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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

FBiO Funding for Local Government Cybersecurity: What Can Be Funded and How to Prepare the Project?

The Security and Defence Fund can be an important financing source for local governments to strengthen digital resilience, cybersecurity, critical infrastructure protection and continuity of public services. However, it is not a standard grant for any IT purchase. In practice, it is preferential financing for investments that strengthen the security and resilience of the state and local services. A local government should prepare the project around real risks: water supply, wastewater, transport, crisis communication, e-services, backup, monitoring, MFA, SOC, digital hygiene, data protection, incident procedures and compliance with national cybersecurity rules and NIS2. The biggest mistake is treating FBiO as fast money for equipment. The best projects connect cybersecurity with civil protection, business continuity and measurable resilience improvement.

Prepared by: CCyber Editorial Team

Short answer

The Security and Defence Fund can help local governments finance cybersecurity projects, but the best projects should not start with a shopping list. They should start with the question: which public services must continue to operate during a crisis, failure, cyberattack or sabotage? FBiO can support investments that strengthen security and resilience, including cybersecurity, threat detection and warning systems, critical infrastructure, ICT services, continuity of operations and dual-use solutions. For local government units and municipal companies, this is an opportunity to finance projects that were previously postponed: backup, recovery, MFA, monitoring, SOC, EDR, crisis communication systems, OT protection, cybersecurity of water, wastewater, transport and e-services. However, this is an investment project with conditions, documentation, eligible costs, deadlines and the need to sustain outcomes.

Last updated

July 2026

Who this article is for

  • mayors, city presidents, county leaders, regional leaders and local government boards
  • treasurers, secretaries, office directors, unit heads and investment owners
  • IT teams, administrators, CISOs, vCISOs, DPOs, internal audit and public-sector compliance teams
  • municipal companies, water and wastewater utilities, public transport, municipal service entities and shared service centres
  • local governments preparing for national cybersecurity rules, NIS2, S46, ISMS and cybersecurity audits
  • IT, cloud, backup, SOC, MSSP, EDR, SIEM, e-service and domain system providers serving local governments
  • technology companies and enterprises preparing projects under the FBiO loan or equity instruments
  • organizations that want to connect financing with real cyber resilience improvement

Key takeaways

  1. FBiO is a financing instrument for security and resilience, and cybersecurity is one of its key areas.
  2. For the municipal sector, financing may cover cyber projects, detection and warning systems, collective protection facilities, military mobility and dual-use rolling stock.
  3. A local government should prepare the project around critical services: water, wastewater, transport, energy, communication, e-services, resident data and crisis communication.
  4. This is not funding for any IT purchase. Every cost must be linked to the project objective, eligibility, resilience and documentation.
  5. The best project connects FBiO with national cybersecurity rules, NIS2, ISMS, incident procedures, backup, MFA, suppliers, training and business continuity.

What is the Security and Defence Fund?

The Security and Defence Fund is financed from Poland’s National Recovery and Resilience Plan. Its purpose is to support investments strengthening state security and resilience, civil protection, dual-use infrastructure, cybersecurity, continuity of critical services and the potential of enterprises, including the defence sector.

In practice, FBiO has two main pillars: a loan part operated by BGK and an equity part implemented by Chrobry S.A. The loan part is especially important for local governments, municipal companies, the rail sector and enterprises planning investments in security and resilience.

Key elements of FBiO

  • financing from the National Recovery and Resilience Plan
  • total budget of about PLN 23 billion
  • loan part of about PLN 16 billion
  • equity part of about PLN 7 billion
  • over PLN 11 billion for the municipal sector
  • cybersecurity projects as one financing category
  • preferential loan terms for local government units
  • possibility of partial capital cancellation for eligible local government units

FBiO is not a classic grant. It is preferential financing

In discussions about FBiO, terms such as “money”, “support” or “financing” often appear. For local governments, however, it is important to understand the mechanism precisely. In the loan part, this is a preferential loan, not a classic non-refundable grant for any purchase.

For the municipal sector, this means:

  • recipients may include local government units and municipal companies
  • loan amount may range from PLN 2 million to PLN 500 million
  • interest rate starts from 0%
  • financing may cover up to 100% of eligible net costs
  • repayment period may be up to 20 years
  • capital repayment grace period may be up to 12 months
  • capital cancellation may be 20% for eligible local government units
  • in selected cases cancellation may increase to 40%

This still requires careful financial planning. Even with zero interest and possible cancellation, a local government must understand the project’s impact on the budget, repayment capacity, investment maintenance and operating costs after completion.

What can a local government obtain financing for?

In the municipal loan part, financing may cover several investment categories. Cybersecurity is one of them, but it can also connect with other categories, such as detection and warning systems, civil protection infrastructure, crisis communication and critical service resilience.

Example categories for the municipal sector

  • construction, modernization and renovation of collective protection facilities
  • cybersecurity projects
  • construction and modernization of threat detection systems
  • construction and modernization of notification and warning systems
  • purchase, modernization or renovation of rolling stock for military or dual-use purposes
  • construction and modernization of roads, bridges and tunnels for military mobility standards

What does this mean for cybersecurity?

A local government should not treat cyber as a separate add-on to infrastructure. In practice, cybersecurity can strengthen almost every resilience project: shelters need communication, water utilities need control systems, transport needs ICT systems, a crisis management centre needs secure communication, and the office needs backup, MFA and response procedures.

Which cyber projects may make sense in local government?

Exact eligibility depends on the call rules and BGK documentation, so every idea must be formally checked. The list below shows which types of projects may fit the FBiO logic if they are connected with security, resilience and continuity of services.

1. Protection of critical local government services

  • cybersecurity of water supply and wastewater systems
  • security of wastewater treatment systems
  • security of heating systems
  • protection of public transport and control systems
  • security of municipal services
  • security of crisis management centres

2. Backup, recovery and business continuity

  • backup system modernization
  • ransomware-resistant backup
  • recovery of critical systems
  • backup data processing centre
  • DRP and BCP procedures
  • restore tests and recovery exercises

3. Monitoring, detection and response

  • SOC as a Service for a group of entities
  • Local Cybersecurity Centre
  • SIEM or log management
  • EDR or XDR for endpoints
  • Microsoft 365 or Google Workspace monitoring
  • incident response procedures and playbooks

4. Identity, access and MFA

  • MFA for email and administrators
  • IAM for local government units
  • PAM for privileged accounts
  • access review
  • secure remote access for suppliers
  • logging of administrator actions

5. Cybersecurity of e-services

  • resident portal protection
  • public information bulletin and local government website protection
  • security of e-delivery and document workflow
  • API and integration protection
  • penetration testing of e-services
  • WAF, DDoS protection and availability monitoring

6. OT and technical infrastructure security

  • IT and OT network segmentation
  • industrial network monitoring
  • secure remote access to technical systems
  • configuration backup for controllers and supervisory systems
  • OT asset inventory
  • emergency procedures for technical suppliers

7. Training, cyber hygiene and operational readiness

  • training for office employees
  • training for leadership and treasurers
  • phishing simulations
  • ransomware tabletop
  • incident reporting exercises
  • safe AI use procedures

How to connect FBiO with national cybersecurity rules and NIS2?

The best FBiO-funded project should support obligations under national cybersecurity rules and NIS2. This helps a local government avoid a situation where infrastructure is financed, but there is still no compliance evidence, procedures, risk owners or incident readiness.

FBiO can support elements such as:

  • ISMS
  • cyber risk register
  • critical service and system register
  • backup and restore testing
  • incident response procedures
  • incident reporting and S46 readiness
  • monitoring and detection
  • supplier and remote access security
  • training and cyber hygiene
  • leadership reporting

Practical rule

Every FBiO project with a cyber component should be mapped to a risk, critical service and organizational obligation. If the project buys a tool, it must show which process the tool supports, who owns it, which evidence will be produced and how resilience improvement will be measured.

How to build a good cyber project for FBiO?

Step 1: start with critical services

Do not start with hardware. Start with the list of services that must operate during crisis: water, wastewater, heating, transport, resident communication, crisis management, e-services, document workflow, finance system and resident data.

Step 2: describe the risk

The project should come from risk. Example: ransomware may stop the office and municipal utility, missing backup prevents recovery, supplier account takeover gives attackers access to systems, and missing monitoring delays incident detection.

Step 3: define the outcome

The outcome should be measurable. Not “security improvement”, but for example: 100% of administrator accounts with MFA, 95% of endpoints with EDR, restore test for a critical system every six months, incident escalation under 30 minutes or 24/7 monitoring for five critical systems.

Step 4: prepare architecture

A cyber project should show how the solution will operate: which systems are covered, which data is processed, which integrations are needed, who will administer it, what supplier access looks like and how logs will be secured.

Step 5: plan maintenance

A loan can finance investment, but the local government must maintain the outcomes. Licences, monitoring, MSSP services, updates, tests, training and maintenance need a funding source after project completion.

What should be included in the project description?

Problem description

  • which public service is at risk
  • which systems support it
  • which incidents or near misses occurred
  • which gaps exist today
  • what downtime impact would be

Project scope

  • systems covered by the project
  • units and companies covered by the project
  • technology scope
  • organizational scope
  • training and procedure scope
  • testing and acceptance scope

Outcomes

  • implemented safeguards
  • tested backup
  • ready procedures
  • trained employees
  • monitored systems
  • compliance reports and evidence
  • resilience metrics

Sustainability

  • post-project maintenance costs
  • service owner
  • service contracts
  • test and review cycle
  • update plan
  • leadership reporting

Which costs are worth planning?

Costs must comply with the call and eligibility rules. The list below is a practical starting point for budgeting a cyber project, but every item must be verified against BGK documentation.

Preparation costs

  • needs and risk analysis
  • cybersecurity audit
  • technical design
  • technical, legal and financial advisory
  • project documentation preparation

Technology costs

  • security system licences and implementation
  • EDR, XDR, SIEM, SOAR, NDR or log management
  • backup and recovery system
  • MFA, IAM, PAM
  • critical infrastructure monitoring
  • DDoS protection, WAF, DNS security
  • secure crisis communication

Service costs

  • implementation and configuration
  • penetration testing
  • restore test
  • tabletop exercises
  • SOC or MSSP monitoring
  • supplier assessment
  • employee and leadership training

Documentation and evidence costs

  • ISMS
  • incident response procedures
  • BCP and DRP
  • backup policy
  • access policy
  • AI policy
  • acceptance and test reports

What should not be financed without thinking?

