NIS2 Penetration Testing and Compliance

Every day, we hear about security threats and attacks on organisations. These threats can range from ransomware and data breaches to leakage of sensitive data. There is no denying that cyber threats have been on the rise, and many organisations have fallen victim to these attacks, leading to financial and reputational losses. Hence, it is crucial to implement policies and processes that can help respond to these attacks.

What is NIS2 Penetration Testing?

NIS 2 penetration testing simulates a cyber attack against an organisation’s assets to identify vulnerabilities an actual attacker can exploit. This helps organisations comply with the NIS 2 requirement to assess their security posture thoroughly.

A penetration test under NIS 2 involves inspecting your network and information systems security measures. It is a simulated attack on your systems and networks to identify vulnerabilities. Organisations can achieve the required standards by taking corrective actions against the identified vulnerabilities.

NIS2 directive has the following direct links with penetration testing:

Aligned with recital 49 from the NIS2 directive, penetration tests help to identify missing updates and inadequate password controls.

Aligned with Recital 58 is the quick detection and mitigation of exploitable vulnerabilities in information systems and networks, a critical element of risk management.

10 Key Requirements For Network and Information Systems Compliance

Apart from conducting NIS 2 penetration tests, organisations are also required to fulfil some requirements for NIS 2 compliance. Implementing organisational measures is crucial as part of these requirements to effectively manage network and information systems risks while minimising the impact of cyber incidents on service recipients.

1. Risk Management

Risk management is the single most critical component from where everything starts. This is the spine of your cyber security program addressing your overall security posture and regulatory and compliance landscape. Therefore, risk identification and risk remediation aligned with standards or frameworks is a go-to approach for organisations ensuring proactive risk management.

2. Incident Reporting

NIS2 directive asks all companies to report high-impact security incidents within 24 hours to the authorities. The affected organisations must also share a detailed report on the incident within 72 hours. Should you need a breach notification template, download our free one as a starting point.

3. Business Continuity

Organisations should develop business continuity plans to ensure their essential services and functions face as little downtime as possible after a cyber attack. Disaster recovery is a critical control that must be addressed to avoid downtimes. It is not directly measured under technical risk assessments, therefore, a thorough review covering broader security of an organisation should pick up disaster recovery related controls, policies and processes. 

4. Security Policies

Organisations must develop thorough security policies describing the procedure for managing cyber risks, including implementing organisational measures. As you may have guessed, these policies define the roles and responsibilities of employees during a security incident.

5. Access Control

You can think of access controls as security checks that protect your organisation’s data from malicious actors. Hence, it is important to implement these controls from time to time and review them periodically.

6. Monitoring and Logging

Network activities and traffic should be continuously monitored and logged regularly. It will help detect potential cyber security threats and create an incident response plan. Having incident response capabilities demonstrates an organisations’ cybersecurity preparedness against adverse events, decreasing the probability of future attacks that could cripple an organisation. 

7. Supply Chain Security

Organisations must assess the cybersecurity posture and security measures of third-party vendors and ensure they meet cybersecurity standards. It will protect your organisation from supply chain attacks from malicious actors.

Additionally, it is crucial to comply with national law when ensuring third-party vendors meet cybersecurity standards.

8. Training and Awareness

Organisations must conduct regular cybersecurity training sessions for staff so that they understand their role in maintaining the security posture and best practices.

9. Incident Response Plans

Organisations must develop incident response plans so that the security teams have a playbook to prevent security incidents from causing more damage. You should test these plans regularly to ensure they are up-to-date with the evolving threat landscape. This is also included in wider crisis management plans or if any applicable cybersecurity legislation based on organisations’ requirements. 

10. Management Accountability

Your organisation’s senior management must oversee the implementation of security measures and access controls. It ensures management is held accountable for compliance with NIS 2 requirements.

Does NIS2 Compliance Require Penetration Testing?

Yes! Penetration testing is an integral part of risk management that is the core element of achieving NIS2 compliance. Without it, how would you know that your systems have gaps and vulnerabilities? It is better that these issues are discovered and fixed before they are exploited by attackers. It thus emphasises the need for organisations to assess their security measures regularly, which includes conducting penetration tests to identify and mitigate vulnerabilities.

Cyphere is a CREST-accredited penetration testing partner and IASME certification body for Cyber Essentials Plus certifications delivered across the UK and Europe. Our approach is more than ‘report and run’ style work and includes retests, risk remediation planning, and debriefs demonstrating post-care for all customers.

Penetration tests help validate existing security controls’ effectiveness and provide recommendations based on the findings.

Importance of NIS2 Penetration Testing for critical sectors

If you know about the first version of the NIS directive, then you would know that NIS2 is an upgrade from its predecessor in more ways than one. It focuses on risk management, incident reporting, and corporate accountability. Organisations are classified as essential, particularly those in critical sectors such as utilities, healthcare, and transportation. Each must implement security measures that are designed to protect against cyber threats.

