens the directive's reach, bringing thousands of new medium-sized businesses into scope. While the supervisory approach is typically reactive (following an incident), the core data security requirements of Article 21 remain mandatory.

You are classified as an Important Entity if your business has over 50 employees and an annual turnover exceeding €10 million, and you fall under any of the following categories:

  • Chemicals

    E.g., Chemical Production and Distribution.

  • Foods

    E.g., Processing and Distribution.

  • Manufacturing

    E.g., Medical Device Manufacturing, Computer Equipment, Machinery.

  • Postal Services

    E.g., Postal and Courier Services.

  • Research

    E.g., Research Organizations.

  • Waste Management

    E.g., Waste Disposal and Recycling Operations.

Download the Checklist and Evaluate Your NIS2
Compliance

Checklist guide cover titled 'Getting NIS2 Ready: Your 7-Step Checklist'

Key NIS2 Requirements

NIS2 standardizes security measures across the entire EU by mandating ten minimum requirements that all Essential and Important Entities must meet. Successfully integrating these is the core of your NIS2 compliance defense.

Here are the 10 non-negotiable requirements you must address:

1. Incident Handling (The 24-Hour Rule):

Establish procedures for preventing, detecting, and responding to security incidents, including the mandatory 24-hour Early Warning reporting timeline.

2. Risk Analysis and Security Policies:

Implement detailed risk analysis procedures and establish comprehensive information system security policies to guide operations.

3. Business Continuity and Disaster Recovery:

Apply policies to ensure continuity of service, including robust backup management, disaster recovery (DR) capabilities, and crisis management planning.

4. Supply Chain Security:

Address security risks within the supply chain and manage the security aspects concerning the relationship between your entity and its direct suppliers or service providers.

5. Security in Development and Acquisition:

Enforce security principles throughout the acquisition, development, and maintenance of network and information systems, including vulnerability handling and disclosure.

6. Testing and Auditing:

Conduct regular testing and auditing of the effectiveness of the cybersecurity risk management measures you have implemented

7. Cryptography and Encryption:

Utilize cryptographic and encryption solutions to protect data in transit and at rest, maintaining confidentiality and integrity.

8. Access Control and Asset Management:

Implement strict policies on access control and manage the security of all IT assets and systems,  including those used by employees.

9. Human Resources Security and Training:

Incorporate cyber security awareness training, implement access restrictions, and establish robust personnel security procedures.

10. Multi-Factor Authentication (MFA) and Secure Communication:

Deploy MFA solutions, secure voice, video, and text communications, and utilize secure emergency communication systems

How Object First Can Help Comply with NIS2

The new rules under the NIS2 Directive are significantly more demanding, introducing higher or entirely new fines for non-compliance. Essential Entities must be prepared to face fines up to €10 million or 2% of their global yearly earnings (whichever is higher), while Important Entities could face fines up to €7 million or 1.4% of their global earnings.

These high penalties underscore the urgency of complying with technical sections, such as Article 21. We encourage every business to review the entire directive, as this tremendous evolution demands a significant architectural overhaul to ensure efficient compliance.

To streamline this essential architectural lift, we thought we’d extend specific, technical recommendations that demonstrate how Object First can help you achieve and sustain your NIS2 goals efficiently.

  • NIS2 Section 89 recommends organizations adopt Zero Trust principles to improve their overall security posture. However, traditional Zero Trust models often overlook the backup environment.

    Zero Trust Data Resilience (ZTDR) is a comprehensive data protection approach that expands Zero Trust to your recovery systems. It introduces critical elements, such as separating backup software and backup storage, creating multiple resilience zones, and mandating immutable, encrypted storage.

    ZTDR is crucial because it provides a robust, breach-assumed framework that directly supports the resilience and accountability NIS2 demands.

Discover the solution that meets all NIS2 Checklist Requirements

Object First seeks to help all Veeam customers in the EU ensure that their backup storage exceeds NIS2 standards. That’s why we created Ootbi 
(Out-of-the-Box Immutability), a NIS2-compliant solution.

Ransomware-proof Ootbi by Object First delivers secure, simple, and powerful backup storage that’s Absolutely Immutable. With the ultimate ransomware defense, you and your organization become Simply Resilient.

Object First is built on Zero Trust best practices and is third-party tested to be secure, is simple to deploy and manage with no security expertise required, and is powerful enough to supercharge Instant Recovery and scale with your business.

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The 7-Step NIS2 Compliance Checklist to Audit Your Security Posture

The 10 minimum security measures of Article 21 are technically demanding and can be ambiguous without a clear plan of action. That’s why we have distilled the entire NIS2 Directive into a powerful, 7-step framework that moves you from regulatory interpretation to proven technical execution.


Download our NIS2 checklist now to immediately evaluate your current security posture against the mandatory requirements and build an audit-proof data protection strategy that protects both the business and its management.

Checklist guide cover titled 'Getting NIS2 Ready: Your 7-Step Checklist'

FAQ

When Should NIS2 Be Implemented? 

The formal deadline for EU Member States to transpose NIS2 into national law was October 17, 2024. All essential and important entities should align their operational and security measures to meet the directive's requirements immediately, regardless of their local government's transposition status. 

How Does the NIS2 Directive Impact EU Businesses? 

NIS2 fundamentally raises the bar for cyber resilience, mandating that all in-scope businesses implement technical controls across the supply chain and business continuity. The directive most significantly impacts senior management by introducing personal liability and steep financial penalties for compliance failures. 

Are There Industry-Specific Considerations in a NIS2 Compliance Checklist?

While the 10 minimum security measures are standard, organizations must apply them proportionately based on their sector's unique risk profile (e.g., healthcare's data vs. manufacturing's OT systems). Our checklist provides the framework, but the implementation details must be tailored to your specific industry's operational technology and data handling. 

NIS2 vs GDPR: What’s the Difference and Where Do the Reporting Obligations Overlap? 

GDPR protects the privacy of personal data, whereas NIS2 protects the security and resilience of the system itself. An incident involving a data breach will trigger both laws, requiring separate reports to the NIS Competent Authority and the relevant Data Protection Authority (DPA).