CCyber Blog

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

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

Cyber Resilience Act: What Digital Product Manufacturers Must Prepare in 2026 and 2027

The Cyber Resilience Act means that manufacturers of software, hardware and products with digital elements must prepare product security as a process, not as a one-time test. In 2026, the key tasks are vulnerability handling, reporting of actively exploited vulnerabilities and severe incidents, product inventory, product classification, SBOM, update process, reporting contact and evidence. In 2027, manufacturers must complete risk assessment, technical documentation, conformity assessment, user instructions, support period, CE marking and market surveillance readiness.

Prepared by: CCyber Editorial Team

Short answer

The Cyber Resilience Act, or CRA, changes the approach to digital product security in the European Union. A manufacturer of software, hardware, applications, components or products connected to a network must prepare not only a secure product on the day it is placed on the market, but also a security maintenance process throughout the support period. In 2026, the most important task is to prepare vulnerability handling and reporting of actively exploited vulnerabilities and severe incidents affecting product security. In 2027, manufacturers must complete full readiness: cybersecurity risk assessment, essential requirements, technical documentation, conformity assessment, EU declaration of conformity, CE marking, user instructions, support period, SBOM, security updates and evidence for market surveillance.

Last updated

July 2026

Who this article is for

  • software and hardware manufacturers
  • software houses building own products or products for customers
  • SaaS companies, digital platforms and application providers
  • manufacturers of IoT, smart devices, automation, electronics and embedded systems
  • companies building components, libraries, firmware, operating systems, security tools and network devices
  • boards, CTOs, CISOs, vCISOs, product owners, engineering managers and compliance teams
  • legal, quality, certification, procurement and B2B sales teams
  • companies preparing for CRA, NIS2, ISO 27001, IEC 62443, customer audits or EU market entry

Key takeaways

  1. CRA applies to products with digital elements, which in practice includes many software, hardware, IoT, network device, application and separately marketed component products on the EU market.
  2. 2026 is the year to prepare vulnerability and incident reporting because Article 14 obligations start applying from 11 September 2026.
  3. 2027 is the year of full product readiness because the main CRA obligations apply from 11 December 2027.
  4. The manufacturer must prepare a product security process: risk assessment, secure by design, secure by default, SBOM, vulnerability handling, updates, documentation, conformity assessment and evidence.
  5. The biggest mistake is treating CRA as a one-time certification. It is a product lifecycle process from design and development, through sales, to updates and end of support.

What is the Cyber Resilience Act?

The Cyber Resilience Act is an EU regulation that introduces horizontal cybersecurity requirements for products with digital elements. Its goal is to reduce the number of vulnerable products on the market, improve transparency for users and require manufacturers to maintain product security throughout the expected period of use.

In practice, CRA means that product security becomes a condition for entering the EU market. A manufacturer should not think only about functionality, sales and UX. It must also show that the product was designed, developed, documented, assessed and maintained according to cybersecurity requirements.

Why are 2026 and 2027 critical?

2026: reporting and compliance infrastructure

From 11 September 2026, reporting obligations for actively exploited vulnerabilities and severe incidents affecting product security will start applying. This means the manufacturer should already have a working process for detection, qualification, escalation and notification.

2027: full product requirements

From 11 December 2027, the main CRA obligations will apply. New products with digital elements made available on the EU market will need to meet the essential cybersecurity requirements. The manufacturer must have technical documentation, risk assessment, conformity assessment, instructions, support period and declaration of conformity ready.

Practical conclusion

Companies that start preparation only at the end of 2027 will be late. CRA requires changes in the product, code, architecture, documentation, supplier contracts, update process, vulnerability handling and the way product teams work.

Who is covered by CRA?

CRA applies to products with digital elements made available on the EU market. This includes final products and separately marketed components. A product with digital elements may be hardware, software or a combination of hardware and software.

Examples of products that may be in scope

  • desktop and mobile applications
  • locally installed software
  • embedded software
  • firmware
  • IoT devices
  • routers, modems, switches and network devices
  • operating systems
  • password managers
  • antivirus and security software
  • IAM, PAM, VPN and SIEM systems
  • smart home devices
  • internet-connected toys
  • wearables and health products, unless excluded by sector-specific rules
  • software or hardware components made available separately

Does CRA apply to SaaS?

