CCyber Blog

Our blog features practical articles on cybersecurity and regulations, written in plain language that business owners and managers can understand. We cover specific topics such as NIS2, DORA and CRA requirements, ISO 27001 implementations, incident analysis, phishing, ransomware and best practices for SMEs.

Instead of technical jargon we offer actionable guidance that can be applied to your business straight away. We focus on content you can implement immediately: checklists, threat analyses, SME guides and regular updates on new regulations.

What Is IT Contracting and How to Work Securely with IT Contractors?

IT Contracting is a cooperation model where a company uses external IT specialists for a specific project, capability or period. For organizations, it means faster access to experts, flexibility and the ability to scale teams without a long recruitment process. For contractors, it usually means higher rates, more independence, B2B settlement and project-based work. However, this model requires good governance: contract terms, confidentiality, IP rights, non-compete clauses, time tracking, payments, professional liability insurance, access control, onboarding, offboarding and security requirements. The biggest company mistake is treating a contractor like a temporary employee without access and accountability rules. The biggest contractor mistake is signing a contract without understanding the risks.

Prepared by: CCyber Editorial Team

Note: This article is educational and strategic. It is not legal, tax or accounting advice. When signing B2B contracts, choosing tax treatment, insurance or liability clauses, it is worth consulting a lawyer, accountant or tax adviser.

Short answer

IT Contracting is a flexible cooperation model in which a company uses an external IT specialist for a specific project, task or business need. Most often, the contractor works as a B2B entrepreneur, issues invoices, tracks working time and provides services to an agency, end customer or directly to the company. For organizations, this is a fast way to obtain skills without creating a full-time role. For specialists, it means greater independence, potentially higher rates and varied projects. However, the model has risks: liability for errors, confidentiality, intellectual property rights, non-compete clauses, data access, settlement, payment delays, taxes and insurance. From a cybersecurity perspective, an IT contractor is also a supplier with access to systems, so their access, permissions, devices, accounts, logs and offboarding must be managed.

Last updated

July 2026

Who this article is for

  • boards and business owners using IT contractors
  • CIOs, CTOs, CISOs, vCISOs, IT managers and technology supplier owners
  • HR, procurement, legal, compliance and people preparing B2B contracts
  • companies that need cybersecurity, cloud, DevOps, AI, ERP, OT or software development experts quickly
  • SMEs without a large IT department that need an expert for a project
  • software houses, SaaS companies, fintechs, e-commerce, manufacturing, logistics and companies facing customer requirements
  • IT specialists considering B2B or contract work
  • organizations preparing for NIS2, national cybersecurity rules, ISO 27001, DORA, CRA or customer audits

Key takeaways

  1. IT Contracting means using an IT specialist’s skills temporarily in a project-based model.
  2. For a company, it is a way to scale skills quickly. For a contractor, it is a chance for flexibility and higher rates.
  3. Cooperation is often based on B2B and time & material, meaning settlement for actual working time or availability.
  4. The contract should clearly regulate scope, rate, duration, confidentiality, IP rights, non-compete, payments and liability.
  5. From a cybersecurity perspective, a contractor should be treated as a high-risk supplier if they access systems, data, code or infrastructure.

What is IT Contracting?

IT Contracting is a model in which a company uses an external IT specialist for a defined period or for a specific project. The specialist does not have to be an employee. They may work as a B2B entrepreneur, through an outsourcing agency or directly with the customer.

In simple terms: the organization needs expertise, such as DevOps, Cloud Engineer, Security Architect, Java Developer, Data Engineer, SAP Consultant, AI Engineer or Pentester. Instead of running a long full-time recruitment process, it brings in a contractor for a defined period.

In practice, IT Contracting means:

  • project-based cooperation
  • temporary access to a specialist
  • B2B or agency-based settlement
  • often a time & material model
  • more flexibility than full-time employment
  • greater responsibility on the contractor side
  • need for clear access, confidentiality and ownership rules

IT Contracting and IT outsourcing

IT Contracting is sometimes called IT outsourcing, but it is useful to distinguish several models. In outsourcing, a company often delegates an entire process or service to an external provider, such as infrastructure maintenance, SOC, helpdesk or application development. In IT Contracting, the company usually obtains specific specialists to work in a project, often together with the customer’s internal team.

Service outsourcing

  • the company delegates an entire area or function
  • the provider is responsible for service outcome
  • example: SOC as a Service, helpdesk, cloud operations

IT Contracting

  • the company obtains a specific specialist
  • the contractor works in the customer project
  • settlement often depends on working time
  • example: DevOps for 6 months, Security Engineer for NIS2 project, Solution Architect for cloud migration

Body leasing

  • the organization uses specific people provided by an agency
  • the model focuses on resources and availability of skills
  • often used in larger transformation projects

When should a company consider IT Contracting?

1. The project requires skills the company does not have

The company needs a cybersecurity, cloud, DevOps, AI, ERP, OT, data or architecture expert, but does not have such a person in the team. A contractor can quickly fill the gap.

2. The project is temporary

Cloud migration, EDR implementation, NIS2 audit, ISO 27001 project, penetration testing, ERP integration or application modernization does not always justify a full-time role.

3. Recruitment takes too long

Hiring a strong IT specialist can be difficult. IT Contracting shortens time to skills, especially when the company works with an agency that has a candidate pool.

4. The company wants to reduce permanent hiring risk

When demand for skills is uncertain, the contracting model may be more flexible than employment.

5. The company needs an expert for a specific decision

A full team is not always needed. Sometimes a senior expert is needed to design architecture, review a supplier, prepare a roadmap or perform an audit.

IT Contracting in cybersecurity

In cybersecurity, IT Contracting is especially important. Many companies need advanced skills, but do not have the budget or scale for a full-time security team. A contractor can support controls implementation, audits, architecture, incident response, cloud, OT, NIS2, ISO 27001 or security testing.

Typical cyber contract roles

  • Security Architect
  • Cloud Security Engineer
  • DevSecOps Engineer
  • IAM or PAM Consultant
  • Security Analyst
  • Incident Response Specialist
  • GRC Consultant
  • NIS2 or ISO 27001 Consultant
  • OT Security Specialist
  • vCISO or fractional CISO

Typical projects

  • MFA, IAM or PAM implementation
  • EDR, SIEM, SOC or MDR implementation
  • NIS2 and national cybersecurity preparation
  • ISMS development
  • supplier audit
  • penetration testing
  • IT and OT segmentation project
  • secure cloud migration
  • post-incident response
  • ransomware tabletop

Benefits for the company

Fast access to skills

The company can bring in an expert for weeks or months without a long recruitment process. This matters when a project has a regulatory, audit or business deadline.

Cost flexibility

The organization pays for a defined scope, time or project. It does not need to maintain a full-time role when demand is temporary.

Experience from many projects

A strong contractor has worked in different environments and seen many problems. They can quickly recommend practical solutions and avoid mistakes.

Team scaling

The company can temporarily expand the team during migration, audit, tool implementation or a large customer project.

Knowledge transfer

A well-managed contract should leave behind knowledge, documentation, processes and skills in the customer team.

Benefits for the contractor

Higher rates

Mid and senior contractors can often achieve higher hourly rates than employees. However, taxes, social contributions, accounting, breaks, insurance and development are paid from this rate.

More independence

The contractor has more influence over project choice, work mode and specialization development. They can focus on projects that best use their skills.

Project variety

Working with different customers helps build business and technical experience faster.

Remote work

Many IT projects can be delivered remotely. However, availability, time zones, device security and customer requirements must be defined.

Risks for the company

1. Access to systems and data

A contractor often receives access to code repositories, cloud environments, VPN, production systems, databases, logs or documentation. Without access control, serious risk may arise.

2. Unclear accountability

When the project is delayed or an error occurs, the company must know who is responsible: contractor, agency, customer, tool provider or internal process owner.

3. Confidentiality and personal data

A contractor may have access to personal data, customer data, trade secrets, know-how and NDA-protected documents. Confidentiality clauses must be clear and proportionate.

4. IP rights and code

In software development, automation, DevOps and AI projects, it must be clear who owns economic rights to code, scripts, documentation, models, configurations and materials.

5. Offboarding

After the contract ends, access, accounts, tokens, keys, repository access, VPN access, devices and SaaS permissions must be removed.

Risks for the contractor

1. Liability for damage

A B2B contractor may be liable for damage related to service delivery. That is why professional liability insurance and contractual liability limits are worth considering.

2. Project uncertainty

A project may end earlier. The contractor should have a financial reserve and a plan for obtaining new assignments.

3. No typical employment protections

Holiday, illness, breaks and development do not work as in employment. They must be reflected in the rate and contract.

4. Non-compete clauses

An overly broad non-compete clause may limit earning opportunities. Check whether it applies only to the end customer, entire industry, other agencies or a period after cooperation ends.

5. Payments and invoices

The contractor must track time, work acceptance, invoice correctness, payment date and project data required by the agency or customer.

What should be included in the contract?

Service scope

  • project description
  • contractor role
  • general task scope
  • expected outcomes
  • cooperation rules with the customer team
  • place and mode of service delivery

Time and settlement

  • hourly or daily rate
  • time & material or fixed price model
  • time tracking rules
  • work hour approval rules
  • invoice issue date
  • payment date
  • currency and VAT where relevant

Availability and breaks

  • monthly availability
  • working hours
  • time zones
  • days off and breaks in service delivery
  • after-hours availability
  • replacement rules if allowed

Liability

  • liability limit
  • liability for subcontractors
  • liability exclusions
  • contractual penalties
  • required professional liability insurance
  • damage notification procedure

Intellectual property rights

  • what qualifies as a work product
  • when rights are transferred
  • fields of exploitation
  • rights to code, documentation, scripts and configurations
  • rules for using open-source components
  • licence instead of rights transfer, if agreed

Confidentiality and data

  • definition of confidential information
  • duration of confidentiality
  • rules for working with personal data
  • rules for storing customer materials
  • ban on using customer data in private AI tools
  • penalties proportionate to risk and remuneration

Contractor security checklist for the company

Before project start

  • verify contractor identity
  • sign NDA and data processing agreement where needed
  • define minimum security requirements
  • decide whether the contractor uses company or own equipment
  • define VPN, MFA, password and password manager rules
  • check whether contractor has liability insurance for high-risk projects
  • create named account, not a shared account
  • define access end date

During the project

  • apply least privilege
  • monitor access to critical systems
  • require MFA for all accounts
  • log administrative actions
  • review permissions regularly
  • control repository and secret usage
  • verify work through code review and pull requests
  • keep documentation updated

After project completion

  • remove all access
  • delete tokens, API keys and temporary accounts
  • change technical passwords if they were known to the contractor
  • confirm documentation handover
  • confirm rights transfer or licence
  • remove the contractor from groups, repositories and communicators
  • archive time records and acceptance protocols
  • perform short lessons learned

IT Contracting and NIS2, national cybersecurity rules and ISO 27001

IT contractors are part of the technology supply chain. In organizations covered by NIS2, national cybersecurity rules, DORA or ISO 27001, they cannot be treated as random system users. Supplier management, access control, contracts, evidence and incident procedures are needed.

What should be prepared?

  • contractor and IT supplier register
  • contractor risk assessment
  • minimum security requirements in contracts
  • list of systems accessible by contractor
  • access review
  • contractor incident reporting procedure
  • MFA and activity logging evidence
  • offboarding checklist
  • report for audit or customer

How to assess an IT contracting agency?

Experience and specialization

Check whether the agency has experience in a given technology, sector and seniority level. Finding a helpdesk contractor differs from finding SOC, cloud architecture or OT specialists.

Selection process

Ask how the agency verifies technical skills, language, availability, references and project experience.

Formal support

A good agency should have a clear process for contracts, invoices, time approval, payments, communication and project changes.

Security and compliance

The agency should support NDA, confidentiality, GDPR, security clauses, contractor availability and incident procedures.

Cost transparency

The company should understand how much it pays for the specialist, what the margin model is, who is responsible for replacement and what happens when the project ends early.

How to assess an IT contractor?

Technical skills

  • experience in similar projects
  • knowledge of customer technologies
  • certifications where relevant
  • portfolio and references
  • ability to work with documentation

Soft skills

  • communication
  • independence
  • ownership of outcomes
  • work in distributed teams
  • time management
  • ability to escalate issues

Security

  • understanding confidentiality
  • acceptance of MFA and access rules
  • readiness to work on customer equipment
  • secure coding or security basics knowledge
  • awareness of AI and public tool risks
  • willingness to sign NDA and security rules

How should a contractor prepare for B2B?