Equipment without process

A server, storage, firewall or licence will not increase resilience if there is no owner, procedure, configuration, testing and maintenance.

Tools without people

SIEM, EDR or backup generate value only when someone analyzes alerts, performs tests, updates rules and responds to incidents.

Solutions without integration

A security system must be connected to real data sources: email, identity, endpoints, servers, cloud, firewalls, domain systems and OT.

Project without maintenance

If there is no budget for licences, service, monitoring and training after project completion, the outcome will quickly disappear.

How to prepare the BGK application?

The application should be complete, signed with a qualified electronic signature and compliant with the call requirements. It is important to prepare attachments, cost descriptions, formal documents and investment justification in advance.

Practical preparation list

  • check the right BGK product for the municipal sector or enterprises
  • check minimum and maximum loan amount
  • check that the project did not start before application submission
  • check the DNSH principle
  • check that costs are not financed from another programme
  • prepare project description and resilience justification
  • prepare net budget and eligible costs
  • prepare timeline and delivery plan
  • prepare electronically signed documents
  • plan secure document transfer

Which documents should a local government have before applying?

Strategic documents

  • local government cyber resilience diagnosis
  • critical service register
  • supplier dependency map
  • national cybersecurity and NIS2 compliance analysis
  • cybersecurity roadmap
  • leadership decision on the project

Project documents

  • project description
  • technical scope
  • timeline
  • budget
  • cost justification
  • project risk analysis
  • outcome maintenance plan
  • outcome and KPI list

Cyber documents

  • cyber risk register
  • asset register
  • privileged account register
  • backup policy
  • incident response plan
  • BCP and DRP
  • supplier assessment
  • training plan

How to assess whether the project is good?

Test 1: does the project protect a public service?

A good project shows how the investment will reduce the risk of service interruption for residents, businesses or dependent units.

Test 2: does the project have a measurable outcome?

The outcome should be countable: systems covered by monitoring, accounts with MFA, recovery time, trained people, tests performed, vulnerabilities closed.

Test 3: does the project support national cybersecurity rules or NIS2?

If the project supports incident response, business continuity, supplier assessment, asset management, backup, training or risk management, its strategic character is easier to justify.

Test 4: can the project be maintained?

The local government should know how much the solution will cost after the first year, who will operate it and whether an external service will be needed.

Test 5: does the project have an owner?

A project without an owner on the office or municipal company side quickly becomes a procurement issue instead of a resilience investment.

Project ideas for a small or medium-sized municipality

Baseline package: local government cyber minimum

  • MFA for email, administrators and VPN
  • EDR for workstations and servers
  • ransomware-resistant backup
  • restore test
  • incident response plan
  • cyber hygiene training
  • IT supplier assessment

Critical service resilience package

  • water and wastewater system protection
  • IT and OT network segmentation
  • supplier remote access monitoring
  • configuration backup for technical systems
  • emergency plan for municipal services
  • tabletop exercise with the municipal company

SOC package for a group of local governments

  • shared monitoring centre
  • log collection from offices and units
  • 24/7 or after-hours monitoring
  • shared incident playbooks
  • reporting to local government leadership
  • shared maintenance cost model

Crisis communication package

  • secure emergency communication for leadership
  • alternative channels when email is down
  • resident communication procedures
  • warning and notification system
  • crisis management exercises
  • integration with incident procedure

FBiO for enterprises: what matters?

FBiO is not only for local governments. Enterprises can use the loan part and equity instruments if the project strengthens state security and resilience. In the loan part for enterprises, financing may cover cybersecurity projects, continuity of energy and fuel supply, physical security of critical infrastructure, ICT services, transport and dual-use production.

Key parameters for enterprises

  • recipients are enterprises
  • loan amount from PLN 10 million to PLN 300 million
  • minimum PLN 100 million for energy sector projects
  • interest rate from 1%
  • repayment period up to 20 years
  • financing up to 100% of eligible net costs
  • state aid or de minimis aid may apply

For cyber companies, this creates opportunities for:

  • development of cyber products and services of strategic importance
  • SOC, MDR, cyber threat intelligence or services for critical infrastructure
  • solutions for water, energy, transport, communications and public administration
  • dual-use projects connecting civil and defence security
  • deployments ensuring continuity of ICT services

How to combine FBiO with other financing sources?

A local government may use different programmes at the same time, but it must avoid double financing of the same costs. FBiO cannot finance expenses already settled or submitted for settlement under the National Recovery Plan or other EU programmes, nor costs covered by other national support.

Practical rule

One project may be part of a broader resilience strategy, but each cost must have one funding source, clear justification and documentation. It is useful to prepare a financing map showing which actions are funded by FBiO, which by own budget, which by Digital Europe and which by other sources.

Action plan before submitting the application

First 30 days

  • appoint FBiO project owner
  • check the right product: municipal sector, rail sector or enterprises
  • identify critical services and cyber risks
  • prepare initial project scope
  • check investor and cost eligibility
  • check cancellation option, if applicable to the local government unit
  • prepare first budget and timeline
  • present leadership decision on application preparation

Days 31 to 60

  • develop project description and resilience justification
  • prepare technical architecture
  • prepare eligible cost list
  • collect formal documents
  • prepare project risk analysis
  • prepare outcome maintenance plan
  • check DNSH and cost exclusions
  • agree the project with treasurer, IT, DPO and leadership

Days 61 to 90

  • complete application and attachments
  • verify electronic signatures
  • prepare editable document package
  • perform financial review
  • perform technical review
  • perform call rules compliance review
  • prepare procurement plan after decision
  • submit before the last day

Action plan after receiving financing

First 30 days

  • read the loan agreement and financing conditions carefully
  • create project team
  • appoint project manager
  • prepare operational timeline
  • create evidence repository
  • create risk and decision register
  • define cost description method
  • prepare leadership communication plan

Days 31 to 60

  • launch procurement or procedures
  • prepare security requirements for suppliers
  • define acceptance protocols
  • plan tests and training
  • confirm integrations with local government systems
  • define progress reporting method
  • check cost compliance with budget

Days 61 to 90

  • check delivery of first milestones
  • perform first project risk review
  • update timeline
  • prepare first leadership report
  • check financial document completeness
  • check technical evidence completeness
  • close first nonconformities or delays

Metrics for local government leadership

Project metrics

  • project completion percentage
  • number of milestones completed on time
  • number of delayed tasks
  • budget utilization
  • project risk status

Cyber resilience metrics

  • number of critical services covered by the project
  • percentage of critical accounts with MFA
  • percentage of devices covered by EDR
  • number of systems covered by backup
  • date of latest restore test
  • incident escalation time

Business continuity metrics

  • RTO for critical systems
  • RPO for critical systems
  • number of tested emergency procedures
  • number of services with workaround plan
  • tabletop exercise result

Supplier metrics

  • number of critical suppliers assessed
  • number of suppliers with remote access
  • number of suppliers without MFA
  • number of contracts requiring security annex
  • number of suppliers with exit plan

Common local government mistakes

Mistake 1: the project starts with purchases

First describe the critical service, risk and expected outcome. Only then choose technology and suppliers.

Mistake 2: no owner on the local government side

An external contractor can implement the solution, but the office or municipal company must own decisions, acceptance and maintenance.

Mistake 3: no maintenance costs

The project is financed, but there is no budget for licences, monitoring, service, training and testing in the following years.

Mistake 4: no link with national cybersecurity rules and NIS2

The local government buys tools, but procedures, registers, evidence, reports and incident reporting mechanisms are not created.

Mistake 5: dependent units and companies omitted

The office strengthens its systems, but water utilities, municipal services or education units remain outside the project.

Mistake 6: no testing

Backup, SOC, incident procedure and emergency communication must be tested. Without tests, the project is incomplete.

Mistake 7: unclear cost eligibility

The project includes costs that are not well linked to the financing objective, are not described or may be excluded.

Mistake 8: no documentation from day one

Evidence is hardest to recreate at the end of the project. Documentation should be created during delivery, at each milestone and acceptance.

Practical example

A medium-sized municipality has an office, water utility, tax system, document workflow, public information bulletin, email, e-delivery and an external IT provider. After risk analysis, the biggest threat is ransomware and the inability to quickly recover office and water utility systems. In addition, some administrator accounts do not have MFA, and the IT provider uses remote access without full action logging.

The municipality prepares an FBiO project not as an “IT equipment purchase”, but as a digital resilience programme for critical services. The scope includes ransomware-resistant backup, MFA, EDR, segmentation, log monitoring, incident procedure, restore test, tabletop and supplier assessment. The project covers the office and water utility because the utility provides a critical service to residents.

After implementation, the municipality has not only new tools, but also evidence: MFA report, restore test report, risk register, supplier register, incident reporting procedure, business continuity plan and leadership report. This connects financing with national cybersecurity rules, NIS2 and real resilience for residents.

Related CCyber resources and services

This topic can be connected with further reading and CCyber services to move from an FBiO idea to a well-prepared project, application and implementation.

  • CCyber Blog - related articles on financing, national cybersecurity rules, NIS2, local government cyber resilience, MFA, backup, incident response, AI, suppliers and audits.
  • Funded projects - support in selecting the programme, preparing application, budget, scope, delivery and project settlement.
  • Cybersecurity funding - support in financing actions related to NIS2, CRA, ISO 27001, audit, training and security implementation.
  • Cybersecurity for the public sector - support for local governments, public institutions, organizational units and critical infrastructure.
  • NIS2 compliance programme - applicability assessment, gap assessment, documentation, evidence, roadmap and audit readiness.
  • NIS2, national cybersecurity and DORA incident reporting - 24h, 72h, final report, CSIRT, DPO, customers and insurer procedures.
  • vCISO - external CISO, strategy, governance, leadership reporting and risk oversight.
  • Secure IT deployments - support for IT, AI, cloud and e-service deployments with security, access and compliance in mind.