Some of the critical sectors run OT and IT components together, meaning that without conducting risk assessment, organisations may remain unaware of the gaps in their posture introducing systemic risks.

Penetration testing is the most crucial part of NIS2 compliance because of these factors:

Identify Vulnerabilities

Penetration testing helps organisations identify and patch vulnerabilities in their systems before attackers exploit them.

Incident Response

Regular penetration tests allow organisations to evaluate their incident response protocols in real-world scenarios. It ensures that your team is prepared to mitigate security incidents effectively.

Meet Regulatory Requirements

As part of NIS 2 compliance, organisations must show that they have taken appropriate measures to manage risks effectively, and penetration tests are a way of proving that.

Build Customer Trust

Due to increasing threats leading to more cyber risks, customers are concerned about how their data is protected online. By performing penetration tests regularly and being NIS 2 compliant, you can reassure clients that you take their security seriously.

Stay on Top of New Attacks

Cyber threats constantly evolve, so organisations must stay one step ahead of attackers to be aware of their security gaps before threat actors. Regular penetration tests allow organisations to adapt their security measures in response to emerging threats.

Who Needs NIS 2 Penetration Testing?

NIS 2 applies primarily to “essential” and “important” entities within various sectors across the EU, including digital infrastructure.

Essential Entities

These include organisations that provide critical services, such as energy suppliers, healthcare, digital service providers, banks, etc. Since these entities are essential in maintaining public safety and economic stability, they must prioritise penetration testing as part of their compliance efforts.

Important Entities

This category contains organisations whose services may not be critical but still play a significant economic role. Think of businesses such as postal services, food supply chains, or manufacturing companies. These entities might not face as strict rules as essential entities, but they benefit greatly from regular penetration testing.

Non-EU Companies Operating in the EU

These companies are not based in the EU but still provide services within the EU market, such as cloud service providers or online platforms. They also need to comply with NIS 2 regulations.

When Should You Perform NIS 2 Penetration Testing?

Now, that is an excellent question. The timing is crucial when performing a penetration test, essential for NIS 2 compliance. If your organisation is beginning its journey towards NIS 2 compliance, conducting an initial penetration test to establish a baseline security posture will be beneficial.

A penetration test can also be conducted when your IT infrastructure undergoes major changes. This is a critical risk assessment step especially when discussing critical infrastructure for scope of a pentest. It will help you identify gaps and vulnerabilities in your new systems and suggest appropriate remediation steps that direct towards risk based vulnerability management. Vulnerability management is effective only once you have thorough risk identification processes in place that include penetration testing. Running point-and-click scanners is not an in-depth exercise, though it is important to cover the breadth of an estate in a shorter time period to know high-level security posture. 

Even if your IT systems have not undergone major changes, it is still recommended that you conduct regular penetration tests, either annually or bi-annually. You should also perform a pentest if your organisation has recently experienced a cyber attack. It will help you better prepare for future attacks and deploy a defensive strategy.

How Much Does NIS2 Penetration Testing Cost?

Similar to a standard penetration test, the cost of a NIS 2 penetration test varies and is dependent on several factors:

Scope of Testing

The scope includes all the company’s assets, such as systems, networks, and applications, that will be assessed during a penetration test. Some penetration tests are limited to only the internal network, while others are more comprehensive and may include web applications and mobile apps.

Remember, we are discussing penetration testing here, not automated vulnerability assessments, which are a fraction of the price of a pentest.

Complexity of Systems

Organisations with complex IT assets and critical infrastructure may take more time to assess due to the complexities of evaluating various components.

Experience of the Testers

Another important factor determining the cost of a penetration test is the experience level of the penetration testers and the security vendor you choose to conduct the test. Every vendor has a different cost depending on their business operations and the number of people working on your project.

Frequency of Testing

An organisation may perform security assessments regularly after a specific interval. Different organisations carry out penetration tests differently. Some perform a pentest annually, while others perform it bi-annually or quarterly. The frequency of the penetration tests depends on the organisation’s goals and objectives.

How does Cyphere perform penetration testing for NIS compliance?

Our team of experts at Cyphere will guide you through the entire process. We start with a pre-consultation session to discuss your business needs and tailor our approach to your business goals. Then, our team develops a detailed plan for performing the assessment.

After completing the penetration test, we will submit a detailed report that includes the findings and remediation steps to improve your organisation’s security. Even after that, we offer ongoing support throughout remediation efforts, ensuring successful implementation before re-testing if necessary!

Summary

We have covered the importance of penetration testing in NIS 2 and how it works. So, now there is no denying the importance of NIS 2 and its role in protecting organisations in the EU. The European Union has done its part of developing a robust regulation, now it is our turn to implement it diligently to create a secure digital environmet for the users.