Formalities

  • set up business activity
  • choose tax treatment after consulting an accountant
  • business bank account
  • invoicing tool
  • accounting
  • working time records
  • professional liability insurance

Finances

  • reserve for taxes and social contributions
  • reserve for breaks between projects
  • days off reflected in the rate
  • accounting, equipment and training costs
  • payment date review
  • clear invoice and time approval process

Development

  • certification plan
  • project portfolio
  • updated LinkedIn profile
  • references
  • awareness of market rates
  • specialization that differentiates on the market

Remote contractor work security

Remote work is one reason why IT Contracting is popular. From a security perspective, it requires clear rules.

Minimum remote work security

  • MFA for all customer systems
  • VPN or secure zero trust access
  • disk encryption
  • updated operating system
  • endpoint protection
  • no shared accounts
  • no copying customer data outside approved environments
  • secure storage of secrets
  • reporting incidents and device loss

Which metrics are worth tracking?

Metrics for the company

  • time to obtain a contractor
  • onboarding time
  • number of contractors with access to critical systems
  • percentage of contractors with MFA
  • number of contractor accounts after project end date
  • number of contractors with signed NDA
  • number of projects completed with full documentation
  • number of incidents or near misses involving suppliers

Metrics for the contractor

  • monthly time utilization
  • invoice timeliness
  • number of days between projects
  • average hourly rate
  • number of projects completed with references
  • number of trainings and certifications per year
  • number of delayed payments

Action plan for a company using IT Contracting

First 30 days

  • define required skills
  • decide whether you need a person, team or full service
  • prepare role description and accountability scope
  • define systems the contractor will access
  • prepare security requirements
  • choose agency or contractor sourcing process
  • prepare NDA and access rules template

Days 31 to 60

  • select the contractor
  • verify skills and references
  • sign contract and project order
  • create named account
  • enable MFA
  • limit permissions to project scope
  • prepare technical and business onboarding
  • define time tracking model

Days 61 to 90

  • perform first work and security review
  • check whether access is still appropriate
  • confirm documentation quality
  • review settlements and invoices
  • assess project risks
  • prepare contract extension or completion plan
  • update contractor and supplier register

Action plan for an IT contractor

First 30 days

  • define specialization and seniority level
  • check market rates
  • choose business form and accounting
  • prepare professional profile and references
  • check insurance requirements
  • define minimum contract terms
  • prepare questions for agency or customer

Days 31 to 60

  • compare agency or customer offers
  • review contract before signing
  • verify intellectual property clauses
  • check non-compete
  • check liability and penalties
  • define days off and availability rules
  • define invoice and time approval process

Days 61 to 90

  • track working time
  • document project decisions
  • protect customer data
  • escalate risks and blockers early
  • collect feedback and references
  • plan the next project in advance

Common company mistakes

Mistake 1: unclear scope

The company hires a contractor but does not define which problem should be solved. The contractor “helps with everything” and the project has no measurable outcome.

Mistake 2: excessive access

The contractor receives administrator access to too many systems because it is faster. This increases incident risk.

Mistake 3: no offboarding

The project ends, but account, VPN, repository access or tokens still work.

Mistake 4: no IP clauses

The company receives code or documentation, but is not sure whether it has full rights to use and develop it further.

Mistake 5: no security requirements in the contract

The contract covers rate and timeline, but not MFA, confidentiality, data, incidents, devices, AI and access.

Mistake 6: treating the agency as a security guarantee

The agency helps source the specialist and handle formalities, but the customer still must control access, data and project risk.

Common contractor mistakes

Mistake 1: signing without reading attachments

The most important risks often sit in attachments: scope, IP rights, non-compete, liability, penalties and confidentiality.

Mistake 2: not including breaks in the rate

The contractor looks only at hourly rate, but does not account for holiday, illness, breaks between projects, training, equipment and taxes.

Mistake 3: no liability insurance

In high-risk projects, one error may cost more than a month of compensation. Insurance does not solve everything, but reduces financial risk.

Mistake 4: working on several projects without checking conflicts

Combining projects may be possible, but non-compete, conflict of interest, confidentiality and real availability must be checked.

Mistake 5: using private tools for customer data

Pasting customer data into private AI tools, private drives, online notebooks or communicators may breach the contract and security rules.

Practical example

A manufacturing company is preparing for NIS2 and wants to implement network segmentation and secure remote access for OT suppliers. It has no internal OT security expert. It decides to hire a contractor for 4 months.

At the start, the company defines the scope: remote access inventory, segmentation review, architecture recommendations, supplier requirements and implementation plan. The contractor receives a named account, MFA, access only to required systems and an NDA. The contract includes confidentiality, rights to documentation, data handling rules, time tracking, liability insurance and cooperation termination terms.

After 90 days, the company has a supplier access map, risk list, segmentation design, remote access procedure, requirements for supplier contracts and board report. The contractor was not just an extra pair of hands. They were a controlled supplier of expertise who left behind measurable value.

Related CCyber resources and services

This topic can be connected with further reading and CCyber services to move from simply hiring a contractor to secure management of access, suppliers and risk.

  • CCyber Blog - related articles on suppliers, NIS2, national cybersecurity rules, vCISO, risk management, audits, MFA, backup, AI and incident response.
  • vCISO - external CISO, strategy, governance, board reporting and supplier risk oversight.
  • EU regulatory compliance - preparation for NIS2, DORA, CRA, ISO 27001 and customer requirements.
  • NIS2 compliance programme - applicability assessment, gap assessment, documentation, evidence, roadmap and audit readiness.
  • Secure IT deployments - support for IT, cloud, AI, OT and e-service projects with security and access in mind.
  • Managed services MSS / MDR / vCISO - monitoring, alert handling, SOC, MDR and expert support.
  • Cybersecurity for SMEs - practical MFA, backup, EDR, policies, training and compliance implementations.
  • Cyber Academy and training - training for boards, IT, project teams, contractors and suppliers.

How can ccyber.io help?

ccyber.io helps organizations use external IT specialists, contractors, agencies, software houses, MSPs, MSSPs and cloud providers securely. We combine governance, cybersecurity, contracts, access, compliance and operations.

We can support your organization with:

  • risk assessment of IT contractors and suppliers
  • minimum security requirements for contractors
  • onboarding and offboarding checklist
  • access control, MFA, IAM and PAM
  • contractor and supplier access review
  • security clauses for supplier contracts
  • incident reporting procedure for contractors
  • assessment of agencies, MSPs, MSSPs, software houses or SaaS providers
  • evidence pack for NIS2, national cybersecurity rules, ISO 27001 or customer audits
  • contractor training on organizational security rules
  • vCISO and oversight of high-risk suppliers
  • 30, 60, 90-day and 12-month roadmap

The best first step is an IT Contractor Security Review. In a short review, the company can determine which contractors have access to critical systems, whether accounts are named, whether MFA works, whether an NDA exists, whether IP rights are organized and whether offboarding actually closes access after the project.

FAQ

What is IT Contracting?

It is a project-based cooperation model where a company uses an external IT specialist for a defined time or task. It is most often based on B2B and time & material settlement.

How is IT Contracting different from employment?

A contractor usually does not have employee status. They often run a business, issue invoices, settle taxes themselves and carry more responsibility for formalities and project continuity.

Is IT Contracting only for seniors?

It usually works best for mid and senior people who are independent, organize time well and can work project-based. Juniors often benefit from employment, where there is more support and learning.

Should the company treat a contractor as a supplier?

Yes, especially when the contractor accesses systems, data, code, infrastructure or production environments. They should be covered by supplier security requirements.

What matters most in the contract?

Service scope, rate, duration, settlement, confidentiality, IP rights, non-compete, liability, insurance, access rules, time tracking and cooperation termination process.

Should a contractor have liability insurance?

It is worth considering, especially in projects where an error could cause downtime, data loss or financial damage. Some customers may require it.

Can a contractor work on several projects?

Yes, if the contract, time, non-compete, confidentiality and conflict-of-interest rules allow it. Real availability for each customer must also be maintained.

Where should the company start?

Start by defining required skills, project scope, system access, security requirements, contract model, onboarding, time tracking and offboarding.

Summary

IT Contracting is a practical way to obtain IT skills when a company needs fast project support, specialist knowledge or flexible team scaling. For contractors, it offers independence, higher rates and varied projects. For companies, it offers faster access to experts without a long employment recruitment process.

However, the model requires maturity. The contract must clearly define scope, settlement, confidentiality, IP rights, non-compete and liability. The company must also remember that a contractor with system access is part of the cyber supply chain. MFA, named accounts, permission limits, logging, access reviews and proper offboarding are needed.

The best rule is: IT Contracting should not be only a fast way to get “extra hands for a project”. It should be a controlled model for obtaining expertise, where the company knows who has access, to what, for how long, under which rules and with what responsibility.

Sources

Is Cybersecurity Slowing AI Adoption? How to Unlock AI Projects Without Increasing Risk

Cybersecurity often slows AI adoption not because it blocks innovation, but because companies lack clear rules, skills, data classification, tool approval processes, supplier controls and accountability models. The biggest risks include shadow AI, data leakage into public tools, lack of output validation, prompt injection, uncontrolled integrations, missing logs, no AI policy and a shortage of experts who combine AI, cybersecurity, legal and business understanding. A good AI security programme does not stop adoption. It accelerates it by giving teams safe rules, an approved tool list, approval paths, monitoring, training and measurable outcomes.

Prepared by: CCyber Editorial Team

Short answer

Cybersecurity can slow AI adoption, but it should not block it. The problem usually does not lie in artificial intelligence itself, but in the lack of rules: who may use AI, for what data, in which processes, with which tools, with what oversight and who is responsible for the output. Companies fear data leakage, wrong answers, prompt injection, shadow AI, GDPR violations, AI Act uncertainty and loss of control over suppliers. At the same time, many organizations lack experts who can combine AI, cybersecurity, legal, compliance and business process knowledge. The solution is not an AI ban, but AI governance: AI policy, data classification, approved tool list, use case approval process, monitoring, training, security testing and clear accountability.

Last updated

July 2026

Who this article is for

  • boards and business owners who want to adopt AI without chaos and data risk
  • CIOs, CTOs, CISOs, vCISOs, AI Leads, CDOs and digital transformation owners
  • SMEs using ChatGPT, Copilot, Gemini, Claude, AI-enabled SaaS or AI agents
  • companies pausing AI projects because of security, GDPR, compliance or expert shortages
  • HR, marketing, sales, finance, customer service and operations teams using AI in daily work
  • IT and security teams that need to enable AI while keeping data under control
  • compliance, legal, DPO, internal audit and risk management teams
  • companies preparing for AI Act, NIS2, national cybersecurity rules, ISO 27001, DORA or customer audits

Key takeaways

  1. Cybersecurity slows AI when a company lacks policy, approval process, data classification and accountability.
  2. The biggest risk is shadow AI, meaning use of AI tools outside organizational knowledge and control.
  3. Expert shortages do not have to stop AI adoption, but they require governance, training, vCISO, AI Lead or external support.
  4. Secure AI requires procedural and technical controls together, not only one document or one tool.
  5. The best AI security programme does not say “AI is forbidden”. It says: when it is allowed, how it is allowed, with which data and who oversees it.

Why does cybersecurity slow AI adoption?

In many companies, AI appeared faster than rules for its use. Employees started using public generative tools to write emails, analyze documents, summarize meetings, create code, compare offers, support customers and prepare reports. Some of these use cases are valuable. Some can be risky.

Security teams often react carefully because they see risks that users do not: personal data, customer data, business information, source code, trade secrets, financial documents, contracts, HR data, medical data, production data and information covered by NDAs.

Most common reasons for blocking AI

  • no AI usage policy
  • no data classification
  • no approved tool list
  • no AI supplier assessment process
  • fear of data leakage into public models
  • no logs and auditability
  • no accountability for AI output
  • lack of experts combining AI, cyber, legal and business
  • regulatory uncertainty, including AI Act and GDPR
  • risk of wrong decisions based on AI answers

The biggest problem: AI is adopted bottom-up

Many companies do not start with an AI strategy. They start with employees who find tools, test them at work and exchange tips. This creates shadow AI. It is natural because the tools are simple, available and often useful. The problem is that the organization loses visibility.