How can ccyber.io help?

ccyber.io helps local governments, municipal companies and suppliers prepare cybersecurity projects for FBiO and other national and EU financing programmes. We connect financing, cybersecurity, national cybersecurity rules, NIS2, IT projects, suppliers and delivery evidence.

We can support your organization with:

  • cyber needs diagnosis for FBiO
  • mapping of critical services and local government risks
  • preparation of cybersecurity project scope
  • review of cost eligibility from a cyber perspective
  • budget and project timeline preparation
  • security architecture design
  • MFA, backup, EDR, SIEM, SOC, IAM and PAM implementation
  • ISMS, BCP, DRP and incident procedure preparation
  • assessment of IT, cloud, SaaS, domain system and OT suppliers
  • training, tabletop and incident reporting exercises
  • evidence repository and leadership report
  • 30, 60, 90-day and 12-month roadmap

The best first step is an FBiO Cyber Project Workshop for local governments. In a short workshop, the organization can decide whether the idea fits the financing, which critical services it covers, which costs should be planned, which evidence will be produced and how to connect the project with national cybersecurity rules and NIS2.

FAQ

Is FBiO a cybersecurity grant?

Not in the classic sense. For the municipal sector, it is primarily a preferential loan that may have interest from 0%, a long repayment period and possible partial cancellation for eligible local government units.

Can a local government finance a cybersecurity project?

Yes, cybersecurity projects are indicated as one of the categories eligible for financing. However, the project must show a link with security, resilience and eligible costs.

Can SOC or monitoring be financed?

This may be justified if the project is linked to resilience of critical services, incident detection, national cybersecurity rules, NIS2 and business continuity. Eligibility of a specific cost model must be checked in the call rules.

Can backup be financed?

A backup and recovery project can fit well into cyber resilience, especially if it concerns critical systems, ransomware protection and restore tests. However, the outcome and post-project maintenance must be described.

Can the project include a municipal company?

Yes, the BGK product for the municipal sector indicates local government units and municipal companies as recipients. Project structure, roles, ownership, costs and impact on public services must be described.

Can FBiO be combined with other programmes?

A broader financing strategy can be planned, but the same costs cannot be financed twice. A clear cost and funding source map should be maintained.

What matters most before applying?

The key is connecting the project with a critical service, risk, measurable outcome, budget, cost eligibility and outcome maintenance plan.

Where should a small municipality start?

Start with critical services, system register, backup, MFA, suppliers, risks and incident procedure. Only then build the financing project and select technology.

Summary

FBiO can become one of the most important instruments for financing local government resilience in the coming years. For local government units and municipal companies, it creates an opportunity for projects that connect civil protection, service continuity, cybersecurity, warning systems, critical infrastructure and digital resilience.

The key is the right approach. The project should not be a shopping list or an attempt to spend money on any IT. It should come from risk, concern services important to residents, have measurable outcomes, a maintenance plan, owners and delivery evidence.

The best rule is: do not first ask what can be bought. Ask which public service will stop after a cyberattack, how long recovery will take, who will make the decision and which financing will truly increase resident resilience.

Sources

How to Achieve Full Asset Inventory and Visibility for NIS2 Without Expensive Enterprise Tools?

A full asset inventory aligned with NIS2 does not have to mean an expensive enterprise platform. For SMEs, the key is to know which devices, accounts, applications, cloud services, data, suppliers, critical systems and internet-facing assets the company has. You can start with a spreadsheet, exports from Microsoft 365 or Google Workspace, data from routers, DHCP, DNS, EDR, antivirus, backup systems, invoices, contracts, accounting systems and simple network scans. The tool is not the main point. The process is: asset owner, criticality, data, access, backup, updates, supplier, security status and regular review.

Prepared by: CCyber Editorial Team

Short answer

Full asset inventory and visibility aligned with NIS2 does not have to start with buying an expensive CMDB, EASM, CAASM or enterprise platform. For SMEs, the key is to build a reliable, regularly updated asset register and connect it with simple data sources: identity directory, email system, MDM or EDR, router, DHCP, DNS, firewall, backup, cloud, invoices, contracts and accounting system. The company should know which devices, applications, systems, accounts, data, cloud services, suppliers and internet-facing assets it has. Full visibility does not mean perfect automation on day one. It means the company can answer: what do we have, who owns it, how critical is it, what data is there, who has access, is there backup, are there updates and is the asset monitored?

Last updated

July 2026

Who this article is for

  • SME owners and boards preparing for NIS2 or customer requirements
  • companies without a large IT department and without enterprise tools
  • CISOs, vCISOs, CTOs, CIOs, administrators and IT owners
  • compliance, risk, legal, DPO and internal audit teams
  • software houses, SaaS companies, e-commerce, professional services and manufacturing
  • IT providers supporting small and medium-sized companies
  • companies preparing for ISO 27001, cyber insurance or customer audit
  • organizations that want to organize assets before implementing MFA, backup, EDR, SIEM or vulnerability management

Key takeaways

  1. Without asset inventory, the company does not know what to protect, update, monitor and recover after an incident.
  2. NIS2 requires a risk-based approach, and asset management is one element of cybersecurity risk management measures.
  3. An SME can start with a spreadsheet, system exports and a simple review process before buying expensive tools.
  4. The most important categories are devices, users, privileged accounts, applications, SaaS services, data, cloud, backup, suppliers, domains, certificates and internet-facing assets.
  5. A good inventory has an owner, update date, criticality, security status, data source and recurring review.

What does NIS2 mean for asset inventory?

NIS2 does not say that every company must buy a specific inventory system. It does require cybersecurity risk management, and that cannot be done without asset visibility. If the company does not know which systems it has, who has access, where data is located and which services are critical, it cannot reliably assess risk, prepare continuity plans or demonstrate compliance.

From a NIS2 perspective, asset inventory helps show:

  • which systems support critical services
  • which data is processed
  • who owns the system or process
  • which assets are exposed to the internet
  • which accounts have privileged access
  • whether the system is backed up
  • whether the system is updated
  • whether the asset is monitored
  • which supplier maintains it
  • which remediation actions are open

Simply put, asset inventory is the foundation for risk, MFA, backup, vulnerabilities, incidents, suppliers, business continuity and audit.

Does “full inventory” mean 100% perfection?

No. In a small or medium-sized company, full inventory does not mean that every cable, device and application is automatically visible in one console from day one. It means the company has a process that continuously moves toward completeness and quickly detects gaps.

Practical definition of full inventory for SMEs

  • all critical systems are known
  • all company devices are known
  • main applications and SaaS services are known
  • administrator and supplier accounts are known
  • internet-facing assets are known
  • critical data location is known
  • asset owners are known
  • backup, MFA, EDR and update status are known
  • there is a way to detect new or unknown assets
  • regular review and gap remediation are performed

An auditor or customer rarely expects an SME to have a global enterprise-grade platform. They will expect a clear register, owners, dates, criticality, security status and evidence of recurring review.

Why you do not need enterprise tooling immediately

Expensive tools can be very helpful, but they will not solve the problem if the company does not have a process. A tool without owners, classification, review and business decisions becomes another outdated database.

An SME can start with a simple model

  • spreadsheet or simple database as the main register
  • exports from source systems
  • monthly or quarterly review
  • clear mandatory fields
  • simple criticality classification
  • gap and remediation list
  • board report

The key point is that the register is used for decisions. If the register shows that a system has no owner, backup or public exposure, a remediation action must be created.

Which assets should be inventoried?

1. End-user devices

  • laptops
  • desktops
  • company phones
  • tablets
  • BYOD devices used for work, if allowed
  • remote worker devices

2. Servers and infrastructure

  • physical servers
  • virtual machines
  • file servers
  • application servers
  • database servers
  • NAS and storage
  • test and development environments

3. Network assets

  • routers
  • firewalls
  • switches
  • Wi-Fi access points
  • VPN
  • ZTNA
  • public IP addresses
  • NAT and port forwarding rules

4. Applications and software

  • operating systems
  • business applications
  • local applications
  • remote access tools
  • accounting software
  • CRM, ERP, HR and finance systems
  • developer tools
  • unapproved software

5. SaaS and cloud services

  • Microsoft 365
  • Google Workspace
  • online CRM
  • marketing tools
  • e-commerce platforms
  • ticketing systems
  • code repositories
  • AI services
  • backup services
  • AWS, Azure or Google Cloud resources

6. Accounts, roles and identities

  • users
  • administrators
  • supplier accounts
  • service accounts
  • service principals
  • API keys
  • tokens
  • break glass accounts

7. Data

  • customer data
  • personal data
  • financial data
  • employee data
  • trade secrets
  • source code
  • technical documentation
  • production data

8. Suppliers and subcontractors

  • IT provider
  • cloud provider
  • hosting provider
  • backup provider
  • software house
  • accounting office
  • business system provider
  • SOC or MDR provider
  • OT integrator

9. Domains, DNS and certificates

  • company domains
  • subdomains
  • DNS records
  • TLS certificates
  • email services
  • SPF, DKIM and DMARC
  • external login services

10. Critical systems and dependencies

  • systems needed for sales
  • systems needed for production
  • payment systems
  • customer service systems
  • finance systems
  • backup systems
  • identity systems
  • crisis communication systems

Minimum fields in the asset register

The register does not need to be complicated. It must contain fields that support risk decisions.

Basic fields

  • asset ID
  • asset name
  • asset type
  • business owner
  • technical owner
  • location or environment
  • supplier or maintainer
  • status: active, planned, being retired, disabled
  • date of last update

Risk fields

  • criticality: low, medium, high, critical
  • data type
  • whether the asset supports a critical service
  • whether the asset is exposed to the internet
  • whether supplier has access
  • whether there is single supplier dependency
  • impact of outage on the company

Security fields

  • MFA: yes, no, partial, not applicable
  • backup: yes, no, partial, not applicable
  • date of latest restore test
  • EDR or endpoint protection
  • update status
  • latest vulnerability scan
  • logging and monitoring
  • latest access review
  • open remediation actions

Audit fields

  • information source
  • date confirmed by owner
  • technical evidence
  • link to ticket or report
  • review notes
  • next review date

Visibility model without enterprise tools

Layer 1: main register

This is a spreadsheet, simple database, ticketing system or lightweight IT asset management tool. The main register is where the company makes decisions. It does not need to discover everything automatically, but it must collect outputs from many sources.