This requires careful analysis. CRA applies to products with digital elements, and the definition includes remote data processing solutions if they are designed or developed by the manufacturer or under its responsibility and if their absence would prevent the product from performing one of its functions. Therefore, a SaaS company should check whether it offers a product with digital elements, component, client application, agent, installed software, device or remote data processing solution that is necessary for product functionality.

Does CRA apply to a software house?

A software house will not always be the manufacturer under CRA. If it creates custom software and the customer places the product on the market under its own brand, roles must be defined in the contract. If the software house develops and sells a product under its own name or trademark, it may be the manufacturer and should prepare for CRA obligations.

CRA roles: manufacturer, importer, distributor and others

The key role for this article is the manufacturer. This is the entity that develops or manufactures a product with digital elements, or has it designed, developed or manufactured, and markets it under its own name or trademark.

Manufacturer

The manufacturer is responsible for product security, risk assessment, requirements, technical documentation, conformity assessment, declaration of conformity, CE marking, support period, updates and vulnerability handling.

Importer

The importer places on the EU market a product from a manufacturer outside the EU. It must make sure the product meets the requirements and that the manufacturer has performed the required actions.

Distributor

The distributor makes a product available on the market without affecting its properties. It must act with due care and check basic conformity elements.

Important practical rule

If a company modifies a product, sells it under its own brand, integrates it into a larger solution or makes a substantial modification, it should check whether it assumes manufacturer obligations.

What must be prepared in 2026?

1. Product and component register

The manufacturer should start with a full list of products with digital elements. Without a register, CRA scope, product class, support period, vulnerabilities, components and documentation cannot be managed.

Record in the register:

  • product name
  • versions and variants
  • product type: software, hardware, firmware, component, remote data processing service
  • product owner
  • target market
  • whether the product is made available on the EU market
  • whether the product connects to a device or network
  • whether the product is a component for other products
  • whether the product may be important or critical under CRA
  • documentation and risk assessment status

Evidence to prepare: CRA product register with owners and classification.

2. Product classification

Not every product will follow the same conformity assessment path. Many products may use manufacturer self-assessment, but important and critical products may require stricter procedures, including notified body involvement.

Check whether the product belongs to:

  • default category
  • important class I
  • important class II
  • critical category
  • excluded category or product covered by specific sector rules

Evidence to prepare: product classification card with justification.

3. Vulnerability handling process

This is the most important area for 2026. The manufacturer must know how it receives vulnerability reports, qualifies them, escalates them, fixes them, informs users and reports actively exploited vulnerabilities.

The process should include:

  • contact address for vulnerability reporting
  • coordinated vulnerability disclosure policy
  • vulnerability triage
  • product impact assessment
  • prioritization and remediation timelines
  • security update preparation
  • user communication
  • remediation evidence
  • reporting process through the required channels

Evidence to prepare: vulnerability handling procedure and vulnerability register.

4. Reporting procedure from 11 September 2026

From 11 September 2026, the manufacturer should be ready to report actively exploited vulnerabilities and severe incidents affecting product security. Roles, escalation path, templates and decisions must be prepared before an incident occurs.

The procedure should cover:

  • criteria for actively exploited vulnerability
  • criteria for severe incident affecting product security
  • early warning within 24 hours
  • fuller notification within 72 hours
  • final report after remediation actions
  • contact with CSIRT and ENISA through the CRA reporting platform
  • informing product users
  • evidence preservation

Evidence to prepare: CRA reporting playbook, notification templates and escalation exercise.

5. SBOM and component management

CRA requires identifying and documenting vulnerabilities and components contained in products, including preparing a software bill of materials in a commonly used and machine-readable format covering at least top-level dependencies.

Prepare:

  • open source dependency list
  • commercial component list
  • library and version list
  • connection between components and product versions
  • component vulnerability monitoring
  • dependency update process
  • component license and security rules

Evidence to prepare: SBOM, component policy and dependency vulnerability report.

6. Secure SDLC

The manufacturer should show that security is part of product development, not an end-stage test. Secure SDLC should cover security requirements, architecture, code, tests, reviews and updates.