Shadow AI means the company does not know:

  • which AI tools employees use
  • which data is entered into them
  • whether the tool trains on user data
  • where data is stored
  • who has access to prompt history
  • whether AI answers are verified
  • whether AI output reaches customers without review
  • whether the tool meets GDPR, AI Act and customer contract requirements

A ban on AI often makes the situation worse. Employees keep using tools, but outside the official process. A better approach is to create safe paths of use.

AI security is not the same as AI governance

AI security focuses on protecting systems, data, models, integrations and users from threats. AI governance is broader. It includes rules, roles, accountability, risk, compliance, processes, auditability and management oversight.

AI security answers:

  • is data protected?
  • is access controlled?
  • is prompt injection limited?
  • are logs available?
  • are the model and integrations secure?
  • is the AI supplier assessed?

AI governance answers:

  • who may use AI?
  • for which processes?
  • with which data?
  • who approves a new tool?
  • who is responsible for the output?
  • when is legal or DPIA review needed?
  • how do we measure impact and risk?
  • how do we report AI use to the board?

Which AI risks must be controlled?

1. Data leakage

The simplest risk scenario: an employee pastes customer data, a contract, source code, personal data, financial results or internal document into a public AI tool. Even if done in good faith, the company may lose control over information.

2. Wrong answers and hallucinations

AI can generate answers that sound confident but are wrong. The risk increases when AI output is used in legal, financial, HR, medical, technical decisions or customer communication.

3. Prompt injection

Prompt injection means an attacker hides instructions in content that AI is asked to process. If an AI system has access to tools, documents, email, CRM or APIs, it may perform unwanted actions or disclose data.

4. Excessive autonomy of AI agents

AI agents can perform actions, not only generate text. They can send messages, make queries, modify data, launch processes, download files or connect to APIs. The more autonomy, the greater the need for control, logging and approval.

5. Unclear accountability

If AI prepares a wrong analysis, sends a bad recommendation or generates content that breaches confidentiality, the company must know who is accountable: employee, manager, process owner, supplier or AI owner.

6. Supplier risk

AI adoption often means entrusting data to a SaaS, cloud, model or integration provider. Data location, model training terms, retention, logs, subprocessors, incident history, encryption and exit plan must be checked.

7. Legal and contractual breach

AI may touch GDPR, trade secrets, intellectual property, customer contracts, AI Act, sector rules and internal policies. Lack of governance increases breach risk.

Why does lack of experts block AI so strongly?

AI is interdisciplinary. A prompt specialist is not enough. A lawyer is not enough. An IT administrator is not enough. The organization needs a combination of data, security, architecture, legal, process, change management and business skills.

Companies usually need roles such as:

  • AI owner or AI lead
  • CISO or vCISO
  • DPO or privacy expert
  • IT or cloud architect
  • business process owner
  • legal and compliance
  • security engineer
  • training and communication owner
  • board-side risk owner

When these roles are missing, AI becomes “everyone’s and nobody’s project”. That is the easiest path to chaos, shadow AI and AI projects blocked by security.

How to unlock AI without increasing risk?

The company should implement a model that works like a safe highway for AI. Employees know which vehicles they can use, how fast, which lanes are allowed and where emergency exits are. Without this, everyone drives their own route.

Minimum AI governance model

  • AI usage policy
  • data classification
  • approved, conditionally approved and prohibited tool list
  • new use case submission process
  • AI risk assessment
  • AI supplier assessment
  • human oversight rules
  • logging and audit rules
  • employee training
  • board reporting

AI policy: a document that should help, not scare

A good AI policy should be short, practical and understandable. It should not only list prohibitions. It should show how to use AI safely in everyday work.

An AI policy should answer:

  • which AI tools can be used?
  • which data must not be entered?
  • when must a company tool be used instead of a public tool?
  • when is IT, legal or DPO approval required?
  • can AI output be sent to customers?
  • when is human verification required?
  • how should an AI incident be reported?
  • how should AI-generated content be labelled where required?

Example simple rule

Do not enter personal data, customer data, trade secrets, source code, NDA-covered documents, financial data, medical data or any information we would not publish outside the company into public AI tools.

Data classification for AI

Without data classification, employees do not know what is safe and what is risky. Classification does not have to be complex. Four levels are enough to start.

Level 1: public data

Data that can be published on the company website. It may be used in AI tools if it does not contain personal data or secrets.

Level 2: internal data

Data used inside the company, but without high confidentiality. It may be used in approved company tools if the policy allows it.

Level 3: confidential data

Customer data, pricing, contracts, strategy, financial reports, projects, HR data and NDA-covered documents. Requires approved tools, access controls and often legal review.

Level 4: sensitive and critical data

Medical data, special category data, technology secrets, source code, security data, critical production data and regulated information. Requires a special approval path or prohibition unless a dedicated architecture is used.

AI tool list: green, yellow and red

The company should create a simple AI tool list. Employees must know which tools are approved, which require approval and which cannot be used.

Green tools

  • approved by IT and security
  • covered by a company agreement
  • have defined data rules
  • have logging and access control
  • have training on company data disabled where required

Yellow tools

  • can be used after assessment of a specific use case
  • require process owner approval
  • may require DPO, legal or security assessment
  • may have data restrictions

Red tools

  • do not have clear data processing terms
  • train on user data without control
  • do not provide logs or access controls
  • do not have acceptable legal terms
  • are not approved for company use

AI use case approval process

Not every AI project needs months of analysis. The process should be proportionate to risk. A simple chatbot for general marketing ideas is a different risk level than AI analyzing customer data or making HR decisions.

The process should include:

  • business objective description
  • input data description
  • tool or supplier description
  • risk classification
  • GDPR and confidentiality assessment
  • supplier security assessment
  • human oversight rules
  • test plan
  • success metrics
  • business owner

AI Act: what should a company know practically?

The AI Act uses a risk-based model. Most simple AI uses will have minimal or limited risk. Some use cases may fall into high-risk areas, especially when AI affects employment, evaluation of people, education, access to services, healthcare, safety or critical infrastructure.

Practical AI Act checklist

  • do we know where AI is used in the company?
  • do we classify AI systems by risk?
  • could any use case be high-risk?
  • do we have human oversight?
  • do we log system use?
  • do we inform users when required?
  • do we assess AI suppliers?
  • do we have documentation and evidence?
  • do we train employees on AI usage rules?

AI security in technical practice

1. Access control

AI tools should use company login, MFA, roles, groups, administrator controls and access removal after employee departure.

2. Data protection

The company must define which data may be processed, whether it is encrypted, whether it leaves the EEA, whether it may be used for training and how long it is stored.

3. Logging and audit

The organization should know who uses the tool, when, with which data and in which process. Without logs, audit and incident response are difficult.

4. DLP and paste control

DLP can help detect confidential data being entered into AI tools. It does not replace training and clear policy.

5. Isolation and least privilege for agents

AI agents should have minimum permissions, limited API access, action control, approval of critical operations and logging.

6. AI security testing

Internal AI applications should be tested for prompt injection, data disclosure, improper output handling, excessive autonomy and integration vulnerabilities.

Prompt injection: why is it different from classic vulnerabilities?

In classic applications, it is easier to separate instructions from data. In LLM systems, this boundary may be blurred because the model processes instructions and content in one context. A document, email, web page or CRM record may contain a hidden instruction that affects AI behaviour.

How to limit prompt injection?

  • do not trust input from external sources
  • limit model access to data and tools
  • apply least privilege
  • require human approval for high-risk actions
  • separate contexts and data sources
  • test AI applications with red team scenarios
  • log prompts, answers and tool actions
  • do not use LLMs for uncontrolled critical operations

How to train employees on AI security?

Training should be practical and role-based. Marketing, HR, finance, IT, sales and the board need different rules.

General training for everyone

  • what shadow AI is
  • which data is forbidden in public tools
  • how to verify AI answers
  • how to label AI content where needed
  • how to report an AI incident

Training for managers

  • how to assess an AI use case idea
  • how to measure business impact
  • how to recognize data risk
  • when to escalate to security, legal or DPO
  • how not to pressure teams into bypassing rules

Training for IT and security

  • AI supplier assessment
  • logging and integrations
  • DLP and access control
  • prompt injection testing
  • private AI or enterprise AI architecture
  • AI agent monitoring

How to measure whether AI is adopted safely?

Governance metrics

  • number of registered AI use cases
  • number of approved and prohibited tools
  • percentage of use cases with business owner
  • number of use cases after risk assessment
  • number of exceptions accepted by the board

Security metrics

  • number of detected shadow AI uses
  • number of AI-related incidents
  • number of attempts to enter confidential data into AI
  • number of AI tools with MFA and logging
  • number of AI applications after security testing

People metrics

  • percentage of employees trained in AI security
  • number of managers trained in AI governance
  • number of safe AI use questions reported
  • number of teams with an AI champion

Business impact metrics

  • number of processes improved by AI
  • time saved in pilot processes
  • number of production deployments after pilots
  • number of projects stopped because of risk
  • number of projects unlocked after controls were implemented

30, 60 and 90-day action plan

First 30 days

  • assign AI governance owner
  • identify AI tools used in the company
  • perform quick shadow AI review
  • prepare temporary AI policy
  • introduce simple data classification for AI
  • define approved and prohibited tools
  • launch AI questions and reporting channel
  • present first AI risk map to the board

Days 31 to 60

  • develop target AI policy
  • create approval process for new use cases
  • assess key AI tool suppliers
  • launch employee AI security training
  • define human oversight rules
  • define logging and audit requirements
  • prepare AI risk assessment template
  • select 2-3 safe AI pilots

Days 61 to 90

  • test AI pilots with real users
  • perform security testing of AI applications
  • implement monitoring of approved tools
  • prepare AI incident procedure
  • define AI KPIs and KRIs
  • prepare board report
  • approve 12-month AI security roadmap
  • define budget for tools, training and expert support

Common AI adoption mistakes

Mistake 1: ban without alternative

The company bans AI, but provides no safe tool or clear approval path. Employees move to shadow AI.

Mistake 2: AI policy written in legal language

The document is formally correct, but the employee still does not know whether they may paste an offer, customer email or code fragment into an AI tool.

Mistake 3: no owner

AI is simultaneously an IT, business, HR, legal and security matter. In practice, nobody makes decisions.

Mistake 4: no data classification

Without simple data levels, users guess what is confidential. This leads to mistakes.

Mistake 5: no AI supplier assessment

The company buys a tool, but does not check what happens to data, logs, subprocessors and prompt history.

Mistake 6: no output verification

AI generates an answer that reaches a customer, decision or report without human review.

Mistake 7: no security testing

The company builds an AI application with access to data and APIs, but does not test prompt injection, output handling and excessive autonomy.

Mistake 8: measuring number of tools instead of outcomes

The board hears that the company has AI, but does not know which processes improved, what risks appeared and how many projects are in production.

How not to kill innovation with rules?

AI governance should not be bureaucracy. Good rules unlock adoption because employees know what they can do. Security stops being the function that says “no” and becomes the partner that gives a safe path.

Good rules are:

  • simple
  • role-based
  • proportionate to risk
  • understandable for employees
  • supported by tools
  • measured
  • regularly updated

A bad rule says:

Do not use AI.

A good rule says:

You may use approved AI tools for public and internal data. Confidential data requires a company-approved tool and process owner approval. Sensitive data requires separate legal, DPO and security assessment.

Practical example

A services company has 220 employees. Marketing uses generative tools to create content. HR tests AI for CV analysis. Sales uses AI to prepare offers. IT launches Copilot. Legal learns that fragments of contracts were pasted into public tools. Security wants to block all AI tools.

The board chooses a middle path. The company creates an AI policy, data classification, approved tool list, use case approval process and employee training. HR pauses automated CV assessment until legal and risk review is completed. Marketing receives clear rules on what data it may use. Sales receives prompt templates without customer data. IT implements logging and access control for company tools.

After 90 days, the company has no chaos. It has 12 approved use cases, 3 high-risk projects paused, 80% of employees trained, tool list, risk register and board report. AI was not blocked. It was governed.

Related CCyber resources and services

This topic can be connected with further reading and CCyber services to move from fear of AI to a safe adoption programme.