Layer 2: technical sources

These are systems where you collect data: Microsoft 365, Google Workspace, identity directory, MDM, EDR, antivirus, firewall, DHCP, DNS, backup, cloud, hosting, code repository and network scanner.

Layer 3: owner review

Automation does not know everything. The business owner must confirm whether the system is still used, whether it is critical, what data it contains and whether the supplier still has access.

Layer 4: remediation actions

Visibility should lead to action. Unknown device, missing MFA, missing backup, public port, unused application or former employee account should become a remediation item.

10 low-cost data sources for asset visibility

1. Identity directory

Microsoft Entra ID, Active Directory, Google Workspace or another identity directory shows users, groups, administrator accounts, devices, applications and logins.

What to extract?

  • user list
  • administrator list
  • inactive accounts
  • MFA status
  • groups and roles
  • applications with SSO

2. Microsoft 365 or Google Workspace admin panel

The admin panel shows licenses, users, groups, devices, services, applications and some security settings.

What to extract?

  • active users
  • services used by the company
  • OAuth apps or external integrations
  • mobile devices
  • email settings
  • email forwarding rules

3. DHCP, DNS and router

Even a simple router, DHCP server or DNS server provides useful information about devices seen on the network.

What to extract?

  • IP addresses
  • hostnames
  • MAC addresses
  • unknown devices
  • long-inactive devices
  • new devices on the network

4. Firewall and VPN

The firewall shows public services, remote access, NAT rules, VPN and internet traffic. This is very important for attack surface visibility.

What to extract?

  • public IP addresses
  • open ports
  • port forwarding rules
  • VPN users
  • suppliers with remote access
  • connections from outside the operating country

5. EDR, antivirus or MDM

If the company has endpoint protection, the console usually shows laptops, servers, operating system versions, agent health and missing updates.

What to extract?

  • device list
  • last activity
  • operating system version
  • protection status
  • devices without agent
  • high-risk alerts

6. Backup system

The backup system shows which systems are covered, which are not, which jobs failed and when restore was tested.

What to extract?

  • systems covered by backup
  • systems without backup
  • backup errors
  • retention
  • latest restore test
  • backup administrator accounts

7. Cloud and hosting

AWS, Azure, Google Cloud, hosting, VPS and PaaS platforms show assets that may be invisible in the local network.

What to extract?

  • virtual machines
  • databases
  • storage
  • public IP addresses
  • load balancers
  • API keys
  • containers
  • service accounts

8. Invoices, contracts and accounting system

Some of the most important assets are hidden in costs. An invoice for a SaaS tool may reveal a service that IT did not know about.

What to extract?

  • SaaS subscriptions
  • IT suppliers
  • cloud providers
  • software licenses
  • tools bought by card
  • services used by departments outside IT

9. Simple network scan

A periodic internal network scan can show devices, open services and unexpected systems. It must be done carefully, especially in OT environments.

What to extract?

  • active hosts
  • open ports
  • service names
  • unknown devices
  • administrative services
  • systems without owner

10. Interviews with process owners

Not everything can be found technically. Marketing, sales, finance, HR and production may use tools that central IT cannot see.

What to extract?

  • SaaS tools used by the department
  • files and data repositories
  • shared accounts
  • suppliers with access
  • critical processes
  • AI or automation tools

How to detect Shadow IT and uncontrolled assets?

Shadow IT means tools, accounts, applications, devices and services used outside formal organizational control. In SMEs, it often appears without bad intent. Someone buys a marketing tool, creates a test account, uses a private drive or orders a small application from a supplier.

Sources for detecting Shadow IT

  • invoices and company card payments
  • SSO logins and OAuth apps
  • DNS queries to SaaS services
  • manager interviews
  • quarterly department survey
  • browser extensions and integrations review
  • list of tools used in projects
  • code repository and CI/CD pipeline review

How to respond?

  • do not start with punishment
  • determine what the tool is used for
  • check data and access
  • assess supplier risk
  • approve, limit or retire the service
  • add the tool to the register
  • assign owner and usage rules

How to define asset criticality?

Not every asset needs the same attention. Criticality helps prioritize safeguards and remediation actions.

Critical level

An asset whose outage stops sales, production, payments, customer service, security, data access or recovery.

High level

An asset important for many users, customer data, finance, operations or suppliers, but with a short-term workaround available.

Medium level

An asset that supports a department or process, but does not stop the whole company and can be worked around manually for some time.

Low level

A supporting, test or low-importance asset without sensitive data and without impact on critical services.

Classification questions

  • would outage stop the company?
  • does outage affect customers?
  • does the asset contain personal or confidential data?
  • is the asset exposed to the internet?
  • does the asset have administrator accounts?
  • is the asset backed up?
  • how quickly must it be recovered?
  • is there a replacement supplier?

How to build the inventory step by step?

Step 1: assign process owner

Without an owner, the register will die after the first export. The process owner does not need to know every system personally, but owns completeness, review cycle and reporting.

Step 2: define scope

Define whether the inventory covers the whole company, one entity, one branch, one system, production environment or customer audit scope.

Step 3: choose the main register

A spreadsheet is enough to start, but it should have version control, an owner and clear mandatory fields. Later it can move to a lightweight ITSM or asset management tool.

Step 4: import data from first sources

Start with identity directory, Microsoft 365 or Google Workspace admin panel, EDR, backup, DHCP, firewalls and invoices. Do not wait for perfect data.

Step 5: remove duplicates

The same laptop may appear in EDR, DHCP, identity directory and invoice data. Define a matching rule, for example by serial number, device name, user and MAC address.

Step 6: assign owners

Every critical asset must have a business owner and technical owner. “IT” as owner of everything is weak evidence.

Step 7: assess criticality and data

The process owner should define whether the asset supports a critical service and what data it processes.

Step 8: add security status

For every critical asset, check MFA, backup, EDR, updates, logs, suppliers and public exposure.

Step 9: mark gaps

Missing owner, missing backup, missing MFA, missing EDR, missing restore test or public port should have a status and remediation action.

Step 10: introduce review cycle

The register must be updated periodically and after changes. A good minimum for SMEs is quarterly review of critical assets and annual full review.

Simple inventory update workflow

New asset

  1. The department requests a new system, application or service.
  2. The register owner adds the asset with basic fields.
  3. IT or supplier defines the technical configuration.
  4. The business owner classifies data and criticality.
  5. Security or vCISO defines minimum safeguards.
  6. The asset is added to the register before production launch.

Asset change

  1. A change in system, supplier, data or access triggers register update.
  2. The technical owner updates status.
  3. The business owner confirms process impact.
  4. Open risks go to the action plan.

Asset retirement

  1. The owner requests system or service retirement.
  2. IT removes access and integrations.
  3. Data is returned, archived or deleted according to decision.
  4. Backup and logs are retained according to retention rules.
  5. The asset receives disabled status.

Which evidence should be shown for NIS2?

Inventory evidence

  • asset register with update date
  • critical system map
  • data register and classification
  • administrator account register
  • critical supplier register
  • internet-facing asset list
  • systems without owner list

Visibility evidence

  • identity directory export
  • EDR or MDM device report
  • backup report
  • network scan or firewall review report
  • public services and domains report
  • SaaS application report

Review evidence

  • quarterly critical asset review minutes
  • list of changes since last review
  • list of removed or consolidated assets
  • remediation action list
  • exception acceptance decisions
  • board report

Which metrics are worth measuring?

Completeness metrics

  • number of assets in the register
  • percentage of assets with owner
  • percentage of assets with defined criticality
  • percentage of critical systems with data type described
  • number of assets without technical source

Security metrics

  • percentage of critical systems with MFA
  • percentage of devices with EDR or antivirus
  • percentage of critical systems with backup
  • number of systems without restore test
  • number of assets with critical vulnerabilities
  • number of public administrative services

Visibility metrics

  • number of new assets detected outside the process
  • number of unknown devices on the network
  • number of SaaS tools detected from invoices
  • number of assets without technical owner
  • time to add a new asset to the register

Governance metrics

  • number of open remediation actions
  • number of overdue actions
  • number of accepted exceptions
  • inventory completeness trend
  • trend of critical assets without baseline safeguards

Common SME mistakes

Mistake 1: inventory as a one-time project

The company creates a spreadsheet before an audit, then nobody updates it. After three months, the register no longer reflects reality.

Mistake 2: only devices, no applications and SaaS

Modern SMEs often have more risk in SaaS services than in laptops. The register must include cloud tools and business applications.

Mistake 3: no business owners

IT knows that the system exists, but not how important it is for the process or what data it contains.

Mistake 4: no public attack surface

The company knows laptops, but not which domains, subdomains, ports and admin panels are reachable from the internet.

Mistake 5: suppliers omitted

An IT, backup, hosting or SaaS provider may have more impact on continuity than an internal laptop.

Mistake 6: no security status

The system name alone is not enough. The register should show MFA, backup, EDR, logs, updates and restore tests.

Mistake 7: no asset retirement

Old systems, unused accounts, abandoned subdomains and forgotten test environments are often the easiest targets.

Mistake 8: looking for the perfect tool instead of the process

A tool helps, but it does not replace decisions: who owns it, what is critical, what must be fixed and who closes gaps.

30, 60 and 90-day action plan

First 30 days

  • assign asset inventory owner
  • define register scope
  • prepare a simple spreadsheet with mandatory fields
  • import users and administrators
  • import devices from EDR, MDM or antivirus
  • collect SaaS services from invoices and contracts
  • identify critical systems
  • present first asset map to the board

Days 31 to 60

  • add business and technical owners
  • mark asset criticality
  • add data types processed in systems
  • check MFA for critical systems
  • check backup and restore tests
  • check public IP addresses, domains and admin panels
  • add suppliers and subcontractors
  • create gap and remediation list

Days 61 to 90

  • perform first quarterly critical asset review
  • compare register with DHCP, DNS, EDR, backup and invoices
  • remove or explain unknown devices and services
  • close key gaps: missing owner, missing backup, missing MFA, public exposure
  • prepare NIS2 evidence report
  • define update cycle after changes
  • add inventory to procurement and system onboarding processes
  • approve 12-month roadmap

Minimum board report

The board does not need the list of every laptop. It needs to see risk, gaps and decisions.