Minimum Secure SDLC

  • security requirements in the backlog
  • threat modeling for high-risk features
  • code review
  • SAST, DAST, SCA or other tests adequate to the product
  • secrets control
  • configuration testing
  • security criteria before release
  • post-release vulnerability handling

Evidence to prepare: secure SDLC policy, test results and review evidence.

7. Security update process

CRA requires effective mechanisms for distributing updates so that vulnerabilities are fixed or mitigated in a timely manner. For many products, security updates should be easy for users, secure and separated from functionality updates where technically feasible.

Prepare:

  • update distribution channel
  • update signing
  • integrity validation
  • emergency security update procedure
  • user communication
  • rollback or contingency plan
  • evidence of update availability

Evidence to prepare: security update procedure and update process test report.

What must be prepared in 2027?

1. Product cybersecurity risk assessment

Every in-scope CRA product should have a cybersecurity risk assessment. The assessment should identify risks, operating environment, users, interfaces, data, foreseeable misuse, vulnerabilities, components and applicable requirements.

The risk assessment should cover:

  • product intended purpose
  • foreseeable use and misuse
  • interfaces and connections
  • data processed by the product
  • privileges and accounts
  • components and dependencies
  • attack scenarios
  • impact on users and other systems
  • security requirements and evidence of fulfillment

Evidence to prepare: product cybersecurity risk assessment.

2. Essential cybersecurity requirements

The manufacturer must show how the product meets the essential cybersecurity requirements in Annex I. In practice, this means the product should be designed without known exploitable vulnerabilities, have secure default settings, limited attack surface, access control, data protection, security updates and vulnerability handling.

Areas to prepare

  • secure by design
  • secure by default
  • no known exploitable vulnerabilities when made available
  • protection against unauthorized access
  • data encryption where adequate
  • integrity of data and configuration
  • data minimization
  • resilience and availability of basic functions
  • attack surface reduction
  • mechanisms reducing incident impact
  • recording and monitoring of security-relevant activity
  • secure removal of data and settings

Evidence to prepare: CRA requirements matrix with controls, tests and evidence.

3. Technical documentation

Technical documentation will be one of the most important conformity evidence items. It should make it possible to demonstrate that the product meets CRA requirements and that the manufacturer operates product security processes.

Documentation should cover:

  • product description
  • architecture
  • cybersecurity risk assessment
  • security requirements
  • test results
  • SBOM or component information
  • vulnerability handling process
  • update process
  • user instructions
  • conformity assessment
  • evidence of requirement fulfillment

Evidence to prepare: complete CRA technical documentation.

4. Conformity assessment

The manufacturer must select the right conformity assessment procedure. For many products, self-assessment will be possible. For important or critical products, a stricter procedure or notified body involvement may be required.

Check:

  • whether the product is in the default category
  • whether the product is important class I
  • whether the product is important class II
  • whether the product is critical
  • whether harmonised standards were applied
  • whether a notified body is needed
  • whether certificates or schemes can help demonstrate conformity

Evidence to prepare: conformity assessment path decision and evidence pack.

5. EU declaration of conformity and CE marking

After a positive conformity assessment, the manufacturer can issue the EU declaration of conformity and mark the product with CE. This is not only a formality. CE means the manufacturer declares that the product meets the applicable requirements.

Prepare:

  • EU declaration of conformity template
  • product and version identification
  • manufacturer identification
  • conformity basis
  • standards, specifications or schemes used to demonstrate conformity
  • declaration version control process
  • CE marking control process

Evidence to prepare: EU declaration of conformity and CE marking procedure.

6. Instructions and information for users

CRA requires that users receive information necessary for secure use of the product. This includes contact details for vulnerability reporting, intended purpose, security properties, support period, security updates, secure setup and secure decommissioning.

Prepare information on:

  • manufacturer and contact point
  • vulnerability reporting
  • product and version identification
  • intended purpose
  • security properties
  • known circumstances that may create risk
  • support period
  • security update installation
  • secure configuration
  • secure data removal and product decommissioning

Evidence to prepare: product security instructions and public support information.