  • CCyber Blog - related articles on AI security, shadow AI, prompt injection, AI governance, NIS2, national cybersecurity rules, training, MFA, backup and suppliers.
  • AI Security - AI risk assessment, AI policy, shadow AI control, AI application security testing and governance.
  • Secure IT deployments - AI, cloud, SaaS and e-service deployments with security, access and compliance in mind.
  • EU regulatory compliance - preparation for NIS2, DORA, CRA, AI Act, ISO 27001 and customer requirements.
  • vCISO - external CISO, strategy, governance, board reporting and oversight of AI and cyber risk.
  • Managed services MSS / MDR / vCISO - monitoring, alert handling, SOC, MDR and operational security support.
  • Cyber Academy and training - training for employees, boards, IT, security, AI owners and business teams.

How can ccyber.io help?

ccyber.io helps companies adopt AI without increasing data, compliance and cybersecurity risk. We do not start with prohibitions. We start with an AI usage map, data classification, risks, business processes and rules that let teams use new tools safely.

We can support your organization with:

  • AI security assessment
  • shadow AI discovery
  • AI usage policy
  • data classification for AI
  • AI use case approval process
  • AI and SaaS supplier assessment
  • mapping AI to AI Act, GDPR, NIS2, national cybersecurity rules and ISO 27001
  • prompt injection and AI application security testing
  • secure AI architecture design
  • AI usage monitoring and logging
  • AI security training for employees, managers and IT
  • AI incident tabletop
  • board report and 12-month AI security roadmap

The best first step is an AI Security and Governance Workshop. In a short workshop, the company can determine where AI is used, which data is most risky, which use cases should be unlocked, which should be paused and which rules should be implemented in the first 90 days.

FAQ

Does cybersecurity really slow AI adoption?

Yes, but often because the company lacks rules, data classification, approval process and accountability. Good cybersecurity does not block AI. It creates safe conditions for deployment.

What is shadow AI?

Shadow AI means using AI tools outside organizational knowledge and control. It most commonly involves public chatbots or AI plug-ins used with company data without approval from IT, security or legal.

Is writing an AI policy enough?

No. A policy is needed, but it must be supported by training, tool list, data classification, supplier assessment, monitoring and use case approval process.

Should the company ban public AI tools?

Not always. It is better to define which data and tasks they may be used for and which they cannot. Confidential data usually requires approved company tools or a dedicated architecture.

What is prompt injection?

It is an attack where external content contains hidden instructions affecting the AI model’s behaviour. The risk increases when AI has access to documents, email, APIs or can perform actions.

Does AI Act apply to every company?

The AI Act uses a risk-based model. Obligations depend on whether the company is a provider or deployer, which system it uses and whether the use case is minimal, limited, high-risk or prohibited.

Who should own AI governance?

It is usually shared by AI owner, IT, security, legal, DPO and business. However, there must be one person or committee that makes decisions and reports to the board.

Where should we start?

Start with AI usage mapping, data classification, temporary AI policy, approved tool list, employee training and a process for assessing new use cases.

Summary

Cybersecurity does not have to slow AI adoption. It can unlock it if the company builds clear usage rules, data classification, approval paths, supplier assessment, monitoring and training. The biggest problem is not the technology itself, but lack of governance.

Companies that ban AI without alternatives risk shadow AI. Companies that adopt AI without rules risk data leaks, wrong decisions, regulatory issues and loss of trust. The best organizations choose the third path: secure AI adoption with clear rules, human oversight and measurable outcomes.

The best rule is: do not ask only whether AI is secure by itself. Ask whether your company knows who uses AI, for what, with which data, who is accountable for the output and which controls work when something goes wrong.

Sources

NIS2 for Polish SMEs: A Simple Explanation and 5 Quick Wins to Implement Now

NIS2 and the amended Polish national cybersecurity rules are not only a topic for large corporations. Many SMEs may be affected directly or indirectly through customer, insurer, bank, investor and larger contractor requirements. A company should first check whether it operates in a covered sector, meets size criteria and must register in the national cybersecurity register. Then it should implement 5 quick wins: MFA, backup with restore testing, patching and EDR, phishing training and a simple incident procedure. The key conclusion: NIS2 does not require perfection from day one, but it does require real risk management, evidence and board decisions.

Prepared by: CCyber Editorial Team

Short answer

NIS2 and Polish national cybersecurity rules mean that many companies must approach cybersecurity more systematically. This is not only about buying antivirus software or writing a policy. A company should know whether it is in scope, which services and systems are critical, who owns risk, how backup works, whether accounts have MFA, how to report an incident and which evidence it can show to a customer, auditor, insurer or regulator. For SMEs, the most reasonable approach is to start with simple, effective actions: MFA, backup and restore testing, patching and EDR, phishing training, incident procedure and supplier assessment. NIS2 should not be a paperwork project. It should increase resilience against real attacks.

Last updated

July 2026

Who this article is for

  • SME owners and boards who want to understand NIS2 without legal language
  • companies unsure whether they fall under national cybersecurity rules as essential or important entities
  • IT providers, SaaS companies, MSPs, software houses, e-commerce, logistics, manufacturing, healthcare, food and retail
  • companies receiving security questionnaires from large customers
  • organizations preparing for cyber insurance, ISO 27001, customer audit or due diligence
  • CIOs, CTOs, IT managers, administrators and people responsible for security in small teams
  • compliance, legal, DPO, risk, audit and compliance evidence owners
  • companies that want to implement minimum security before a larger cyber programme

Key takeaways

  1. NIS2 expands the range of organizations that must manage cyber risk and report significant incidents.
  2. In Poland, practical obligations come from national cybersecurity rules, so a company should check sector, size, exceptions and registration duties.
  3. SMEs may be affected directly or indirectly through requirements from customers, banks, insurers and larger contractors.
  4. The best start is 5 quick wins: MFA, backup with restore testing, patching and EDR, phishing training and an incident procedure.
  5. Evidence matters most: MFA report, restore test, access review, training report, risk register and board decisions.

What is NIS2 in simple terms?

NIS2 is the EU directive on cybersecurity of network and information systems. Its goal is simple: raise cyber resilience in sectors important for the state, economy and citizens. The directive does not tell every company to buy a specific product. It requires covered organizations to manage risk, implement appropriate security measures, report serious incidents and involve management.

For Polish companies, the most important element is the amendment to national cybersecurity rules implementing NIS2. These rules define practical obligations, deadlines, the national register, incident reporting through S46, ISMS, audits and supervision.

What changes for companies?

Polish national cybersecurity rules expand the catalogue of entities covered by obligations. Previously, many organizations were not formally part of the national cybersecurity system. Now more companies must independently check whether they fall into scope.

Key changes

  • division into essential and important entities
  • wider list of sectors covered by obligations
  • obligation to assess own status
  • national register and self-registration for some entities
  • S46 system for statutory duties, including incident reporting
  • ISMS implementation
  • incident reporting to CSIRT
  • management accountability
  • audits for selected essential entities
  • possibility of penalties for non-compliance after transition period

Does NIS2 apply to SMEs?

It depends. NIS2 and national rules do not automatically cover every small company. Sector, company size, service type, role in the supply chain and exceptions must be checked. Some entities may be covered regardless of size, while others may feel the regulation indirectly through customer requirements.

The company should check four questions

  • Sector: whether it operates in an essential or important sector, such as healthcare, transport, energy, water, wastewater, digital infrastructure, ICT service management, manufacturing, food, waste, chemicals, digital services or public administration.
  • Size: whether it meets medium or large company criteria.
  • Exception: whether it is covered regardless of size due to a specific digital or communication service type.
  • Supply chain: whether a larger customer requires cybersecurity evidence, even if the company is not formally in scope.

Indirect impact: the most common SME trap

Many SMEs say: “NIS2 does not apply to us because we are too small”. This may be true formally, but not always commercially. A large customer covered by NIS2 may require suppliers to have certain safeguards. A bank, insurer, investor, auditor or contractor may ask about MFA, backup, EDR, incident procedure, training and supplier assessment.

Requirements may appear in:

  • customer security questionnaires
  • contracts and security annexes
  • supplier audits
  • cyber insurance process
  • investor due diligence
  • public and private tenders
  • corporate group requirements

NIS2, national rules, GDPR, DORA and cyber insurance: how to connect them?

The company should not build separate programmes for every regulation. In practice, many requirements repeat: risk, access, backup, incidents, suppliers, training, evidence and reporting. A good approach is to create one cyber resilience programme that supports multiple obligations.

Common elements

  • risk register
  • asset register
  • access control and MFA
  • backup and restore testing
  • incident procedure
  • supplier assessment
  • employee training
  • board reporting
  • delivery evidence

Different regulations may have different definitions, deadlines and thresholds, but the operational foundation is similar. For SMEs, this is good news: practical safeguards can help in many areas at once.

5 quick wins for SMEs

Quick win 1: Enable MFA where risk is highest

MFA, or multi-factor authentication, is one of the simplest and most effective actions. Start with email, administrators, VPN, cloud, backup, finance systems and supplier accounts.

MFA minimum

  • business email
  • Microsoft 365 or Google Workspace
  • VPN and remote access
  • administrator accounts
  • backup panel
  • CRM, ERP and finance system
  • controlled supplier accounts

Evidence

  • MFA account report
  • MFA exception list
  • administrator MFA confirmation
  • supplier remote access MFA confirmation

Case study: how could MFA reduce a real breach?

The Medibank case is a useful example. The Australian regulator alleged that lack of MFA on VPN access allowed the attacker to use stolen credentials and access the network. The incident led to data of millions of people being published on the dark web. This shows that MFA is not an “extra”. It is a control that often separates stolen credentials from real environment compromise.

The lesson for SMEs is simple: even if the company does not have a mature SOC, it can quickly reduce account takeover risk by enabling MFA. Phishing-resistant methods are best for critical accounts, such as security keys, passkeys or apps with number matching. SMS is better than no MFA, but should not be the target standard for critical accounts.

Quick win 2: Make backup and test restore

Backup without restore testing is a declaration, not resilience. The company should know what is backed up, where copies are stored, who has access, whether backup is ransomware-resistant and how long it takes to restore a critical system.

What to check?

  • whether backup covers critical systems
  • whether backup is separated from ordinary administrator accounts
  • whether the backup account has MFA
  • whether copies are protected from deletion
  • when the latest restore test was performed
  • how long it takes to restore email, files, ERP, CRM or production system

Evidence

  • backup report
  • restore test report
  • list of systems covered by backup
  • RTO and RPO for critical systems

Quick win 3: Patching, EDR and vulnerabilities

Many attacks start with a known vulnerability or infected computer. An SME should have a basic patching process, endpoint protection and a review of internet-facing systems.

What to do?

  • check internet-facing systems
  • update VPN, firewalls, servers and CMS
  • enable EDR or strong endpoint protection
  • remove unused services and accounts
  • scan vulnerabilities periodically
  • set remediation deadlines for critical vulnerabilities

Evidence

  • patching report
  • EDR report
  • vulnerability report
  • list of public-facing systems
  • remediation action list

Quick win 4: Phishing training and reporting channel

Phishing, BEC and AI scams are everyday risks for SMEs. Training should be short, practical and repeated. The most important point is that employees know how to report suspicious messages without fear of punishment.

Training should cover:

  • phishing and fake login pages
  • fake invoices and bank account changes
  • BEC, or CEO and contractor fraud
  • safe MFA use
  • AI scams, deepfake and voice phishing
  • reporting suspicious messages

Evidence

  • participant list
  • training materials
  • knowledge test results
  • phishing simulation report
  • number of suspicious messages reported

Quick win 5: Simple incident procedure

During an incident, there is no time to decide who makes decisions, who calls the provider, who reports the incident and who informs customers. An SME should have a simple procedure that can be activated in the first hour.

The procedure should include:

  • what counts as an incident
  • who receives the report
  • who classifies the incident
  • who contacts the IT provider
  • who informs the board
  • who communicates with customers
  • who assesses GDPR and notification duties
  • how to document the incident timeline

Evidence

  • incident response plan
  • emergency contact list
  • incident timeline template
  • tabletop report
  • post-exercise action list

What does NIS2 mean for the board?

NIS2 and national rules strengthen management accountability. The board does not need to know every technical detail, but it must understand risk, approve priorities, ensure budget and require reporting. Cybersecurity is no longer only the IT administrator’s task.