The report should include:

  • number of assets in the register
  • number of critical systems
  • number of assets without owner
  • number of critical systems without backup
  • number of critical systems without MFA
  • number of internet-facing assets
  • number of critical suppliers
  • top gaps and remediation actions
  • risks requiring board decision

Business example

A services company has 85 employees. It uses Microsoft 365, CRM, invoicing system, file repository, marketing tools, an external IT provider and several SaaS applications bought by business departments. The board asks whether the company is ready for NIS2 requirements, but IT does not have a complete asset list.

The company starts without an expensive enterprise tool. It creates an asset register spreadsheet, exports users and devices from Microsoft 365 and EDR, collects SaaS invoices, checks backup, lists domains, public IPs and suppliers. After one month, it discovers 14 SaaS tools outside IT awareness, 6 administrator accounts without formal owner, 3 critical systems without confirmed restore test and 2 old subdomains pointing to unused services.

After 90 days, the company has an asset register, owners, criticality, MFA status, backup status and supplier status. It is not yet an enterprise platform, but the company can show the board and auditor what it has, what is critical, where gaps exist and what actions are in progress.

How can ccyber.io help?

ccyber.io helps SMEs build asset inventory and visibility aligned with NIS2 without overloading the company with unnecessary enterprise tools. We start with process, data sources and a practical register, and only then choose automation.

We can support your organization with:

  • NIS2 asset inventory readiness assessment
  • asset register design for SMEs
  • critical system identification
  • data and critical services map
  • exports from Microsoft 365, Google Workspace, EDR, backup, DHCP, DNS and firewalls
  • Shadow IT and Shadow SaaS discovery
  • supplier and supplier access register
  • public attack surface list
  • asset inventory metrics for the board
  • evidence pack for NIS2, ISO 27001, customer audit and cyber insurance
  • 30, 60, 90-day and 12-month roadmap

The best first step is an Asset Visibility for NIS2 Workshop. In a short workshop, the company can determine which assets it already sees, which are hidden, which data sources can be used without new costs and what register is sufficient for the first stage.

FAQ

Does NIS2 require an expensive CMDB?

No. NIS2 requires risk management and asset management as part of security measures, but it does not prescribe a specific tool. For SMEs, a working process and evidence matter more.

Is a spreadsheet enough?

At the start, yes, if it has an owner, versioning, mandatory fields, recurring review and is compared with technical data. Long term, it can be replaced with a lightweight ITSM or asset management tool.

How often should the asset register be updated?

Critical assets should be reviewed at least quarterly and after every material change. Full inventory review can be done annually or more often if the company changes quickly.

What matters more: devices or applications?

Both matter. In many SMEs, the greatest risk is now in SaaS, administrator accounts, cloud services, public assets and suppliers, not only in laptops.

How do we detect assets IT does not know about?

Check invoices, card payments, OAuth apps, SSO logins, DNS, department surveys, project repositories and supplier lists. These often reveal Shadow IT.

Do we need to scan the network?

It is useful, but should be done carefully. Network scans help detect devices and services, but in production and OT environments they should be planned with responsible teams.

Which assets are most important for NIS2?

Systems supporting critical services, identity, email, backup, finance systems, production systems, customer data, critical suppliers and internet-facing assets.

Where should we start?

Start with critical systems, users, administrators, devices, SaaS, backup, public IP addresses, domains and suppliers. Then assign owners and security status.

Summary

Full asset inventory and visibility aligned with NIS2 does not have to begin with expensive enterprise tools. For SMEs, the key is to build a real, current and used asset register that connects devices, applications, data, accounts, cloud, suppliers, backup, public exposure and business criticality.

The greatest value comes from a simple process: collect data from existing sources, assign owners, mark criticality, check baseline safeguards, compare the register with reality and regularly report gaps to the board.

The best rule is: do not start by asking which tool to buy. Ask whether the company can say today what it has, what is critical, where the data is, who has access, what is exposed to the internet and what it still cannot see.

Sources

How to Get Cheaper Cyber Insurance? Implement These Controls Now

Cheaper cyber insurance does not come from simply declaring that the company “cares about security”. Insurers look at real controls, incident history, industry, revenue, data, suppliers and the company’s ability to recover after an attack. The biggest impact on insurability and policy terms usually comes from MFA, tested backup, EDR, updates, administrator account control, secure remote access, email protection, training, payment procedures, incident response plan, BCP, supplier control and an evidence pack. There is no guaranteed premium reduction, but well-documented safeguards can help obtain better terms, higher limits, fewer exclusions or smoother renewal.

Prepared by: CCyber Editorial Team

Short answer

To increase the chance of cheaper cyber insurance, a company should improve what insurers see as the biggest risk sources: no MFA, untested backup, weak endpoint protection, outdated systems, excessive administrator rights, uncontrolled remote access, weak email protection, no training, no payment procedure, no incident response plan and no evidence. A lower premium cannot be guaranteed because pricing depends on industry, revenue, claims history, coverage scope, limits and the insurance market. However, a company can improve its insurability and position in discussions with a broker and insurer. The key point is not to declare safeguards by word alone. Every questionnaire answer should have scope, owner and evidence.

Last updated

July 2026

Who this article is for

  • SME owners and boards planning cyber insurance
  • companies renewing a cyber policy and wanting better terms
  • CFOs, COOs, CEOs and risk or budget owners
  • CISOs, vCISOs, CTOs, CIOs and IT owners
  • compliance, risk, legal, DPO and internal audit teams
  • companies after an incident that want to rebuild insurer trust
  • software houses, SaaS companies, e-commerce, professional services and manufacturing
  • organizations preparing for NIS2, ISO 27001, customer audits or cyber risk assessment

Key takeaways

  1. The best way to obtain better cyber insurance terms is to reduce real risk, not to make the questionnaire look better.
  2. The most commonly assessed areas are MFA, backup, EDR, updates, administrators, remote access, phishing, ransomware, incident response and suppliers.
  3. The insurer may ask about technical, process and human controls. The company should prepare evidence, not only declarations.
  4. Not every safeguard will automatically reduce the premium, but missing basic controls may make it harder to obtain coverage, increase the deductible or reduce coverage scope.
  5. The biggest mistake is answering “yes” when a control only works partially or has never been tested.

Can a company really get cheaper cyber insurance?

Yes, but the word “cheaper” must be understood correctly. The insurer does not sell a discount for a tool name. The insurer assesses risk. If the company can show that it reduced incident likelihood and can limit impact, it may have a better position when discussing premium, limits, exclusions and renewal.

Better preparation may help with:

  • obtaining an offer where coverage would otherwise be difficult
  • lower premium if the insurer recognizes security maturity
  • higher liability limit
  • lower deductible
  • fewer additional requirements before policy binding
  • smoother renewal
  • fewer problems during claims handling

Important: cyber insurance is not a reward for having tools. It is a mechanism for transferring part of the risk. The company still needs to manage risk, maintain safeguards and update information provided to the broker and insurer.

How does an insurer look at a company?

The insurer wants to answer a simple question: how likely is this company to have an expensive incident and how large could that cost be?

Common assessment factors

  • industry
  • revenue
  • employee count
  • type of data
  • online sales
  • dependency on IT systems
  • incident history
  • previous claims
  • security control maturity
  • backup and recovery quality
  • supplier risk
  • regulatory compliance
  • insurance questionnaire results

You cannot change all factors. You cannot easily change the industry or incident history. But you can improve safeguards, prepare evidence, organize processes and show that the company has real control over cyber risk.

The key rule: cheaper coverage starts with evidence

If a broker or insurer asks whether the company has MFA, backup, EDR and training, “yes” is too weak. The company must show exactly where the control works, who is covered, which exceptions exist and when it was last checked.

A good answer has three elements

  • Scope: which systems, accounts, locations and employees are covered
  • Status: implemented, partly implemented, planned or not applicable
  • Evidence: report, configuration, test, procedure, record or system screenshot

Example

Weak: “We have backup”.

Strong: “Backup covers Microsoft 365, file server, finance system and CRM. Copies are separated from production. The latest restore test was performed on 12 June 2026. The test result and remediation actions are in the report.”

15 controls worth implementing before policy discussions

1. MFA for critical accounts

MFA is one of the most important controls from the insurer perspective. It protects against account takeover after password theft, phishing or credential leaks.

What to implement?

  • MFA for email
  • MFA for administrators
  • MFA for VPN and remote access
  • MFA for cloud and admin panels
  • MFA for finance and backup systems
  • exception register
  • regular review of accounts without MFA

Evidence for the insurer: MFA report, list of covered accounts, exception list and risk acceptance decisions.

2. Backup with restore test

Backup without testing is a promise, not evidence. The insurer wants to know whether the company can recover after ransomware, failure, human error or data loss.

What to implement?

  • backup of critical data
  • backup of Microsoft 365 or Google Workspace if critical
  • backup of CRM, ERP, finance system and files
  • copies separated from production
  • backup account protection
  • restore test for critical systems
  • backup error report

Evidence for the insurer: backup report, restore test report, RTO, RPO and remediation list.

3. EDR or effective endpoint protection

The insurer will ask whether laptops, servers and workstations are protected. Antivirus alone may not be enough if nobody monitors alerts or if protection does not cover all devices.

What to implement?

  • protection for all laptops and servers
  • central management
  • high-risk alerts
  • alert response process
  • report of devices without protection
  • regular agent health review

Evidence for the insurer: EDR or antivirus coverage report, exception list, alert report and response procedure.

4. Updates and vulnerability management

Unpatched systems, VPNs, firewalls, servers and internet-facing applications are common entry points. The insurer may ask how quickly the company patches critical vulnerabilities.

What to implement?

  • automatic updates where possible
  • regular vulnerability scanning
  • priority for critical vulnerabilities
  • remediation deadlines
  • exception register
  • retest after remediation
  • monitoring of internet-facing systems

Evidence for the insurer: vulnerability report, patch management report and overdue vulnerability list.