CRA checklist for 2026

  • do we have a product with digital elements register?
  • do we know which products are in scope of CRA?
  • does every product have a business and technical owner?
  • do we have product classification: default, important, critical?
  • do we have a vulnerability reporting process?
  • do we have a coordinated vulnerability disclosure policy?
  • do we have a contact address for vulnerabilities?
  • do we have a product vulnerability register?
  • do we have a 24 and 72-hour reporting procedure?
  • do we have a user notification process?
  • do we have an SBOM or an SBOM preparation plan?
  • do we monitor component vulnerabilities?
  • do we have a security update process?
  • do we have secure SDLC?
  • have we exercised an actively exploited vulnerability scenario?

CRA checklist for 2027

  • does every product have a cybersecurity risk assessment?
  • do we have a CRA essential requirements matrix?
  • do we have evidence of secure by design and secure by default?
  • is the product not made available with weak default passwords?
  • are security updates distributed securely?
  • is the support period defined and justified?
  • is technical documentation complete?
  • has the right conformity assessment path been defined?
  • is a notified body needed?
  • has the EU declaration of conformity been prepared?
  • do user instructions cover security?
  • is the CE process ready?
  • do importers, distributors and partners have required information?
  • do we have an evidence repository for market surveillance?
  • has the board approved risks, budget and CRA roadmap?

What documents and evidence should be prepared?

Strategic documents

  • CRA product applicability assessment
  • product with digital elements register
  • product classification
  • CRA roadmap for 2026 and 2027
  • product risk register
  • board decisions on scope, budget and risk

Product documents

  • product cybersecurity risk assessment
  • CRA essential requirements matrix
  • product architecture description
  • interface and dependency description
  • description of data processed by the product
  • security mechanism description
  • secure use instructions
  • support period and justification

Engineering documents

  • secure SDLC policy
  • threat modeling
  • SAST, DAST, SCA and security test reports
  • SBOM
  • component and dependency register
  • vulnerability management procedure
  • security update procedure
  • code review and testing evidence

Compliance documents

  • CRA technical documentation
  • conformity assessment path decision
  • conformity assessment report
  • EU declaration of conformity
  • CE marking procedure
  • communication for importers and distributors
  • conformity evidence repository

Operational documents

  • vulnerability report intake procedure
  • coordinated vulnerability disclosure policy
  • actively exploited vulnerability playbook
  • severe incident affecting product security playbook
  • user notification template
  • 24-hour notification template
  • 72-hour notification template
  • final report template

30, 60 and 90-day action plan

First 30 days

  • assign CRA programme owner
  • create product with digital elements register
  • identify which products are made available on the EU market
  • define roles: manufacturer, importer, distributor, integrator, contractor
  • perform initial product classification
  • check which products may require a special conformity path
  • launch vulnerability reporting address
  • prepare action plan before 11 September 2026

Days 31 to 60

  • prepare vulnerability handling procedure
  • prepare CRA reporting playbook
  • start building SBOM for priority products
  • check security update process
  • perform first product risk assessment
  • launch component vulnerability reporting
  • identify secure SDLC gaps
  • prepare first board report

Days 61 to 90

  • exercise actively exploited vulnerability scenario
  • exercise severe incident affecting product security
  • prepare CRA requirements matrix for a priority product
  • perform security tests of a priority product
  • prepare technical documentation template
  • decide conformity assessment path
  • define product support period
  • approve 12-month CRA roadmap

Strategic plan for 2026 and 2027

By 11 September 2026

  • actively exploited vulnerability reporting process
  • severe incident affecting product security reporting process
  • vulnerability reporting contact
  • vulnerability triage
  • vulnerability register
  • notification templates
  • decision path
  • reporting exercise

By the end of 2026

  • product register and classification
  • SBOM for priority products
  • secure SDLC for new releases
  • security update process
  • first product risk assessments
  • conformity assessment plan
  • component supplier analysis
  • CRA board report

First half of 2027

  • CRA essential requirements matrix
  • full security testing of priority products
  • complete technical documentation
  • user instructions
  • support period and update policy
  • conformity assessment preparation
  • alignment with notified body if needed

Second half of 2027

  • complete conformity assessment
  • EU declaration of conformity
  • CE process
  • evidence repository
  • contract review with importers, distributors and partners
  • market surveillance readiness
  • plan for maintaining compliance after 11 December 2027

Common manufacturer mistakes

Mistake 1: treating CRA as a legal issue

CRA has legal consequences, but implementation is mainly a product, engineering and operational task. Legal analysis alone is not enough without changes in the product development process.