The board should ask:

  • do we know whether we are in scope?
  • which systems are critical for company operations?
  • do critical accounts have MFA?
  • has backup been tested?
  • do we have an incident procedure?
  • do IT suppliers have controlled access?
  • do employees know how to report phishing?
  • do we have evidence for a customer, audit or insurer?

Which documents should be prepared first?

An SME does not need to start with a huge document system. It is better to prepare a small practical pack answering the most common questions from customers, insurers and auditors.

Minimum pack

  • NIS2 and national cybersecurity applicability assessment
  • critical systems and services register
  • cyber risk register
  • password, MFA and access policy
  • backup policy
  • incident response plan
  • incident reporting procedure
  • critical supplier register
  • digital hygiene training plan
  • board report

Which compliance evidence matters most?

Evidence is more important than declarations. A customer, auditor or insurer does not only want to hear that the company has security. They want to see that the process works.

Key evidence

  • MFA report
  • backup report
  • restore test report
  • EDR or endpoint protection report
  • access review
  • supplier assessment
  • employee training report
  • incident and near miss register
  • tabletop report
  • remediation action list

Cyber budget for SMEs: is 15% of IT budget a good benchmark?

Various market reports mention averages for the share of cybersecurity in IT budgets. Treat these carefully. For one company, 15% of IT budget may be too little, for another too much. A good budget does not come from one average. It comes from risk, sector, number of systems, customer requirements, incident history, insurance and downtime cost.

How to plan the budget practically?

  • first estimate the cost of one day of downtime
  • identify critical systems
  • check customer and regulatory requirements
  • separate one-off and recurring costs
  • start with MFA, backup, EDR, training and procedures
  • plan maintenance, not only implementation
  • measure outcomes, not purchased licence count

Common SME mistakes

Mistake 1: assuming NIS2 applies only to large companies

Formally, many small companies may not be directly in scope, but requirements can come from customers, insurers and partners.

Mistake 2: buying a tool instead of solving a problem

A tool without owner, configuration, monitoring and procedure does not create resilience.

Mistake 3: backup without restore testing

The company has copies, but does not know whether and how quickly it can restore a critical system.

Mistake 4: MFA only for some users

First protect administrator accounts, email, VPN, backup and suppliers. These are common entry points.

Mistake 5: no control over IT provider

The provider has system access, but the company does not know whether MFA, named accounts, action logging and incident reporting procedure are in place.

Mistake 6: incident procedure only on paper

A document is not enough. Run a tabletop and check whether the company knows what to do in the first hour.

Mistake 7: no board reporting

The board must see risks, decisions, budget and action progress. Without this, cyber remains an IT problem.

30, 60 and 90-day action plan

First 30 days

  • assign cybersecurity owner on the board side
  • check whether the company may be in scope of national rules and NIS2
  • identify critical systems and services
  • enable MFA for email, administrators, VPN and backup
  • check backup status
  • collect critical supplier list
  • launch a simple phishing reporting channel
  • prepare first risk report for the board

Days 31 to 60

  • perform restore test for a critical system
  • prepare a simple cyber risk register
  • perform access review for critical accounts
  • update internet-facing systems
  • enable EDR or review current endpoint protection
  • assess key IT and SaaS suppliers
  • run phishing training
  • prepare incident response plan

Days 61 to 90

  • run ransomware or email takeover tabletop
  • prepare evidence pack for customer or insurer
  • define RTO and RPO for critical systems
  • update supplier contracts with security clauses
  • close key high-risk gaps
  • define board metrics
  • approve 12-month cyber roadmap

Metrics for the SME board

Protection metrics

  • percentage of critical accounts with MFA
  • date of latest restore test
  • percentage of devices covered by EDR
  • number of overdue critical vulnerabilities
  • number of critical systems without owner

People metrics

  • percentage of employees trained
  • phishing simulation result
  • number of suspicious messages reported
  • number of people who know the incident procedure

Supplier metrics

  • number of critical suppliers assessed
  • number of suppliers with remote access
  • number of suppliers without MFA
  • number of contracts without security clauses

Compliance metrics

  • status of national cybersecurity applicability assessment
  • number of requirements with owner
  • number of requirements with evidence
  • number of overdue remediation actions

Practical example

A services company has 85 employees and provides software to large customers in manufacturing and logistics. It is unsure whether it falls directly under national cybersecurity rules, but receives security questionnaires from customers. Questions cover MFA, backup, restore testing, EDR, suppliers, incident procedure and training.

The first review shows that MFA works only for some employees, backup has not been tested for a year, the IT provider has remote access without regular access review and the incident procedure is outdated. The company does not immediately need a full SOC or advanced GRC. It needs a 90-day plan.

After three months, the company has MFA for critical accounts, restore test, risk register, incident response plan, phishing training, IT supplier assessment and board report. It can answer customers with concrete evidence, not a declaration that “security is important”.

Related CCyber resources and services

This topic can be connected with further reading and CCyber services to move from understanding NIS2 to practical implementation of security basics.

How can ccyber.io help?

ccyber.io helps SMEs translate NIS2 and national cybersecurity rules into a practical action plan that can be implemented without chaos and random purchases. We start with risk, critical systems and evidence, then select tools and providers.

We can support your organization with:

  • NIS2 and national cybersecurity applicability assessment
  • NIS2 and national cybersecurity gap assessment for SMEs
  • implementation of MFA, backup, EDR and cyber hygiene foundations
  • restore testing and recovery plan
  • incident response plan and ransomware playbook
  • assessment of IT, SaaS, cloud and managed service suppliers
  • cyber risk register and asset register
  • evidence pack for customer, audit or insurer
  • phishing, BEC, MFA and AI scams training
  • vCISO and board reporting
  • 30, 60, 90-day and 12-month roadmap

The best first step is a NIS2 Quick Wins Workshop for SMEs. In a short workshop, the company can check whether it is in scope, which quick wins to implement immediately, which evidence to prepare and how to plan the budget for the next 12 months.

FAQ

Does every small company fall under NIS2?

No. Sector, size, service type and exceptions must be checked. Even if the company is not directly in scope, it may receive requirements from larger customers.

Is antivirus enough?

No. Antivirus or EDR is only one element. The company needs MFA, backup, restore testing, incident procedure, training, supplier assessment and evidence.

What should be done first?

Enable MFA on critical accounts, check backup, perform restore test, update systems, launch phishing training and prepare a simple incident procedure.

Does MFA really make such a big difference?

Yes. Microsoft research shows MFA is highly effective in reducing account compromise. Phishing-resistant MFA is best for critical accounts.

Is backup enough against ransomware?

Backup is necessary, but not enough. It must be deletion-resistant, protected by MFA, tested and connected with a recovery procedure.

Does NIS2 require a full SOC?

Not always. It requires detection, response and risk management proportionate to the organization. An SME may start with baseline monitoring, EDR, MDR or provider support.

Which evidence matters most for a customer?

MFA report, restore test, EDR report, risk register, incident procedure, training report, supplier assessment and remediation action list.

Where should applicability assessment start?

Start by checking sector, company size, services, customer relationships and exceptions. Then prepare a board decision and action plan.

Summary

NIS2 and national cybersecurity rules change how Polish companies should think about cybersecurity. It is not only about new legal requirements, but about real resilience against attacks that can stop operations, compromise data, disrupt deliveries or block customer communication.

For SMEs, the best approach is practical: MFA, backup, restore test, EDR, updates, training, incident procedure, supplier assessment and evidence. These actions help with NIS2, national cybersecurity rules, cyber insurance, customer audits and everyday security.

The best rule is: do not start by asking how to satisfy NIS2 on paper. Start by asking what would stop your company during an attack and which five actions you can implement now to reduce the impact.

Sources

Fractional CISO and vCISO for SMEs: When Does Part-Time Cyber Leadership Make Sense?

A fractional CISO or vCISO is a solution for companies that need experienced cybersecurity leadership but are not ready for a full-time CISO. The model works especially well for SMEs, growing companies, organizations preparing for NIS2, national cybersecurity rules, ISO 27001, cyber insurance, customer audits, M&A or post-incident recovery. A good fractional CISO is not only a documentation consultant. They should work with the board, build strategy, risk register, roadmap, budget, reporting, incident procedures, supplier assessment, training and compliance evidence. The key is to define scope, authority, availability, SLA and outcome metrics clearly.

Prepared by: CCyber Editorial Team

Short answer

A fractional CISO is an experienced cybersecurity leader who acts as a CISO on a part-time or contract basis. In Poland, the term vCISO is also commonly used for an external CISO supporting the organization strategically and operationally. This model is especially useful for SMEs that do not yet need a full-time CISO, but need accountability, strategy, board reporting and oversight of cyber risk. A good fractional CISO helps the board translate cybersecurity into business language: risk, budget, priorities, compliance, evidence, business continuity and decisions. They do not replace the IT administrator, SOC, lawyer or every supplier. They connect their work into one cyber resilience programme.

Last updated

July 2026

Who this article is for

  • boards and SME owners without a full-time CISO
  • companies preparing for NIS2, national cybersecurity rules, DORA, CRA, ISO 27001 or cyber insurance
  • organizations after an incident, audit, customer questionnaire or investor requirement
  • CIOs, CTOs, IT managers and administrators who need board-level support
  • compliance, risk, legal, DPO, internal audit and compliance evidence owners
  • growing companies, SaaS, software houses, fintechs, manufacturing, healthtech, e-commerce and logistics
  • companies preparing for M&A, due diligence or expansion to new markets
  • companies that want to organize cyber budgets and avoid buying tools without strategy

Key takeaways

  1. A fractional CISO gives a company access to senior cyber leadership without the cost of a full-time function.
  2. The model works best when the company has real risks, customer requirements or regulation, but no mature security function yet.
  3. A vCISO should work with the board, not only with IT.
  4. The key outcomes are strategy, risk register, roadmap, budget, procedures, evidence, training and reporting.
  5. The biggest risks are unclear scope, lack of authority, no SLA and treating vCISO as a documentation person instead of a programme leader.

What is a fractional CISO?

A fractional CISO is a senior cybersecurity leader working with an organization part-time, usually under a contract or subscription model. They may work several days per month, one day per week, two days per week or more intensively during an audit, incident or compliance programme.

In practice, a fractional CISO should be responsible for cyber leadership, not every technical configuration. This person helps the board understand risk, set priorities, oversee suppliers, prepare an action plan, measure outcomes and make decisions about risk acceptance.

A fractional CISO usually:

  • attends board or risk committee meetings
  • creates cybersecurity strategy
  • maintains cyber risk register
  • builds an action roadmap
  • oversees IT and security suppliers
  • prepares board reports
  • supports NIS2, national rules, ISO 27001 or cyber insurance preparation
  • supports incident response and tabletop exercises
  • helps build security culture

Fractional CISO, vCISO, security consultant and full-time CISO: what is the difference?

The terms are often used interchangeably, but they are worth separating. A company should know whether it is buying advice, programme leadership, virtual CISO service or a full-time management function.

Fractional CISO

A specific experienced leader who acts as CISO for a defined part of time. Usually has personal responsibility for board advisory, strategy and cyber programme coordination.

vCISO

vCISO is often an external CISO service delivered by one person or an expert team. It may include strategy, governance, reporting, audits, procedures, operational support and implementation oversight.

Security consultant

A consultant may prepare analysis, report, policy, audit or recommendations. However, they may not always have an ongoing role in managing the programme, reporting to the board and driving decisions.

Full-time CISO

A full-time CISO is an internal cybersecurity leader. This person has the highest availability, organizational context and ongoing accountability, but is more expensive and harder to hire.

When does a fractional CISO make the most sense?

1. The company is too small for a full-time CISO

Many SMEs need cyber leadership, but do not yet have the scale to hire a full-time CISO. A fractional CISO provides senior competence without the fixed employment cost.

2. The board started asking about cyber, but IT does not speak risk language

An IT administrator may know which systems are vulnerable, but not always how to translate that into downtime cost, customer impact, budget decision and board accountability. A vCISO bridges IT and business.

3. The company is preparing for NIS2 or national cybersecurity rules

NIS2 and national rules require risk management, management accountability, incident reporting, supplier oversight, training and evidence. A vCISO can organize compliance and avoid chaotic purchases.

4. Customers send security questionnaires

More large customers ask suppliers about MFA, backup, EDR, ISO 27001, SOC, incident procedures, penetration tests and cyber insurance. A vCISO helps prepare answers and evidence.