5. Administrator account control

Administrator accounts are a shortcut to the whole company for an attacker. Insurers pay close attention to MFA, number of administrators, named accounts and access reviews.

What to implement?

  • administrator account list
  • MFA for administrators
  • separate admin accounts and daily-use accounts
  • named accounts instead of shared accounts
  • least privilege
  • Just-in-Time Access where possible
  • quarterly access review

Evidence for the insurer: administrator account report, PIM or PAM report, access review and list of removed permissions.

6. Secure remote access

Remote access is convenient, but it is also one of the most important risk points. Public RDP, old VPNs, supplier accounts without MFA and permanent service access are especially dangerous.

What to implement?

  • MFA for remote access
  • no public RDP unless absolutely required
  • VPN or ZTNA aligned with company policy
  • supplier access limitation
  • session logging
  • time-bound access for service work
  • regular remote account review

Evidence for the insurer: remote access model description, MFA report, supplier access list and session logs.

7. Email and phishing protection

Email is often where fraud, account takeover and fake payment attempts begin. The insurer may ask about MFA, filtering, SPF, DKIM, DMARC and training.

What to implement?

  • MFA for email
  • phishing and malware filtering
  • SPF, DKIM and DMARC
  • mail forwarding rule control
  • phishing reporting procedure
  • phishing simulations with debriefing
  • employee training

Evidence for the insurer: email configuration report, SPF/DKIM/DMARC status, training report and phishing report register.

8. Cyber awareness training

Training should not be one annual presentation. From the insurer perspective, it matters more whether the company teaches employees to recognize phishing, report mistakes, use MFA and verify payments.

What to implement?

  • starter training for new employees
  • phishing training
  • MFA and password training
  • finance training on fake payments
  • short quarterly reminders
  • knowledge test
  • channel for reporting suspicious situations

Evidence for the insurer: training plan, participant list, materials, test results and reporting metrics.

9. Payment procedure and BEC

Business email compromise and fake payments may not be covered by a standard policy or may have sublimits. Regardless of coverage, the company should reduce fake payment risk.

What to implement?

  • second channel for supplier bank account changes
  • two-person rule for larger transfers
  • ban on using phone numbers from suspicious messages
  • bank account change register
  • finance and board training
  • response procedure after suspicious payment

Evidence for the insurer: payment procedure, second-channel confirmation register and finance training report.

10. Incident response plan

The policy may provide access to experts, but the company still needs to know what to do in the first hour of an incident. The response plan should be short, current and exercised.

What to implement?

  • roles and responsibilities
  • emergency contact list
  • ransomware playbook
  • email takeover playbook
  • evidence preservation procedure
  • broker and insurer contact procedure
  • tabletop exercise

Evidence for the insurer: incident response plan, contact list, tabletop report and remediation action list.

11. BCP and disaster recovery

Cyber insurance may cover downtime costs, but the insurer will want to know whether the company can limit downtime and operate in emergency mode.

What to implement?

  • critical process list
  • RTO and RPO
  • system recovery plan
  • manual work plan
  • crisis communication plan
  • restore test
  • service recovery priorities

Evidence for the insurer: BCP, DRP, restore test report, downtime cost analysis and board decisions.

12. System and data inventory

If the company does not know which systems and data it has, it cannot answer insurer questions well. Inventory is the foundation for risk and coverage scope.

What to implement?

  • system register
  • critical data register
  • system owners
  • data owners
  • backup status
  • MFA status
  • supplier status

Evidence for the insurer: asset register, critical system map and data classification.

13. Supplier control

An incident at an IT, cloud, hosting, backup or finance system provider can stop the company. The insurer may ask whether the company manages third-party risk.

What to implement?

  • critical supplier register
  • supplier risk assessment
  • security requirements in contracts
  • MFA for supplier access
  • supplier incident notification rules
  • exit plan for critical suppliers
  • supplier access review

Evidence for the insurer: supplier register, risk assessments, security clauses and list of suppliers with access.

14. Logs, monitoring and evidence of actions

After an incident, the company must reconstruct what happened. Missing logs make response, investigation, notifications and claims handling harder.

What to implement?

  • sign-in logs
  • administrator logs
  • email logs
  • cloud logs
  • EDR logs
  • central log storage
  • alerts on high-risk actions
  • risk-based log retention

Evidence for the insurer: log source report, SIEM or log management configuration, sample alerts and retention policy.

15. Insurance evidence pack

The best safeguards will not help much in a broker conversation if the company has no evidence. An evidence pack shortens discussions, reduces ambiguity and supports renewal.

What to prepare?

  • MFA report
  • backup and restore test report
  • EDR report
  • patch management report
  • administrator list
  • access review
  • incident response plan
  • BCP and DRP
  • training report
  • supplier register
  • gap and remediation report

Evidence for the insurer: organized evidence repository with dates, owners and freshness status.

What may influence policy terms the most?

Every insurer has its own assessment model, but in practice the strongest weight often goes to controls that reduce ransomware, account takeover and downtime.

High-impact controls

  • MFA for email, administrators and remote access
  • tested backup separated from production
  • EDR or strong endpoint protection
  • no public RDP
  • updates for critical systems
  • administrator account control
  • incident response plan and tabletop
  • BEC payment procedure
  • email protection and phishing training
  • critical supplier management

What should be prepared for the broker?

Basic pack

  • company and industry description
  • revenue
  • employee count
  • countries of operation
  • data types
  • critical systems
  • incident history
  • expected coverage scope

Cyber pack

  • MFA
  • backup
  • EDR
  • updates
  • remote access
  • email
  • administrators
  • training
  • incident response
  • suppliers

Governance pack

  • top risks
  • cost of one day of downtime
  • gaps against questionnaire
  • remediation plan
  • budget decisions
  • risk acceptances

What not to do if you want better terms?

Do not declare safeguards without evidence

“We have MFA” is risky if MFA does not cover administrators, VPN or suppliers.

Do not hide exceptions

Exceptions are normal, but they must be known, documented and accepted. A hidden exception may become a problem after an incident.

Do not confuse a tool with a process

The company may have EDR, but nobody responds to alerts. It may have backup, but nobody tests it. It may have an incident plan, but nobody knows it.

Do not send the questionnaire without review

The insurance questionnaire should be reviewed by IT, security, the board, finance, legal and process owners.

Do not buy a policy without checking exclusions

A cheaper policy with large exclusions may not protect against the scenario most realistic for the company.

30, 60 and 90-day action plan

First 30 days

  • collect the latest broker or insurer questionnaire
  • assign policy readiness owner
  • check MFA on email, administrators and VPN
  • check backup scope
  • check EDR or endpoint protection
  • prepare administrator list
  • check public RDP and remote access
  • create a list of gaps and quick fixes

Days 31 to 60

  • perform data restore test
  • enable MFA for missing critical accounts
  • perform access review
  • remove former employee accounts
  • organize supplier accounts
  • prepare incident response plan
  • implement payment and second-channel procedure
  • train employees on phishing, MFA and BEC

Days 61 to 90

  • run ransomware or email takeover tabletop
  • update BCP and DRP
  • assess critical suppliers
  • launch evidence repository
  • prepare board report
  • compare policy scope with real risk scenarios
  • discuss exclusions and sublimits with broker
  • define action plan before policy renewal

Metrics worth showing to the board and broker

Technical 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 administrator accounts
  • number of accounts without owner

Process metrics

  • date of latest access review
  • number of trained employees
  • time to remove access after employee departure
  • number of suppliers without risk assessment
  • date of latest incident exercise
  • number of open remediation actions

Insurance metrics

  • number of questionnaire questions answered “partly”
  • number of declarations without evidence
  • number of exceptions requiring acceptance
  • number of requirements to meet before renewal
  • number of exclusions relevant to company scenarios

Common company mistakes

Mistake 1: looking for a cheaper policy without reducing risk

The broker can compare offers, but if company risk is high, price competition has limited value.

Mistake 2: no backup test

Backup marked as “working” in a questionnaire without a restore test is weak evidence.

Mistake 3: MFA only for part of the company

MFA on standard accounts is not enough if administrators, VPN, suppliers and the finance system are excluded.

Mistake 4: IT provider completes the questionnaire alone

The IT provider knows part of the technology, but usually does not know the full picture of data, finance, incident history, suppliers and board decisions.

Mistake 5: no BEC procedure

Fake payments may be excluded or limited. A second-channel procedure is inexpensive and very important.

Mistake 6: no training evidence

Training without participant lists, programme and test results is hard to show in an audit.

Mistake 7: no updates after changes

The company changes cloud, supplier, system or data scope, but does not update broker and insurer information.

Mistake 8: buying a policy without reading exclusions

The key question is not only “how much does the policy cost”, but what it actually covers and excludes.

Business example

A services company has 70 employees and wants to buy cyber insurance. The first offer is expensive, and the broker points to questionnaire issues: MFA works only in Microsoft 365, backup has not been tested for a year, there is no formal incident response plan, EDR does not cover all devices and no payment procedure exists.

The company does not immediately look for another cheaper offer. First, it closes key gaps over 60 days. It enables MFA for administrators and VPN, performs a restore test, completes EDR coverage, prepares an incident response plan, trains employees, implements second-channel verification for bank account changes and collects evidence.

After the questionnaire update, the broker has stronger material for discussions with insurers. The company is not guaranteed the lowest premium, but it gains a better negotiation position, less ambiguity and a greater chance of a policy that matches real risk scenarios.

How can ccyber.io help?

ccyber.io helps SMEs prepare for cyber insurance in a practical, risk-based and evidence-driven way. We do not promise an automatic premium reduction because the decision belongs to the insurer. We help improve insurability, close key gaps and prepare an evidence pack for the broker.

We can support your organization with:

  • cyber insurance readiness assessment
  • broker or insurer questionnaire review
  • MFA, backup, EDR and remote access verification
  • data restore test
  • access review and administrator account review
  • incident response plan and ransomware playbook
  • payment and business email compromise procedure
  • phishing, MFA and BEC training
  • critical supplier register and assessment
  • evidence pack for broker and insurer
  • board report with gaps, risks and action plan
  • 30, 60, 90-day and renewal roadmap

The best first step is a Cyber Insurance Cost Reduction Readiness Workshop. In a short workshop, the company can check which safeguards are already implemented, where evidence is missing, which gaps most affect broker discussions and what should be done before sending the questionnaire.

