vCISO Responsibilities Under NIS2: What the Regulation Actually Requires.

Does your business truly understand its cybersecurity obligations under the NIS2 Directive?

The NIS2 Directive, set to be transposed into Irish law, significantly expands the scope of cybersecurity requirements for a wide range of businesses, moving beyond critical infrastructure to include many more sectors. This means that for many Irish SMEs, what was once a 'good to have' is now a legal imperative, with clear responsibilities for management. Ignoring these new rules isn't an option; the consequences, including substantial fines and reputational damage, are too great. But how does a busy business owner in, say, County Donegal, navigate these complex regulations without a dedicated in-house cybersecurity expert? This is where the role of a Virtual Chief Information Security Officer (vCISO) becomes not just beneficial, but often essential.

The Expanding Net of NIS2: Are You Caught?

The NIS2 Directive aims to bolster the overall cybersecurity resilience across the European Union. It replaces the original NIS Directive and broadens its reach to include more entities and sectors deemed 'essential' or 'important' for the economy and society. This expansion means that businesses in manufacturing, digital providers, waste management, food production, and even certain research institutions, among others, will now fall under its remit. For many Irish SMEs, particularly those operating in critical supply chains or providing digital services, NIS2 introduces a new layer of legal accountability for their cybersecurity posture. The directive mandates a proactive approach to risk management and incident reporting, shifting the burden squarely onto the shoulders of senior management. This isn't just about preventing cyberattacks; it's about demonstrating due diligence and having robust systems in place to manage and respond to threats effectively.

One of the most significant changes is the explicit requirement for management bodies to approve cybersecurity risk-management measures and oversee their implementation. This isn't a task that can be delegated entirely to IT staff; it requires active engagement and understanding from the top. The National Cyber Security Centre (NCSC) Ireland has been actively involved in preparing for the transposition of NIS2, highlighting the seriousness with which these regulations will be enforced across the country [1]. Businesses in regional hubs like Sligo, with growing tech and manufacturing sectors, need to be particularly aware of how these changes will impact their operations and their legal obligations.

Article 20 & 21: Management's Direct Accountability

Articles 20 and 21 of the NIS2 Directive are particularly impactful for business leaders. Article 20, titled ‘Governance of cybersecurity risk-management measures’, explicitly states that management bodies must approve the cybersecurity risk-management measures and oversee their implementation. This means that the ultimate responsibility for cybersecurity strategy and its effectiveness rests with the board or senior management, not just the IT department. They are expected to take an active role in understanding the risks their organisation faces and ensuring appropriate measures are in place to mitigate them. This is a significant shift from previous regulations, where cybersecurity was often seen as a purely technical concern.

Article 21, ‘Cybersecurity risk-management measures’, outlines the specific types of measures that entities must implement. These include policies on risk analysis and information system security, incident handling, business continuity, supply chain security, and the use of cryptography and multi-factor authentication. For a business owner in, for example, Letterkenny, Donegal, this translates into a need for clear, documented policies and demonstrable actions to protect their digital assets and operations. The directive doesn't just ask for policies; it demands their effective implementation and regular review. Failure to comply can lead to administrative fines of up to €10 million or 2% of the total worldwide annual turnover, whichever is higher, for essential entities, and €7 million or 1.4% for important entities [2]. This financial penalty serves as a stark reminder of the gravity of these new obligations.

The vCISO as Your NIS2 Navigator

Given the direct accountability placed on management, many Irish SMEs are asking how they can realistically meet these demands without hiring a full-time, highly paid Chief Information Security Officer (CISO). This is where a Virtual CISO (vCISO) steps in. A vCISO provides expert cybersecurity leadership and guidance on a part-time or fractional basis, offering the strategic oversight and technical knowledge needed to navigate complex regulations like NIS2. Think of a vCISO as a seasoned captain guiding your ship through stormy seas; they don't row the boat, but they chart the course and ensure the crew is prepared for any squalls. They bring years of experience and a deep understanding of cybersecurity best practices, translating the technical jargon of NIS2 into actionable steps for your business.

A vCISO can help your organisation by:

• Developing and implementing cybersecurity policies: Crafting policies that meet NIS2 requirements for risk management, incident handling, and business continuity.
• Conducting risk assessments: Identifying vulnerabilities and threats specific to your business, including supply chain risks, and recommending appropriate controls.
• Overseeing security measure implementation: Ensuring that technical and organisational measures, such as multi-factor authentication and encryption, are correctly deployed and maintained.
• Providing training and awareness: Educating management and staff on their cybersecurity responsibilities and best practices.
• Assisting with incident response planning: Developing robust plans to detect, respond to, and recover from cyber incidents, including reporting obligations to authorities like the NCSC Ireland.
• Monitoring compliance: Regularly assessing your organisation's adherence to NIS2 requirements and preparing for audits.