5. The company is after an incident

After ransomware, data leakage or email takeover, the board often wants to organize security quickly. A fractional CISO can help move from firefighting to a remediation programme.

6. The company is preparing for M&A or investors

Due diligence increasingly covers cybersecurity. A vCISO can prepare evidence pack, risk map, remediation plan and investor answers.

7. The organization has too many tools and consultants

After years of purchases, a company may have EDR, backup, firewall, SIEM, tests, audits and several advisory firms, but no coherent programme. A vCISO rationalizes the stack and checks what actually works.

When may a fractional CISO be insufficient?

The fractional model is not for everyone. If an organization has a very complex environment, many active incidents, global scale, high security maturity or needs daily management of a large team, a full-time CISO may be more appropriate.

A full-time CISO may be better when:

  • the company has many plants, jurisdictions and regulated sectors
  • the security team is large and requires daily management
  • the organization has continuous high-risk incidents
  • the board needs constant CISO availability
  • the company is a major critical infrastructure operator
  • the cyber programme is already mature and needs a full-time leader

Risks of the fractional model

  • limited availability
  • no exclusivity
  • scope that is too broad
  • lack of decision-making authority on the customer side
  • unclear split of responsibility between vCISO, IT and suppliers
  • difficulty responding 24/7 without separate incident response or SOC service

Which tasks should a vCISO have?

The scope should match organizational maturity. A vCISO in a small SaaS company, manufacturing plant, healthcare provider or ISO 27001 preparation project will have different tasks.

Governance and strategy

  • cybersecurity strategy
  • accountability model and RACI
  • security policies
  • recurring board reporting
  • risk appetite definition
  • cyber budget and roadmap

Risk and compliance

  • applicability assessment for NIS2, national rules, DORA, CRA or ISO 27001
  • cyber risk register
  • risk treatment plan
  • evidence repository
  • preparation for customer or regulator audit
  • supplier compliance assessment

Technical minimum

  • prioritization of MFA, backup, EDR and monitoring
  • identity and permissions review
  • vulnerability and patching review
  • cloud and SaaS review
  • supplier remote access review
  • OT security plan where relevant

Incidents and business continuity

  • incident response plan
  • ransomware playbook
  • incident reporting procedure
  • BCP and DRP
  • board tabletop
  • post-incident lessons learned

People and culture

  • digital hygiene training programme
  • board training
  • phishing simulations
  • training for IT, finance, HR and critical teams
  • safe AI use policy
  • building a culture of incident reporting

What should a vCISO deliver in the first 90 days?

First 30 days: diagnosis and priorities

  • meeting with the board and process owners
  • list of critical services and systems
  • initial cyber risk register
  • review of MFA, backup, EDR, cloud, suppliers and incidents
  • analysis of regulatory and contractual requirements
  • first board report

Days 31 to 60: plan and quick wins

  • 12-month cyber roadmap
  • high-risk action priorities
  • budget plan
  • draft incident response plan
  • training plan
  • critical supplier list
  • MFA, backup and access review recommendations

Days 61 to 90: foundations and governance

  • risk and board decision report
  • reporting cycle launch
  • first tabletop or incident exercise
  • compliance evidence repository
  • approved priority policies or procedures
  • supplier assessment plan
  • board KPIs and KRIs

How to hire a fractional CISO?

Step 1: define the problem

Do not start by asking how many days per week you need a CISO. Start with the problem: NIS2, customer audit, no strategy, incident, no reporting, supplier chaos, no budget or need to build the security function.

Step 2: define authority level

A vCISO may advise, recommend, lead a programme or have formal responsibility for selected decisions. This must be agreed at the beginning.

Step 3: define time commitment

Two days per month for reporting and governance is different from two days per week during NIS2 implementation. Time commitment should follow objectives, not a generic package.

Step 4: define incident availability

A fractional CISO is not always available 24/7. If the company needs after-hours support, SLA, on-call model, incident response retainer or separate SOC/MDR service should be defined.

Step 5: define outcomes

The agreement should describe not only hours, but outcomes: board report, risk register, roadmap, incident procedure, tabletop, evidence, training, supplier assessments and KPIs.

Which questions should you ask a fractional CISO candidate?

Questions about experience

  • which sectors have you led cyber programmes in?
  • have you worked with SMEs or only large organizations?
  • which regulations do you know practically?
  • have you led NIS2, national rules, ISO 27001, DORA or SOC 2?
  • do you have post-ransomware experience?
  • have you worked with boards and business owners?

Questions about ways of working

  • what do the first 30 days look like?
  • how do you report risk to the board?
  • how do you prioritize actions with limited budget?
  • how do you work with IT and suppliers?
  • which metrics do you recommend?
  • what is your availability during an incident?

Questions about evidence

  • which documents and evidence will exist after 90 days?
  • what does a sample board report look like?
  • how do you build a risk register?
  • how do you prepare an organization for audit?
  • how do you run tabletop exercises?
  • how do you measure cyber resilience improvement?

What should you watch out for when choosing a vCISO?

Red flag 1: only speaks technically

A vCISO must understand technology, but must also speak the language of risk, decisions, downtime cost and board accountability.

Red flag 2: promises full compliance after one document

Compliance is a process, evidence, reviews and operation. One document is not enough.

Red flag 3: does not ask about business

If the candidate does not ask about customers, critical systems, revenue, operations, suppliers and risks, they will likely propose a generic programme.

Red flag 4: does not define availability

Hours matter during an incident. Availability, escalation and backups must be agreed before signing the contract.

Red flag 5: sells tools instead of governance

A vCISO may recommend tools, but the main role is building the programme and priorities, not selling licences.

Red flag 6: has no evidence of their work

A good vCISO should show sample reporting formats, risk registers, plans, metrics and ways of working, without disclosing client data.

How much time should a vCISO work?

There is no single answer. Time commitment depends on risk, regulation, number of systems, IT maturity, customer pressure and programme scope.

Light model

  • 1-2 days per month
  • board reporting
  • risk review
  • roadmap oversight
  • budget decision support

Standard model

  • 2-4 days per month
  • cyber strategy
  • risk register
  • incident response plan
  • supplier assessment
  • implementation oversight

Intensive model

  • 1-3 days per week
  • NIS2, national rules or ISO 27001 implementation
  • audit preparation
  • post-incident remediation programme
  • coordination of multiple suppliers
  • building the security function from scratch

What should a good vCISO contract include?

Scope

  • cooperation objectives
  • responsibility areas
  • reporting scope
  • participation in board meetings
  • scope of work with IT and suppliers

Availability

  • number of days or hours
  • remote and onsite work model
  • response time for urgent questions
  • incident support model
  • backup person or support team

Outcomes

  • board report
  • risk register
  • roadmap
  • priority procedures
  • evidence pack
  • metrics and action status

Security and confidentiality

  • NDA
  • rules for data access
  • MFA for vCISO accounts
  • activity logging
  • personal data processing where applicable
  • exit plan after cooperation ends

vCISO performance metrics

Governance metrics

  • number of risks with owners
  • number of board decisions on cyber
  • percentage of roadmap actions on time
  • number of consciously accepted exceptions
  • board reporting frequency

Security metrics

  • percentage of critical accounts with MFA
  • date of latest restore test
  • number of overdue critical vulnerabilities
  • percentage of devices covered by EDR
  • number of critical suppliers assessed

Incident metrics

  • time from detection to escalation
  • incident qualification time
  • number of near misses reported
  • number of tabletop exercises performed
  • number of lessons learned actions

People metrics

  • percentage of employees trained
  • phishing simulation result
  • number of suspicious messages reported
  • number of managers trained in cyber risk
  • number of teams with a clear incident role

How does vCISO support NIS2 and national cybersecurity rules?

NIS2 and national cybersecurity rules require more than technical safeguards. They require management system, accountability, evidence and response capability. A vCISO can be the person who connects these elements into one programme.

A vCISO can help with:

  • NIS2 and national rules applicability assessment
  • ISMS preparation
  • cyber risk register implementation
  • incident reporting procedure
  • S46 and CSIRT contact readiness where applicable
  • supplier assessment
  • compliance evidence preparation
  • board reporting
  • audit coordination

How does vCISO support cyber insurance?

Insurers increasingly ask about specific safeguards. A declaration that the company cares about security is not enough. Evidence is needed.

A vCISO can prepare:

  • MFA report
  • backup and restore test report
  • EDR or endpoint protection description
  • incident response plan
  • training report
  • supplier assessment
  • risk register
  • remediation plan

How does a vCISO work with IT?

A good vCISO does not replace IT. They help IT get board support, budget, priorities and decisions. IT knows what the technical problem is. A vCISO helps determine what the business risk is and how to communicate it.

Role split

  • IT maintains systems
  • vCISO defines risk priorities
  • the board makes decisions on risk acceptance and budget
  • suppliers implement selected solutions
  • SOC or MDR monitors and escalates alerts if such a service exists
  • compliance and legal support regulation, contracts and data

How does a vCISO work with suppliers?

In many SMEs, security depends on external providers: IT, cloud, SaaS, ERP, backup, SOC, helpdesk, automation and industry systems. A vCISO should help manage their risk.

What should they do?

  • create critical supplier register
  • determine who has access to systems
  • check MFA and named accounts for suppliers
  • add security clauses to contracts
  • define incident notification obligation
  • check backup and exit plan
  • report supplier risk to the board

Action plan before hiring a vCISO

First 30 days

  • describe why you need a vCISO
  • define business and regulatory objectives
  • collect critical systems and services list
  • check current incidents, audits and customer requirements
  • define approximate budget
  • select cooperation owner on the company side
  • prepare questions for candidates

Days 31 to 60

  • compare vCISO candidates or providers
  • check sector experience
  • ask for a sample board report
  • define scope, availability and SLA
  • define expected outcomes after 90 days
  • check security of the provider itself
  • agree work model with IT and compliance

Days 61 to 90

  • sign the agreement and NDA
  • prepare vCISO onboarding
  • provide access to documents and key people
  • define meeting rhythm
  • launch first diagnosis
  • plan first board report

Action plan after cooperation starts

First 30 days

  • board meeting
  • meetings with IT, DPO, legal, finance, HR and operations
  • critical system review
  • MFA, backup, EDR and supplier review
  • initial risk register
  • first priority report

Days 31 to 60

  • 12-month roadmap
  • budget plan
  • incident response plan
  • training plan
  • supplier assessment plan
  • compliance evidence plan

Days 61 to 90

  • first tabletop
  • access review for critical accounts
  • restore test or restore test plan
  • board report
  • approval of priorities and budget
  • monthly reporting cycle launch

Common mistakes when hiring a vCISO

Mistake 1: no cooperation owner

A vCISO needs access to people and decisions. If nobody on the company side owns the cooperation, the project quickly loses momentum.

Mistake 2: expecting full availability from a part-time role

A fractional CISO is not a full-time employee. Availability, SLA and incident mode must be clear.

Mistake 3: scope too broad for the budget

A few days per month are not enough to deliver strategy, ISO implementation, SOC, tests, training and full documentation. Prioritization is needed.

Mistake 4: no board decision-making

A vCISO can recommend, but the board must make decisions about risk, budget and priorities.

Mistake 5: treating vCISO as a documentation person

Documentation matters, but the vCISO role is about risk management, not creating a folder.

Mistake 6: no metrics

Without KPIs, nobody knows whether the cooperation works. Risk reduction, roadmap progress, training, backup, MFA and suppliers should be measured.

Practical example

A SaaS company has 90 employees and serves customers in finance and manufacturing. Customers increasingly ask about ISO 27001, NIS2, backup, MFA, SOC, penetration testing, incident procedures and training evidence. The company has a strong technical team, but no CISO. The CTO owns everything from product roadmap to security, which means cyber topics are delayed.

The company decides to use a vCISO two days per month for the first three months, then four days per month during customer audit preparation. The vCISO starts with a board meeting, critical system map, risk register, MFA, backup, supplier and incident procedure review.

After 90 days, the company has a board report, 12-month roadmap, risk register, budget plan, incident response plan, training plan, first tabletop and customer evidence list. The CTO still manages technology, but is no longer the sole owner of cyber risk. The board starts making informed decisions, and security becomes part of sales and customer trust.

Related CCyber resources and services

This topic can be connected with further reading and CCyber services to move from the need for cyber leadership to a practical governance model.