FAQ

Will MFA reduce the premium?

There is no guarantee, but MFA is one of the most important controls assessed by insurers. Missing MFA may make it harder to obtain good terms.

Is backup enough for cheaper cyber insurance?

Not backup alone. Restore testing, separated copies, backup account protection and critical service recovery planning are important.

Is EDR required?

It depends on the insurer, industry and company size. In practice, endpoint protection, alert monitoring and incident response are very commonly assessed.

Does ISO 27001 or Cyber Essentials help?

It may help as evidence of maturity, but the insurer may still ask about specific controls such as MFA, backup, EDR, incident response and suppliers.

Can policy terms be negotiated?

Yes, through a broker the company can discuss coverage, limits, exclusions, sublimits and requirements. Better security evidence may make that discussion easier.

Is the cheapest policy always better?

No. A cheaper policy may have lower limits, higher deductible, more exclusions or missing coverage for important scenarios such as BEC or supplier incidents.

What if the company has gaps?

Do not hide them. Describe the actual state, scope, remediation plan and deadlines. A “partially implemented” answer with evidence is better than an unsupported declaration.

Where should we start?

Start with MFA, backup testing, endpoint protection, administrator review, secure remote access, incident response plan and evidence pack for the broker.

Summary

Cheaper cyber insurance does not start with price negotiation, but with reducing real risk. The insurer will look at whether the company has basic safeguards and whether it can prove them.

The most important solutions are MFA, tested backup, EDR, updates, administrator control, secure remote access, email protection, training, payment procedure, incident response, BCP, supplier control, logs and evidence repository.

The best rule is: do not try to buy a cheaper policy based on wishful answers. Implement basic controls, test them, collect evidence and only then discuss terms with your broker.

Sources

Does My Company Fall Under NIS2? A Simple Guide for SMEs

An SME should not answer the NIS2 applicability question only based on employee count or business activity code. Five things must be checked: sector, company size, size-independent exceptions, supply chain role and current national rules implementing NIS2. A small company often will not be directly an essential or important entity, but it may be indirectly affected by customer requirements if it provides IT, software, cloud, managed services, components, maintenance, data or processes to regulated entities.

Prepared by: CCyber Editorial Team

Short answer

Not every small or medium-sized company in Poland is directly subject to NIS2. The fact that a company is an SME is not enough. The sector, type of services, company size, group relationships, size-independent exceptions and whether the company is a supplier to a regulated entity must be checked. As a rule, NIS2 mainly covers medium-sized and large entities in defined sectors. However, small and micro companies may be covered in exceptional cases or affected indirectly through customer requirements, contracts, security questionnaires and supplier audits. The safest approach is to prepare a short applicability assessment with date, sources, board decision and a minimum cybersecurity action plan.

Last updated

July 2026

Who this article is for

  • small and medium-sized business owners
  • SME boards checking NIS2 obligations
  • software houses, SaaS companies and application providers
  • IT, cloud, hosting, backup, SOC, MDR and managed service providers
  • manufacturing, logistics, healthcare, food, chemical and technology companies
  • integrators, maintenance providers, OT and industrial automation suppliers
  • companies serving customers from regulated sectors
  • compliance, risk, legal, IT, security, CFO, COO, CTO and customer audit owners

Key takeaways

  1. NIS2 does not automatically cover every small company. Sector, service, size and exceptions must be checked first.
  2. A medium-sized company operating in a NIS2 sector should seriously assess direct applicability.
  3. A small or micro company may be directly covered in selected cases, for example because of a special type of service or its importance for the state, economy or public safety.
  4. Even if the company is not directly in scope, it may be indirectly affected by NIS2 as a supplier to an essential or important entity.
  5. The best first step is an applicability assessment, list of regulated customers, service map and basic cybersecurity evidence pack.

First, an important caveat

NIS2 is a European Union directive. This means that the practical answer in Poland must look at the directive, but also at national implementing rules, especially amendments to the national cybersecurity system. Therefore, the answer to “does my company fall under NIS2?” should include a date and the legal version used.

This guide helps prepare a practical assessment. It does not replace individual legal advice, but it shows how an SME board should organize the topic before speaking with a lawyer, auditor, customer or cybersecurity provider.

The simplest answer for SMEs

If the company is micro or small, does not operate in a special sector and does not provide critical services to larger entities, it will probably not be directly an essential or important entity. This does not mean it can ignore the topic.

If the company is medium-sized, operates in one of the NIS2 sectors or serves customers from those sectors, a formal applicability assessment should be performed.

If the company provides IT, cloud, managed, security, DNS, hosting, telecommunications, trust, domain registration services or maintains customer systems, NIS2 should be treated as a priority regardless of whether the company is ultimately directly covered.

5 questions that decide the topic

  1. Does the company operate in a sector covered by NIS2?
  2. Does the company meet the size criterion of a medium-sized or large enterprise?
  3. Does the company fall under a size-independent exception?
  4. Is the company a supplier to a regulated entity?
  5. What do current national rules and customer requirements say?

Only answers to these questions allow a reasonable conclusion. A business activity code alone, employee count alone or the general label “IT” is not enough.

Step 1: check the sector

NIS2 covers sectors of high criticality and other critical sectors. For SMEs, the key point is to check whether the company’s real activity fits one of these sectors or whether the company serves customers from those sectors.

Sectors of high criticality

  • energy
  • transport
  • banking
  • financial market infrastructures
  • healthcare
  • drinking water
  • waste water
  • digital infrastructure
  • ICT service management
  • public administration
  • space

Other critical sectors

  • postal and courier services
  • waste management
  • chemicals
  • food production, processing and distribution
  • manufacturing of selected products, including medical devices, computers, electronics, machinery, vehicles and transport equipment
  • digital providers
  • research organizations

What does this mean for SMEs?

A small manufacturing company may think NIS2 does not concern it, but if it produces components for the medical, transport, energy or technology sector, it may receive customer requirements. A software house may not be an obvious essential entity, but if it maintains a system for a hospital, infrastructure operator, bank or managed service provider, NIS2 requirements may appear in the contract.

Step 2: check company size

As a rule, NIS2 covers medium-sized and large entities in the sectors listed by the directive. In practice, employee count, turnover, balance sheet total and links with other entities must be checked.

EU SME definition thresholds

  • microenterprise: fewer than 10 employees and turnover or balance sheet total up to EUR 2 million
  • small enterprise: fewer than 50 employees and turnover or balance sheet total up to EUR 10 million
  • medium-sized enterprise: fewer than 250 employees and turnover up to EUR 50 million or balance sheet total up to EUR 43 million

For NIS2, it is especially important whether the company qualifies as a medium-sized enterprise or exceeds the thresholds for a medium-sized enterprise. Partner and linked enterprises must also be considered because the corporate group may affect qualification.

Practical rule

If the company has fewer than 50 employees and does not provide special services, it will often be outside the direct NIS2 scope. If the company has 50 to 249 employees and operates in a NIS2 sector, applicability assessment becomes a board-level task.

Step 3: check size-independent exceptions

Some entities may be covered by NIS2 regardless of size. This is especially important for technology, telecommunications, domain, trust service and entities of special importance for society or the economy.

Example categories to check regardless of size

  • providers of public electronic communications networks
  • providers of publicly available electronic communications services
  • trust service providers
  • top-level domain name registries
  • DNS service providers
  • domain name registration service providers
  • entities that are the sole provider of a service essential for critical societal or economic activities in a Member State
  • entities whose disruption could significantly affect public safety, public health or systemic risk

What does this mean for SMEs?

A small company should not automatically assume it is outside the scope. If it provides a service of special importance, operates in digital infrastructure or is essential for a critical customer service, deeper analysis is needed.

Step 4: determine whether the company may be essential or important

NIS2 divides entities into essential and important. The distinction matters for supervision and enforcement. For SMEs, the first priority is to determine whether the company is directly in scope at all.

Essential entity

An essential entity is generally an organization of higher importance, often larger and operating in high criticality sectors or meeting special criteria. Essential entities are usually subject to stronger supervision.

Important entity

An important entity is an organization covered by NIS2 that does not qualify as essential. Risk management and incident reporting obligations still matter, but the supervisory regime may differ.

Conclusion for SMEs

For most SMEs, the first question is: are we directly in scope? Only then is it useful to decide whether the status is essential or important.

Step 5: check indirect impact through customers

This is the most important part for many SMEs. The company may not be directly an essential or important entity, but it may serve customers that are subject to NIS2. Then requirements will appear in contracts, security questionnaires, audits, procurement procedures and access requirements.

Indirect NIS2 impact may affect your company if:

  • it maintains a regulated customer’s system
  • it provides software for healthcare, energy, transport, finance or critical manufacturing
  • it has administrator access to a customer environment
  • it stores regulated customer data
  • it provides IT, cloud, hosting, backup, SOC, MDR or helpdesk services
  • it supports OT, production or logistics systems
  • it is a subcontractor of a larger ICT provider
  • it supplies components or services whose failure could stop a customer’s service

Typical requirements from a regulated customer

  • MFA for supplier access
  • administrator account control
  • incident reporting within short timelines
  • audit rights
  • backup and recovery tests
  • incident response procedure
  • employee training
  • subcontractor assessment
  • logs and monitoring
  • vulnerability remediation evidence

Is a business activity code enough?

No. A business activity code may be a useful starting point, but it does not replace analysis of real activity. NIS2 concerns service types, sectors, the importance of activity, scale and the organization’s role. A company may have a broad activity code, but in practice provide a critical service to a regulated customer. It may also have a technology code but operate outside NIS2 scope.

What to check besides activity code?

  • actual services provided to customers
  • customer sectors
  • data and systems the company can access
  • contracts and SLAs
  • customer dependency on the company’s service
  • capital links
  • support for public entities or regulated sectors

Simple decision: 4 possible assessment outcomes

Outcome 1: probably directly covered by NIS2

The company operates in a NIS2 sector, meets the size threshold or falls under a size-independent exception. In this case, a fuller compliance and evidence programme is needed.