Mistake 2: no product register

The company does not know which products are in scope, which are components, which are important or critical and which versions are still supported.

Mistake 3: no vulnerability handling process

From 2026, reporting actively exploited vulnerabilities requires a fast decision path. Without a process, the company may not assess and report on time.

Mistake 4: SBOM without a process

A component list is not enough. The company needs an update process, vulnerability monitoring and mapping between components and product versions.

Mistake 5: security testing only before release

CRA requires security throughout the product lifecycle. An end-stage test does not replace secure SDLC, threat modeling and dependency control.

Mistake 6: unclear support period

The user must know how long security support will be provided. The manufacturer must justify and document it.

Mistake 7: no conformity assessment path decision

If the product is important or critical, the manufacturer may need notified body involvement. This requires time and planning.

Mistake 8: no evidence

Documentation, tests, updates, risk decisions and vulnerability handling must leave a trace. Without evidence, conformity is difficult to demonstrate.

Business example

A SaaS company and software house develops an access management product for B2B customers. The product consists of a web application, an agent installed at the customer, API, open source components, login module and cloud integrations. The company initially assumes CRA mainly concerns IoT devices and delays the topic.

After analysis, it turns out that the customer-installed agent and access management product may be products with digital elements in scope of CRA. The company must prepare product register, risk assessment, SBOM, vulnerability reporting process, security update handling, customer instructions and conformity assessment path analysis.

In 2026, the company launches vulnerability contact, CVD, vulnerability register, SBOM and reporting playbook. In 2027, it completes technical documentation, tests, conformity assessment, instructions and CE process. As a result, CRA becomes part of product maturity, not a panic project at the end of 2027.

How can ccyber.io help?

ccyber.io helps digital product manufacturers prepare for the Cyber Resilience Act in a practical, product-focused and evidence-driven way. We combine regulatory, security engineering, secure SDLC, security testing, SBOM, vulnerability, update and conformity documentation perspectives.

We can support your organization with:

  • CRA applicability assessment
  • product with digital elements register
  • CRA product classification
  • product cybersecurity risk assessment
  • CRA essential requirements matrix
  • secure SDLC and threat modeling
  • SBOM and component management
  • vulnerability handling and CVD procedure
  • actively exploited vulnerability reporting playbook
  • security update process
  • technical documentation and evidence pack
  • conformity assessment and CE readiness
  • CRA roadmap for 2026, 2027 and post-application period

The best first step is a CRA Product Readiness Workshop. In a short workshop, the company can identify which products are in scope, which obligations are urgent in 2026, which conformity path may be needed and what evidence must be prepared before 2027.

FAQ

Does CRA apply only to IoT devices?

No. CRA applies to products with digital elements, meaning many hardware and software products, including applications, components, firmware, network devices, security products, embedded systems and network-connected products.

What is most important in 2026?

The most important task is preparing vulnerability handling and reporting of actively exploited vulnerabilities and severe incidents affecting product security.

What is most important in 2027?

The most important task is full product readiness: risk assessment, essential requirements, technical documentation, conformity assessment, instructions, support period, CE marking and evidence repository.

Does every product require a notified body?

No. Many products can use self-assessment. Important or critical products may require stricter procedures and, in certain cases, notified body involvement.

Are products sold before 11 December 2027 covered?

Products placed on the market before 11 December 2027 will generally be subject to the requirements only if they undergo a substantial modification from that date. However, Article 14 reporting obligations apply to in-scope CRA products even if they were placed on the market before that date.

Must the SBOM be public?

CRA requires preparing an SBOM as part of identifying components and vulnerabilities. Public availability to users is a separate issue. The manufacturer should prepare SBOM and procedures for making it available to relevant parties where required.

How long must a product be supported?

The support period should be defined by the manufacturer and generally should be at least 5 years, unless the expected product use period is shorter. It must be clearly indicated to the user and justified in documentation.

Where should we start?