  • CCyber Blog - related articles on vCISO, NIS2, national cybersecurity rules, cyber risk, cyber insurance, MFA, backup, incidents, suppliers and governance.
  • vCISO - external CISO, strategy, governance, board reporting and cyber risk oversight.
  • EU regulatory compliance - preparation for NIS2, DORA, CRA, ISO 27001 and customer requirements.
  • NIS2 compliance programme - applicability assessment, gap assessment, documentation, evidence, roadmap and audit readiness.
  • Cybersecurity for SMEs - practical implementation of MFA, backup, EDR, policies, training and compliance.
  • Managed services MSS / MDR / vCISO - monitoring, alert handling, SOC, MDR, vCISO and expert support.
  • Secure IT deployments - IT, AI, cloud and e-service deployments with security, access and compliance in mind.
  • Cyber Academy and training - training for boards, employees, IT, finance, HR and operations teams.

How can ccyber.io help?

ccyber.io helps companies implement a vCISO and fractional CISO model aligned with organizational scale, risk and budget. We connect the perspectives of board, IT, compliance, risk, suppliers and operations. The goal is not to deliver another report. The goal is to build cybersecurity management capability.

We can support your organization with:

  • vCISO and fractional CISO
  • cybersecurity strategy
  • board reporting
  • NIS2 and national cybersecurity applicability assessment
  • ISMS, risk register and roadmap
  • cyber budget and action priorities
  • incident response plan, BCP, DRP and tabletop
  • assessment of IT, cloud, SaaS, OT and managed service suppliers
  • MFA, backup, EDR, IAM, PAM, SIEM, SOC and MDR
  • cyber insurance and evidence pack for brokers
  • training for board and employees
  • preparation for customer audit, ISO 27001, NIS2 or national cybersecurity rules
  • 30, 60, 90-day and 12-month roadmap

The best first step is a vCISO Readiness Workshop. In a short workshop, the company can decide whether it needs a fractional CISO, full-time CISO, vCISO service, project support or a combination of vCISO with MDR and regulatory advisory.

FAQ

Are fractional CISO and vCISO the same?

Not always. Fractional CISO usually means a specific person acting as CISO part-time. vCISO may be a service delivered by one person or a team. In practice, both models often overlap.

Does an SME really need a CISO?

Not every SME needs a full-time CISO. Many companies need the CISO function: risk, strategy, reporting, procedures, suppliers, compliance and board decisions. This is where vCISO works well.

How many days per month should a vCISO work?

It depends on the goal. Light oversight may require 1-2 days per month. NIS2, audit or remediation preparation may require several days per month or 1-3 days per week.

Does a vCISO respond to incidents 24/7?

Not automatically. Incident availability must be agreed in the contract. It is often worth combining vCISO with an incident response retainer or SOC/MDR service.

Does vCISO replace IT?

No. IT maintains systems and implements solutions. A vCISO sets priorities, manages risk, reports to the board, coordinates actions and oversees the cyber programme.

How do you know whether vCISO is working?

After 90 days, concrete outcomes should exist: risk register, board report, roadmap, budget priorities, incident plan, metrics, first quick wins and evidence list.

Can vCISO prepare a company for NIS2?

Yes, if they have practical governance and regulatory experience. They should help with applicability assessment, ISMS, risk register, incident procedure, suppliers, training, evidence and reporting.

Where should we start?

Start with a short diagnosis: why you need a CISO, what risks you have, what customer or regulatory requirements exist, who makes decisions and what outcomes you want after 90 days.

Summary

Fractional CISO and vCISO are answers to a common SME problem: cybersecurity has become too important to leave to ad hoc decisions, but a full-time CISO is still too expensive or too difficult to hire. A part-time cyber leader can quickly introduce governance, strategy, risk register, reporting, procedures, training and supplier oversight.

The role must be set up properly. A vCISO should not be only a documentation person or tool seller. They should be a board partner who helps make decisions on risk, budget and operational resilience.

The best rule is: do not only ask whether you can afford a CISO. Ask whether you can afford not having someone who can explain cyber risk to the board, organize actions and prepare the company for an audit, incident and customer requirements.

Sources

Poland’s Cybersecurity Market Is Growing. How Should Companies Plan Budgets and Choose Providers?

Poland’s cybersecurity market is growing because cyberattacks, digitalisation, NIS2 and national cybersecurity pressure, and funding from KPO, FBiO and EU programmes are increasing at the same time. For companies, this means cyber budgets should not be planned as one-off IT purchases, but as a resilience programme: MFA, backup, EDR, monitoring, supplier assessment, training, incident response, BCP, DRP, ISMS and board reporting. For IT and security providers, this means rising demand, but also higher customer expectations. The winners will not be those who sell the most tools, but those who deliver working resilience, compliance evidence and post-implementation maintenance.

Prepared by: CCyber Editorial Team

Note: This article is educational and strategic. It is not investment advice, a recommendation to buy or sell shares, or brokerage advice.

Short answer

Poland’s cybersecurity market is growing because companies, public institutions and digital service providers are dealing with more attacks, stronger dependence on cloud and SaaS, NIS2 and national cybersecurity requirements, customer expectations, cyber insurance and public funding for digitalisation and resilience. For customers, this means cyber budgets must be planned wisely. Buying a tool is not enough. Organizations need to build capability: risk management, MFA, backup, EDR, monitoring, incident response, supplier assessment, training, compliance evidence and board reporting. For providers, this means a larger market, but also greater responsibility. The winners will increasingly be companies that can combine technology, regulation, governance, managed services and real security maintenance.

Last updated

July 2026

Who this article is for

  • boards and business owners planning cybersecurity budgets
  • CFOs, COOs, CIOs, CISOs, vCISOs, CTOs and digital risk owners
  • companies covered or potentially covered by NIS2, national cybersecurity rules, DORA, CRA, AI Act or ISO 27001
  • SMEs that want to buy cybersecurity wisely without wasting budget
  • IT companies, integrators, MSPs, MSSPs, SOCs, MDR providers, cloud providers and software houses
  • providers serving critical sectors: healthcare, public administration, water utilities, industry, food, transport and finance
  • compliance, risk, legal, DPO, internal audit and management control teams
  • people analyzing the cyber market without treating this text as investment advice

Key takeaways

  1. Poland’s cybersecurity market is growing because cyber has become a condition for business continuity, compliance and customer trust.
  2. NIS2 and national cybersecurity rules turn cybersecurity from a technical task into a management obligation.
  3. The strongest demand will concern not only tools, but also services: audits, implementations, monitoring, MDR, vCISO, training and compliance evidence.
  4. The biggest customer mistake is buying tools without process, owner, maintenance and testing.
  5. The biggest provider mistake is treating rising demand as easy sales without delivery quality and their own security maturity.

What does cybersecurity market growth show?

The growth of the cybersecurity market in Poland shows that companies are no longer treating security as an IT add-on. It is increasingly becoming part of strategy, continuity, contractual requirements, board-level accountability and the cost of digital business.

This is an important mindset shift. A few years ago, many organizations invested mainly after an incident or when a customer required an audit. Today cyber budgets appear earlier: before audits, before NIS2 implementation, before buying cyber insurance, before entering a new contract or before digital transformation.

The market grows because companies need:

  • protection against ransomware and phishing
  • compliance with NIS2, national rules, DORA, CRA and ISO 27001
  • security evidence for customers and insurers
  • secure cloud and SaaS
  • supplier and supply chain protection
  • monitoring and response after hours
  • employee training
  • continuity of operations after an incident

Why is cyber no longer only an IT cost?

Cybersecurity has become a cost of organizational resilience. A company may have the best product, production, sales and team, but if it loses access to email, ERP, finance system, cloud, warehouse, customer data or production systems, it stops operating normally.

That is why the right question is not: how much does cybersecurity cost? A better question is: how much does one day without systems, data, invoicing, production, customer service and communication cost?

Cyber affects:

  • business continuity
  • revenue and liquidity
  • customer relationships
  • contract delivery
  • board accountability
  • cyber insurance
  • reputation
  • company value

Three main drivers of market growth

1. Increasing threat scale

The number of cyber incidents and reports in Poland is growing quickly. This means companies are not investing in cyber because it is fashionable. They invest because they see real risk: phishing, BEC, ransomware, account takeover, data leaks, edge system vulnerabilities, supplier attacks and DDoS.

2. Regulatory pressure

NIS2 and national cybersecurity rules require a system-based approach to risk. Organizations need owners, processes, procedures, evidence, reporting, incident notification, supplier assessment and training. This drives demand not only for tools, but also consulting, audits, implementation and maintenance.

3. Cloud, SaaS and digitalisation

Companies move processes to cloud, use more SaaS tools and integrate systems through APIs. This improves efficiency, but creates new risks: misconfiguration, shadow IT, uncontrolled supplier access, missing logs, missing SaaS backup and dependence on many digital services.

How is the market structure changing?

Services and software are becoming more important than hardware alone. This is a natural direction. A firewall, server or licence matters, but it is not enough. Organizations need people, processes, configuration, monitoring, tests, reports and incident response.

In practice, demand is growing for:

  • MDR and SOC as a Service
  • managed EDR
  • managed backup
  • vCISO
  • NIS2 and national cybersecurity audits
  • ISMS implementation
  • vulnerability management
  • penetration testing
  • supplier assessment
  • training and phishing simulations
  • cloud security
  • OT security

What does market growth mean for customers?

For customers, a growing market means more provider choice, but also greater risk of buying wrong solutions. When cybersecurity becomes fashionable, many offers appear promising quick security, compliance and resilience. Not every offer really delivers that.

The customer should buy cyber based on risk, not trend

  • first critical services and systems
  • then risks and gaps
  • then owners and processes
  • then tools
  • then maintenance, testing and reporting

Questions before purchase

  • which problem are we solving?
  • which risk are we reducing?
  • which system or process is protected?
  • who will own it after implementation?
  • which evidence will be created?
  • will the solution be maintained?
  • does the provider have its own good security practices?
  • does the project support NIS2, national rules, DORA, CRA or cyber insurance?

What does market growth mean for IT and cyber providers?

For providers, market growth is an opportunity, but also a maturity test. Customers will need not only sales, but responsible delivery, post-implementation support, board reporting, incident handling and compliance evidence.

Providers must prepare:

  • sector-specific offers, not only generic packages
  • ability to work with customer boards and compliance teams
  • recurring service model
  • their own security procedures
  • SLA and incident playbooks
  • post-implementation evidence
  • monthly reporting model
  • ability to work in projects funded by KPO, FBiO and EU programmes

What will distinguish a good provider?

  • understanding NIS2 and national cybersecurity rules
  • sector experience
  • IT and OT competence
  • documentation quality
  • real post-implementation maintenance
  • provider’s own security
  • ability to respond quickly to incidents

Most promising market segments

1. NIS2 and national cybersecurity readiness

Many companies are still determining whether they fall under new obligations. This creates demand for applicability assessment, gap assessment, ISMS, documentation, risk register, incident reporting procedures and board reporting.

2. Managed services, MSS, MDR and SOC

Most organizations will not build their own 24/7 security centre. They will need monitoring, alert handling, triage, escalation, reporting and incident support services.

3. Backup and recovery

Ransomware makes backup, restore testing, DRP and BCP one of the first board-level topics. Organizations increasingly ask not only whether backup exists, but whether it has been tested.

4. Identity and access

MFA, IAM, PAM, access review, supplier accounts and remote access are the foundation of security. This area will appear in almost every regulatory and insurance project.

5. Cloud and SaaS security

Companies use Microsoft 365, Google Workspace, CRM, HR, finance, e-commerce and AI tools as SaaS. They need configuration control, backup, logs, DLP, identity management and access policies.

6. OT security

Manufacturing, energy, water utilities, transport, food and technical infrastructure require OT protection. This area is more demanding than classic IT, but increasingly necessary.

7. Training and cyber awareness

NIS2 and national rules require training, but the real need is broader. Companies must teach people about phishing, BEC, MFA, incident reporting, data handling and safe AI use.

AI in cybersecurity: opportunity and risk

AI will increase cybersecurity demand in two directions. First, companies will buy AI tools supporting threat detection, alert analysis, response automation and vulnerability management. Second, they will need to secure AI use itself: policies, data controls, shadow AI protection, prompt injection protection and deepfake awareness.

