Rockstar Library

NIS2: The Most Misunderstood Cyber Regulation in Europe

Written by Eve Cooper | Jan 2, 2026 5:00:00 AM

 

 

The EU’s NIS2 Directive is widely discussed - and widely misunderstood.

Many organisations are treating it as another technical compliance exercise.

Regulators see it very differently.

 

What NIS2 is really about

NIS2 is not primarily a cybersecurity uplift directive.

It is a leadership accountability and governance regulation.

Guidance from the European Union Agency for Cybersecurity (ENISA) makes this explicit.

 

NIS2 introduces:

  • Personal accountability for senior management
  • Mandatory governance structures
  • Oversight obligations that cannot be delegated

This marks a decisive move away from “IT-owned security” toward executive-owned cyber risk governance.

 

The requirements organisations are missing

Many NIS2 implementations focus on tooling and controls, while overlooking mandatory governance elements such as:

  • Board-approved cyber risk policies
  • Formal assignment of risk ownership
  • Defined escalation and decision pathways
  • Evidence of continuous oversight

These governance failures, not technical gaps, are most likely to trigger enforcement action.

 

Why UK organisations are still in scope

UK-based firms often assume NIS2 does not apply. In practice, many remain exposed through:

  • EU-based clients
  • EU supply chains
  • EU subsidiaries or data processing activities

NIS2 obligations frequently flow contractually, even where they do not apply directly.

 

The RockSec360 interpretation

NIS2 compliance is not achieved by buying more security tools.

It is achieved by being able to demonstrate:

  • How cyber risk is governed
  • Who owns decisions
  • How oversight is maintained
  • Why actions taken were proportionate

RockSec360 enables organisations to evidence NIS2-aligned governance without creating consultant dependency or governance theatre.

 

If you cannot explain your cyber governance model to a regulator, it is not NIS2-ready.

 

Start with the Cyber Risk & Compliance Scorecard to understand your current exposure and governance maturity.