Outcome 2: requires deeper legal analysis

The company operates close to a regulated sector, has an unusual role, is part of a group, provides a service of special importance or its qualification depends on national rules.

Outcome 3: not directly covered, but indirectly affected

This is a very common scenario for SMEs. The company may not be a formal regulated entity, but customers will require specific safeguards and evidence.

Outcome 4: currently out of scope, but requires monitoring

The company does not operate in a covered sector, does not meet the size threshold and has no regulated customers. However, changes in law, customers and business model should be monitored.

Practical SME question list

About the company

  • how many employees does the company have?
  • what is its turnover and balance sheet total?
  • does it belong to a corporate group?
  • does it have linked or partner companies?
  • in which countries does it operate?

About services

  • what services does the company actually provide?
  • are the services digital or technology-based?
  • does the company provide managed or security services?
  • does the company provide cloud, hosting, DNS, domain or communication services?
  • does the company maintain customer systems?

About customers

  • do customers operate in NIS2 sectors?
  • do customers require security questionnaires?
  • do customers require incident reporting?
  • do customers have audit rights?
  • is the company a subcontractor of a larger provider to a regulated sector?

About access and data

  • does the company have administrator access to customer systems?
  • does it store customer data?
  • does it process personal or confidential data?
  • does it access customer production environments?
  • could the company’s outage stop a customer service?

Examples for SMEs

Software house building an application for a hospital

The software house may not be directly an essential or important entity if it does not meet NIS2 criteria. However, it may be an important supplier to a healthcare entity. The customer may require secure SDLC, testing, vulnerability management, SLA, incident reporting and subcontractor controls.

Small IT company supporting a medium-sized manufacturing firm

If the manufacturing customer is subject to NIS2, the IT provider may be covered by contractual requirements. This is especially likely if it has administrator access, manages backup, user accounts, networks or critical systems.

B2C online shop

A typical small online shop will usually not be directly covered only because it operates online. However, scale, service type, possible platform status, customer data, payment providers and contractual requirements should be checked.

SaaS company with 80 employees serving finance and healthcare

Such a company should perform an applicability assessment. It may be a medium-sized enterprise, a digital or ICT service provider and a supplier to regulated customers. Even if final legal qualification requires deeper analysis, customer requirements are highly likely.

Small manufacturing company with 35 employees

Size alone may suggest no direct applicability. However, if the company supplies critical components to healthcare, energy, transport or large regulated customers, it may be affected through the supply chain.

What to do if the company probably falls under NIS2?

If the assessment indicates that the company may be directly covered by NIS2, it should not wait for an audit or customer letter. A readiness plan should be prepared.

Minimum actions

  • confirm applicability with a lawyer or regulatory advisor
  • assign NIS2 programme owner
  • prepare cyber risk register
  • identify critical systems and services
  • implement MFA for critical accounts
  • check backup and perform restore test
  • prepare incident response plan
  • prepare incident reporting procedure
  • assess critical suppliers
  • train the board and employees

What to do if the company is not directly covered but is a supplier?

This is the most common scenario for SMEs. The company should prepare “NIS2 supplier readiness”, meaning the evidence pack and controls that regulated customers will expect.

Prepare supplier minimum

  • service description and responsibility boundaries
  • information security policy
  • MFA report
  • backup and restore test report
  • incident response plan
  • customer incident reporting procedure
  • subcontractor register
  • assessment of own suppliers
  • employee training report
  • remediation action plan

Business benefit

A supplier that can quickly answer a NIS2 questionnaire, show evidence and explain its security model has an advantage when selling to larger customers.

What documents should be prepared?

Documents for applicability assessment

  • description of company activity
  • service list
  • customer sector list
  • employee count, turnover and balance sheet data
  • information about linked and partner companies
  • list of countries where services are provided
  • NIS2 sector analysis
  • conclusion: directly covered, indirectly affected, out of scope or requires legal analysis

Cyber minimum documents

  • system and asset register
  • cyber risk register
  • password and access policy
  • MFA report
  • access review report
  • backup procedure and restore test report
  • incident response plan
  • incident reporting procedure
  • supplier register
  • training report

Customer documents

  • security one-pager
  • security controls description
  • backup and recovery description
  • incident response process description
  • vulnerability management description
  • certification or audit list if available
  • subcontracting rules
  • contact for the person responsible for security

30, 60 and 90-day action plan

First 30 days

  • assign NIS2 topic owner
  • collect company size and group relationship data
  • prepare service and customer list
  • check NIS2 sectors
  • check size-independent exceptions
  • identify regulated customers
  • prepare initial applicability conclusion
  • present a short decision note to the board

Days 31 to 60

  • perform deeper legal analysis if needed
  • prepare cyber risk register
  • check MFA, backup, administrator access and suppliers
  • perform data restore test
  • prepare incident response plan
  • prepare customer incident reporting procedure
  • collect NIS2 requirements from customer contracts
  • prepare remediation action plan

Days 61 to 90

  • perform first access review
  • assess critical suppliers
  • train the board and employees
  • prepare customer evidence pack
  • run incident exercise
  • close the most important gaps
  • update applicability assessment
  • define quarterly review of customer requirements and legal changes

Common SME mistakes around NIS2

Mistake 1: assuming “we are small, so it does not apply”

A small company may be indirectly affected through customers or directly through an exception. Facts must be checked first.

Mistake 2: relying only on activity code

Business activity codes do not show the full picture of services, customers, system access and importance in the supply chain.

Mistake 3: not analyzing corporate links

Company size may depend on partner and linked enterprises. This can change qualification.

Mistake 4: ignoring regulated customers

The company may be outside direct scope, but a regulated-sector customer may impose contractual requirements.

Mistake 5: no evidence of decision

A verbal answer “NIS2 does not apply” is weak. A note or assessment with reasoning is needed.

Mistake 6: waiting for full certainty

Even if qualification needs clarification, the company can already implement the basics: MFA, backup, incident response, access review and training.

Mistake 7: treating NIS2 as a legal-only project

NIS2 is not only legal analysis. It also concerns cyber risk, suppliers, incidents, business continuity and evidence.

Mistake 8: no preparation for customer questionnaires

Larger companies will ask suppliers about safeguards. SMEs should have answers and evidence ready.

Which cybersecurity minimum is worth implementing regardless of applicability?

Even if the company is not directly subject to NIS2, basic safeguards are needed. They protect against ransomware, phishing, email takeover, data loss and customer relationship problems.

Minimum for SMEs

  • MFA for email, administrators, cloud and remote access
  • password manager
  • backup with restore testing
  • endpoint protection
  • updates and vulnerability management
  • phishing procedure
  • payment and second-channel procedure
  • access review
  • employee offboarding
  • incident response plan
  • supplier register
  • employee training

Business example

A SaaS company has 42 employees. It provides a document handling platform for customers in manufacturing, healthcare and local public administration. The board asks whether the company falls under NIS2 because the company itself is small and does not consider itself critical.

The assessment shows that direct applicability requires checking service details, size, customers and national rules. At the same time, it is clear that the company is indirectly affected by NIS2 because several customers may be regulated entities. Customers already ask about MFA, backup, incident reporting, security testing and subcontractors.

The company does not wait for final interpretation. Within 90 days, it prepares applicability assessment, customer evidence pack, MFA, restore test, incident response plan, customer incident reporting procedure and supplier assessment. This makes the company ready for customer requirements and further legal analysis.

How can ccyber.io help?

ccyber.io helps SMEs determine whether NIS2 may affect the company directly or indirectly. We combine legal, technical, supplier and business perspectives. We do not stop at a “yes” or “no” answer. We prepare a practical action plan and evidence pack that helps in conversations with customers, auditors and insurers.

We can support your organization with:

  • NIS2 applicability assessment for SMEs
  • KSC applicability analysis
  • sector, service and regulated customer map
  • NIS2 impact assessment for suppliers or software houses
  • NIS2 supplier readiness
  • customer evidence pack for regulated customers
  • basic cyber control gap analysis
  • cyber risk register
  • incident response plan and incident reporting procedure
  • 30, 60, 90-day and 12-month roadmap

The best first step is a NIS2 Applicability Workshop for SMEs. In a short workshop, the company can determine whether it may be directly covered, whether it is indirectly affected by customers and which minimum safeguards should be implemented regardless of final qualification.

FAQ

Does every small company fall under NIS2?

No. A small company usually is not directly covered only because it operates a business. Sector, service, exceptions and customers must be checked.

Does every medium-sized company fall under NIS2?

No. A medium-sized company is covered when it operates in a sector or provides a service covered by NIS2 or meets special criteria. Size alone is not enough.

Is checking a business activity code enough?

No. It may help, but it does not replace analysis of real activity, customers, services, data, system access and supply chain role.

Does an IT provider for a NIS2 entity also fall under NIS2?

Not always directly. However, it may be covered by customer requirements in contracts, audits, security questionnaires and incident reporting procedures.

Can a software house be covered by NIS2?

Yes, if it meets sector, size or special service criteria. Even if it is not directly covered, it may be indirectly affected as a system supplier to regulated entities.

What if we are not sure?

Prepare an applicability assessment, collect company, service and customer data, check NIS2 sectors and consult the conclusion with a lawyer or advisor. In parallel, implement basic safeguards.

Which evidence will customers need?

Most often: MFA, backup, restore test, incident response plan, access review, training, vulnerability management, supplier security and incident reporting procedure.

Where should we start?

Start with five things: service list, regulated customer list, company size data, analysis of size-independent exceptions and a quick review of basic safeguards.

Summary

The question “does my company fall under NIS2?” requires practical analysis. Checking company size or business activity code is not enough. Sector, service, exceptions, customers, capital links, access to data and systems, and current national rules must be assessed.

For many SMEs, indirect impact will be the most important issue. The company may not be a formal essential or important entity, but as a supplier to a regulated entity it will need to show safeguards, procedures and evidence.

The best rule is: do not wait for a customer questionnaire or inspection. Prepare an applicability assessment, implement the cybersecurity minimum and collect evidence that shows the company manages risk in practice.

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.