AI can support security through:

  • SOC alert analysis
  • incident prioritization
  • anomaly detection
  • phishing analysis
  • report automation
  • support for first-line analysts

AI can increase risk through:

  • shadow AI
  • data leaks into generative tools
  • AI-generated phishing
  • deepfake and vishing
  • wrong recommendations
  • lack of control over model providers

KPO, FBiO and EU programmes: how does funding affect the market?

Public funding does not replace cyber strategy, but it can accelerate implementation. KPO, FBiO, Digital Europe, SME grants, programmes for local governments, water utilities, hospitals and critical infrastructure create demand for projects that might otherwise be delayed.

Funding may drive:

  • audit and gap assessment
  • MFA, EDR, backup and monitoring implementation
  • SOC and MDR projects
  • OT cybersecurity
  • training and tabletop exercises
  • cloud and SaaS projects
  • tools for SMEs
  • AI security projects

Most important funding rule

Do not write a project for a purchase. Write it for a risk, critical service and measurable outcome. Only then choose technology and provider.

How should the board plan a cyber budget?

A cyber budget should not be a percentage of IT spend without connection to risk. It should result from which systems and processes are critical and what their unavailability would cost.

The budget should be split into:

  • governance, risk and compliance
  • identity and access
  • backup and recovery
  • endpoint and server protection
  • monitoring and detection
  • incident response and business continuity
  • supplier security
  • training and digital hygiene
  • testing, audits and evidence
  • maintenance and managed services

CFO questions for the cyber budget

  • which expenses reduce the highest risk?
  • which costs are one-off and which are recurring?
  • how much does maintenance cost after implementation?
  • is the project funded from own budget, grant, loan or service model?
  • is the cost lower than potential downtime cost?
  • does the provider guarantee evidence and reporting?

How not to waste the cyber budget?

1. Start with risk

First determine what can stop the company. Only then choose tools.

2. Build the basics

MFA, backup, EDR, updates, training, incident response and supplier assessment often deliver more value than an expensive platform without operation.

3. Plan maintenance

A tool without an administrator, monitoring, procedure and updates quickly loses value.

4. Test

Backup, incident procedure and crisis communication must be tested. Without testing, the organization has a declaration, not resilience.

5. Measure outcomes

Do not measure only purchased licences. Measure detection time, response time, closed gaps, restore results and number of assessed suppliers.

How to assess a cybersecurity provider?

1. Sector competence

The provider should understand the client’s sector. Hospital cybersecurity differs from water utilities, manufacturing, finance and e-commerce.

2. Evidence of the provider’s own security

A cyber provider can be an attack vector. The customer should require MFA, access controls, incident procedures, action logging and provider security evidence.

3. Delivery capability

Sales is one thing. The key is who will implement, who will maintain, who will answer an alert after hours and who will respond during an incident.

4. Board reporting

A good provider does not report only alerts. It reports risk, impact, gaps, actions, SLA and decisions required from the customer.

5. Exit plan

The customer should know what happens to logs, accounts, configuration, documentation and data after cooperation ends.

Action plan for a company buying cybersecurity

First 30 days

  • assign cyber programme owner
  • check applicability of NIS2, national rules, DORA, CRA or other requirements
  • identify critical services and systems
  • check MFA, backup, EDR, supplier access and updates
  • collect the list of critical suppliers
  • prepare first risk register
  • define minimum and target budget
  • present priority report to the board

Days 31 to 60

  • prepare cyber project scope
  • define provider requirements
  • compare offers by risk and outcome, not only price
  • perform restore test for a critical system
  • perform access review
  • launch baseline training
  • prepare incident response plan
  • plan monitoring or MDR service

Days 61 to 90

  • run ransomware tabletop
  • assess key suppliers
  • prepare compliance evidence pack
  • define board KPIs and KRIs
  • close key high-risk gaps
  • approve 12-month roadmap
  • define maintenance budget

Action plan for an IT and cyber provider

First 30 days

  • define which customer problem you solve
  • prepare sector-specific offer
  • check your own safeguards and evidence
  • prepare sample customer board report
  • build a list of post-implementation evidence
  • prepare SLA and escalation model

Days 31 to 60

  • prepare packages: readiness, implementation, monitoring, maintenance
  • develop ransomware, account takeover and supplier incident playbooks
  • prepare a model for KPO, FBiO and EU-funded projects
  • build technology partnerships
  • define recurring cost model

Days 61 to 90

  • launch a pilot for a selected sector
  • collect references and case studies
  • prepare materials for boards and CFOs
  • test customer onboarding process
  • prepare monthly report model
  • plan delivery team scaling

Metrics for the customer’s board

Risk metrics

  • number of high and critical risks
  • number of risks without owner
  • number of accepted exceptions
  • cost of one day of downtime
  • number of overdue remediation actions

Protection metrics

  • percentage of critical accounts with MFA
  • percentage of devices with EDR
  • date of latest restore test
  • number of overdue critical vulnerabilities
  • number of critical systems without monitoring

Supplier metrics

  • number of critical suppliers assessed
  • number of suppliers with privileged access
  • number of suppliers without MFA
  • number of contracts without security clauses
  • number of suppliers without incident reporting procedure

Compliance metrics

  • percentage of requirements with owner
  • percentage of requirements with current evidence
  • number of outdated evidence items
  • audit readiness status
  • status of national cybersecurity obligations where applicable

Metrics for a cyber provider

Sales metrics

  • number of NIS2 and national cybersecurity inquiries
  • cyber project pipeline value
  • share of recurring services in sales
  • average contract value
  • sales closing time

Delivery metrics

  • number of projects delivered on time
  • number of deployments with complete evidence
  • delivery team utilization
  • number of certified specialists
  • number of corrections after acceptance

Service quality metrics

  • alert triage time
  • escalation time
  • number of SLA breaches
  • number of customers with monthly report
  • number of incidents handled according to playbook

Common customer mistakes

Mistake 1: buying under headline pressure

The company hears about a growing market and regulation, then buys the first fashionable tool. This is not a strategy.

Mistake 2: no owner inside the organization

Even the best provider cannot replace the risk owner, board decisions and customer-side accountability.

Mistake 3: tools without maintenance

SIEM, EDR, backup or PAM require configuration, operation, updates and response. Without maintenance, they become a dead cost.

Mistake 4: no restore test

The company has backup, but never checked whether a critical system can be restored within a business-acceptable time.

Mistake 5: missing evidence

After implementation, reports, protocols, access reviews, risk register and documents needed for audit or customer questionnaires are missing.

Mistake 6: no next-year budget

The project is delivered, but there is no money for licences, monitoring, training and reviews. Resilience drops after a few months.

Common provider mistakes

Mistake 1: selling the tool instead of the outcome

The customer does not buy a dashboard. It buys lower risk, audit readiness, shorter response time and stronger business continuity.

Mistake 2: weak regulatory understanding

NIS2, national cybersecurity rules, DORA and CRA are not marketing slogans. They require specific processes, evidence and reporting.

Mistake 3: underestimating delivery

Sales is easier than delivering a project, especially with many customers, short deadlines and shortage of specialists.

Mistake 4: weak own security

A cyber provider must be well protected itself. Otherwise, it becomes a risk for customers.

Mistake 5: no recurring services

The market is shifting toward services and maintenance. A provider based only on one-off deployments may lose advantage.

Business example

A mid-sized services company sees growing customer requirements and hears about NIS2. The board wants to quickly buy “something for cyber”, but the CFO asks what the outcome will be and whether the cost makes sense. IT proposes EDR and backup. Compliance points to the need for a risk register and procedures. Sales says customers started sending security questionnaires.

The company decides on a staged programme. First it performs applicability assessment, maps critical systems, implements MFA, performs restore testing, prepares an incident response plan and runs phishing training. Then it implements managed EDR, supplier assessment, monitoring and board reporting. After three months, the company has not only tools, but also evidence: MFA report, restore test, risk register, incident plan, training report and remediation list.

The provider that won the project did not sell the cheapest licence. It proposed a resilience plan, maintenance, evidence and reporting. That is why the growing cybersecurity market will reward those who can deliver capability, not only a product.

Related CCyber resources and services

This topic can be connected with further reading and CCyber services to move from market observation to a practical action plan.

  • CCyber Blog - related articles on NIS2, national cybersecurity rules, cyber resilience, MFA, backup, suppliers, cyber insurance, funding and governance.
  • EU regulatory compliance - preparation for NIS2, DORA, CRA, ISO 27001 and customer requirements.
  • NIS2 compliance programme - applicability assessment, gap assessment, documentation, evidence, roadmap and audit readiness.
  • vCISO - external CISO, strategy, governance, board reporting and risk oversight.
  • Managed services MSS / MDR / vCISO - monitoring, alert handling, SOC, MDR, vCISO and expert support.
  • Funded projects - support in selecting a programme, preparing scope, budget, application, delivery and evidence for cyber projects.
  • Secure IT deployments - IT, OT, AI and cloud deployments with security, access and compliance in mind.
  • Cyber Academy and training - training for employees, boards, IT, OT, finance and operations teams.

How can ccyber.io help?

ccyber.io helps companies and institutions use the growing cybersecurity market practically: without random purchases, fake compliance or tools no one maintains. We help plan cyber as a resilience, compliance and business continuity programme.

We can support your organization with:

  • NIS2 and national cybersecurity applicability assessment
  • NIS2 and national cybersecurity gap assessment
  • cyber strategy and 12-month budget
  • vCISO and board reporting
  • ISMS, risk register and evidence pack
  • MFA, backup, EDR, IAM, PAM, SIEM, SOC and MDR
  • supplier and supply chain risk assessment
  • incident response plan, BCP, DRP and tabletop
  • training for board, employees, IT and suppliers
  • project preparation for KPO, FBiO, Digital Europe or other funding
  • support for IT providers building NIS2 and managed service offers
  • 30, 60, 90-day and 12-month roadmap

The best first step is a Cyber Budget and Resilience Workshop. In a short workshop, the organization can determine which risks matter most, which expenses make sense, what can be funded, how to choose a provider and how to measure real cyber resilience improvement.

FAQ

Does cybersecurity market growth mean every company should increase its budget?

Not automatically. Budget should follow risk, regulation, critical services, downtime cost and organizational maturity. Sometimes better use of current tools matters more than buying new ones.

What drives the cyber market in Poland most?

The key drivers are increasing incident numbers, NIS2 and national cybersecurity rules, cloud and SaaS, customer requirements, cyber insurance, public funding and stronger board awareness.

Is SOC as a Service worth buying?

It is worth considering when the organization has no internal monitoring and response capability. Scope, log sources, SLA, escalation, reporting and customer-side responsibilities must be clearly defined.

Are tools enough to meet NIS2?

No. NIS2 requires processes, risk management, incident reporting, employee training, supplier assessment, board oversight and evidence. Tools help, but they do not replace a management system.

How to assess whether a cyber provider is good?

Check sector experience, delivery quality, own security, maintenance model, SLA, board reporting, post-implementation evidence and exit plan.

Will AI reduce or increase cyber spending?

Probably both. It can automate analysis and detection, but it also creates new risks such as shadow AI, deepfake, AI-generated phishing and data leaks.

Can public funding reduce cyber costs?

Yes, selected programmes may fund part of cyber projects. However, the problem, scope, budget, outcomes and evidence still need to be well described. Funding does not replace strategy.

Where should cyber budget planning start?

Start with critical services, downtime cost, baseline safeguards, suppliers, regulatory requirements and backup testing. Then choose tools and providers.

Summary

The cybersecurity market in Poland is growing because companies and institutions depend more heavily on digital systems, while threats, regulations and customer requirements continue to increase. Cybersecurity is no longer an IT purchase. It is part of risk management, business continuity and board accountability.

For customers, this means spending money wisely: risk, processes, owners, evidence and maintenance first, then tools. For providers, this means an opportunity for growth, but only with delivery quality, recurring services, regulatory understanding and strong own security.

The best rule is: do not treat the growing cyber market as a signal to buy everything. Treat it as a signal that digital resilience is becoming a normal cost of operating a modern organization and must be planned as seriously as finance, operations and sales.

Sources

We write about regulations such as NIS2, DORA, CRA and ISO 27001, cybersecurity for SMEs and critical infrastructure, as well as cyber hygiene, emerging threats and building security awareness within organisations.

Every article delivers practical knowledge - no jargon, just concrete steps you can act on to effectively protect your data, people and business continuity.