Compliance & Legislation | Operational resilience

June 7, 2022

Critical infrastructure and its security has never been more in the spotlight; and it’s no different in the EU. The number of cyber disruptions across the globe to key service providers like water, power and financial services suppliers has brought the social and economic implications of such risks into sharp focus.

Critical infrastructure as a high stakes target

The massive growth of ransomware has demonstrated the high stakes at risk in the sector. The recent geo-political events in Europe and elsewhere, in many cases augmented by state-sponsored cyber attacks, have alerted governments everywhere of the need to improve cyber risk readiness and resilience procedures.

These observations were highlighted in some of our recent blogs following the issue of joint cyber security advisories by multiple security agencies identifying the profile of common attacks and recommendations on how best to defend against the plethora of current cyber-attacks.

The security landscape is changing everywhere

There is the healthcare sector and the ransomware attacks on the HSE in Ireland or NHS in the UK. The Colonial Pipeline cyber breach in the US, and the attack on JBS or KP in the food sector. There is a preponderance of cyber attacks and malware targeted at heavy industries and utility companies.

In each of these cases, and there are numerous similar European equivalents, the successful attacks have resulted in significant disruption or even harm to the broader community. Like everywhere else, the European critical infrastructure sector is now acknowledged as being vulnerable to attack and service interruptions can quickly escalate to economic harm, and impact our safety, wellbeing and health. Adversaries, irrespective of their ideological intent, know this all too well and that is why the increasingly prescriptive nature of recent advisories from international security agencies is not coincidental.


In 2016, the EU drafted the Network and Information Security Directive (NIS Directive), providing the groundwork for cyber security awareness and the formalisation of Network and Information Systems security practices and procedures across the critical infrastructure sector. Since that time, however, the range of industries that constitute that sector has expanded considerably; as have the risks of cyber attack. The original implementation, following enactment in the various EU states proved to be a time-consuming process. Some highly regulated industries (such as finance in the UK) already had regulatory regimes which needed to be taken into account; while other sectors required a regulator be appointed.

Necessarily, legislation and regulation preceded the adoption of guidance and standards and while it was a prescient initiative, its adoption was a somewhat “bumpy” process.

And so to NIS2

In the face of the rising risk of attack against infrastructure organisations, especially from ransomware and malware; and given the political atmosphere in Europe, NIS2 tightens and strengthens the controls and procedures required:

“… flagging cybersecurity incidents to authorities within 24 hours, patching software vulnerabilities, and readying risk management measures to secure networks, failing which can incur monetary penalties.”

In the NIS2 draft the Council of the European Union notes that cyber security preparedness and the effectiveness of those efforts are now more essential than ever for the proper functioning of network and information systems.

Cyber security cultural and regulatory changes in the EU

NIS2 anticipates significant changes in cyber culture and regulatory approach to cyber security. It introduces a risk management approach to cyber security together with a baseline list of cyber security elements (hygiene requirements) as well as IT risk assessment provisions for supply chain and 3rd party suppliers.

In many respects this echoes the requirements and advice from other governments to their constituents and business communities. The expanded set of critical infrastructure organisations will need to harden their cyber security posture – assessing vulnerabilities and updating their software and security controls in order to more quickly detect and respond to these attacks.

The growing frequency of joint advisories from government security agencies demonstrates, quite clearly, that intelligence communities everywhere are worried about an increasingly common set of attack risks.  We blogged about these here and here.

NIS2 Strategy

The adoption of NIS2 aims to support the wider EU cyber security strategy by (paraphrased from here):

  • Increasing the level of cyber-resilience across a comprehensive set of key businesses. It seeks to put in place rules that ensure that all public and private entities, that fulfil important functions for the economy and society as a whole, take particular and adequate cyber security measures.
  • Reducing inconsistencies in resilience of those sectors already covered by the Directive, by further aligning the scope, and the security and incident reporting requirements, with provisions that govern national supervision and enforcement and by suitably competent authorities in each of the Member States.
  • Improving the level of joint situational awareness and the collective capability to prepare and respond, by taking measures to increase the level of trust between competent authorities, and sharing information, setting rules and management procedures suitable for a large-scale incident or crisis.

In essence, these objectives can be condensed into:

  • Improve and maintain good security
  • Being consistent across sectors and jurisdictions
  • Share information and procedures to build collaboration and trust between all stakeholders

The new order begins

And so, in May 2022, the European parliament provisionally agreed to adopt the new NIS2 Directive.  Meaning a process of ratification, enactment, standardisation and implementation of cyber security processes and procedures can commence across the EU nations.

The NIS2 Directive brings Europe into closer alignment with a number of other nations and for its citizens that rely on the key services of critical infrastructure businesses, this will improve the state of cyber security and heighten the level of cyber resilience in the sector. To do so, the Directive expects greater cyber security preparedness and security control effectiveness by organisations to better protect the sector and the community they serve.

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