While a vCISO provides invaluable support, it's crucial to understand that they do not absolve management of their ultimate responsibility. The directive is clear: management bodies must approve measures and oversee their implementation. A vCISO acts as an advisor and implementer, but the final decision-making authority and accountability remain with the business's leadership. For example, a vCISO might recommend a specific cybersecurity investment, but the board must approve the budget and understand the rationale behind it. This collaborative approach ensures that management is actively engaged and informed, fulfilling their NIS2 obligations.

---

Not sure where your business stands on cyber risk? Download the Irish SME Cyber Survival Guide — a free, plain-English guide to the 10 controls every Irish business needs. No jargon, no sales pitch.

---

vCISO vs. Internal IT: A Clear Distinction

It's important to distinguish the role of a vCISO from that of internal IT staff. While your IT team is essential for the day-to-day operation and maintenance of your systems, their primary focus is often on uptime and functionality. A vCISO, on the other hand, provides strategic cybersecurity leadership, focusing on risk management, compliance, and developing a holistic security posture. They bridge the gap between technical implementation and executive decision-making. Here's a comparison:

The key takeaway is that an internal IT team executes, while a vCISO strategises and ensures the execution aligns with regulatory requirements and best practices. For many SMEs, especially those in regions like County Sligo where access to highly specialised cybersecurity talent can be challenging, a vCISO offers a pragmatic solution. They provide the necessary expertise to meet NIS2 obligations without the prohibitive cost of a full-time CISO.

What Management Still Must Do Personally

Even with a vCISO on board, certain responsibilities under NIS2 cannot be fully delegated and remain with the management body. These include:

• Active Approval: Management must actively approve the cybersecurity risk-management measures. This isn't a rubber stamp; it requires understanding the proposed measures and their implications.
• Oversight: Continuous oversight of the implementation of these measures is essential. This means regularly reviewing reports from the vCISO, asking pertinent questions, and ensuring that the cybersecurity strategy is evolving with the threat landscape.
• Training: Members of the management body are required to undergo training on cybersecurity to gain sufficient knowledge and skills to identify and assess cybersecurity risks and their impact on the services provided by the entity. This ensures they can make informed decisions and effectively oversee the vCISO's work.
• Incident Reporting: While a vCISO will manage the incident response process, the ultimate responsibility for ensuring timely and accurate reporting of significant incidents to the relevant authorities (like the NCSC Ireland) rests with management.

In essence, management retains the helm, while the vCISO provides the navigation charts and helps steer the ship. This shared responsibility model ensures that cybersecurity is integrated into the core business strategy, rather than being an isolated technical function. It's about fostering a culture of security from the top down, a critical element for effective NIS2 compliance.

Preparing Your Business for NIS2: A Call to Action

The NIS2 Directive is not a distant threat; it's a present reality that demands attention from Irish businesses. The obligations under Articles 20 and 21 are clear: management must take an active, informed role in cybersecurity governance. For many SMEs, particularly those without in-house cybersecurity expertise, a vCISO offers a practical and cost-effective solution to meet these new regulatory demands. They provide the strategic guidance, policy development, and oversight necessary to build a robust cybersecurity posture and ensure compliance.

Don't wait for an incident or an audit to discover your NIS2 shortcomings. Proactive engagement now can save your business from significant fines, reputational damage, and operational disruption. Whether you're a manufacturing firm in Donegal or a digital service provider in Sligo, understanding and addressing your NIS2 responsibilities is paramount for your future resilience. Start by assessing your current cybersecurity maturity and identifying where a vCISO can best support your journey to compliance. The time to act is now.

Related Reading

• NIS2 Fines and Penalties: The Numbers That Should Keep Every Irish Director Awake.
• The 12-Month Cyber Governance Roadmap for a Donegal SME: From Zero to NIS2-Ready.
• Director Liability in the Age of NIS2 and GDPR: A Briefing for Irish Company Directors.

Ready to find out exactly where your business stands? Book a free 20-minute strategy call with our vCISO team at pragmaticsecurity.ie/book-a-call. No sales pitch. No jargon. Just clarity on your cyber risk — and a clear plan to address it.

[1] NCSC Ireland - NIS2 Directive [2] NIS2 Directive - European Parliament