Start with the product register, CRA classification, in-scope assessment, vulnerability handling process, SBOM and action roadmap before 11 September 2026 and 11 December 2027.

Summary

The Cyber Resilience Act requires digital product manufacturers to move from “we released a product” to “we maintain a secure product throughout the support period”. This means changes in product, engineering, legal, quality and operational processes.

In 2026, the manufacturer should focus on reporting, vulnerability handling, SBOM, updates and secure SDLC foundations. In 2027, it must complete full readiness: risk assessment, requirements, documentation, conformity assessment, declaration of conformity, CE and user information.

The best rule is: do not wait until 2027. A product whose architecture, components, updates and documentation are not prepared today may require far more work than a formal declaration of conformity.

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

Cybersecurity Funding: What Polish Companies Should Pay Attention to in 2026

In 2026, Polish companies should look at cybersecurity funding more broadly than just as a “grant for a firewall”. The biggest opportunities appear where cybersecurity is part of digitalization, automation, Industry 4.0, NIS2 compliance, CRA product readiness, operational resilience, cloud, AI, backup, access management and security testing. The best-prepared projects include a risk diagnosis, technical scope, budget, schedule, evidence of need, regulatory links and measurable business outcomes.

Prepared by: CCyber Editorial Team

Short answer

In 2026, Polish companies should look for cybersecurity funding not only in programmes explicitly called “cyber”. In practice, cybersecurity may be part of projects related to digitalization, automation, digital transformation, Industry 4.0, digital product development, NIS2 compliance, Cyber Resilience Act readiness, operational resilience, cloud, AI, backup, identity management, security testing and training. The key is proper project preparation: risk diagnosis, system list, business justification, budget, schedule, measurable outcomes, regulatory links and evidence that the company can implement and maintain the purchased solutions. A list of tools alone is rarely enough. Funding institutions want to see purpose, impact and sustainability.

Last updated

July 2026

Who this article is for

  • business owners and boards planning cybersecurity investments
  • SMEs looking for grants, subsidies, preferential loans or advisory services
  • manufacturing and service companies planning digitalization and automation
  • software houses, SaaS companies and digital product manufacturers
  • IT, cloud, backup, SOC, MDR and managed service providers
  • companies preparing for NIS2, CRA, DORA, ISO 27001 or cyber insurance
  • CFOs, COOs, CTOs, CISOs, vCISOs, compliance, legal and grant application owners
  • organizations that want to connect cybersecurity with growth, resilience and compliance

Key takeaways

  1. In 2026, cybersecurity will often be financed as part of broader digital transformation, not as a single tool purchase.
  2. The strongest projects connect cybersecurity with a specific risk: ransomware, production downtime, customer data protection, NIS2, CRA, DORA, privileged access or product security.
  3. Companies should monitor national programmes, regional programmes, EDIH, FENG, KPO, Digital Europe, loan instruments and direct EU funding.
  4. Funding institutions often require not only a budget, but also needs diagnosis, implementation plan, outcomes, sustainability and organizational capacity.
  5. The biggest mistake is writing the application from a shopping list. A good project starts with a business problem, risk and expected outcome.

Why is 2026 important for cybersecurity funding?

2026 is important because companies face several trends at the same time. Customer, insurer, auditor and regulatory requirements are increasing. NIS2 increases pressure on cyber risk and supplier management. The Cyber Resilience Act requires software and hardware producers to prepare for digital product security. DORA affects the financial sector and ICT providers. AI accelerates digitalization, but also creates new risks. Ransomware and phishing still cause real downtime and losses.

This means cybersecurity is no longer only an IT cost. It becomes part of competitiveness, operational resilience, regulatory compliance and access to larger customers. For this reason, cybersecurity funding should be planned not as a “security project”, but as a company development project.

The key change: funding will not always be called “cybersecurity”

Polish companies often search for programmes using the phrase “cybersecurity grant”. This is too narrow. In practice, cybersecurity costs may appear in projects related to digitalization, automation, IT system implementation, cloud, AI, Industry 4.0, e-services, product security, regulatory compliance or operational resilience.

Cybersecurity may be part of a project involving:

  • ERP, MES, SCADA, CRM or B2B platform implementation
  • cloud migration
  • production automation
  • AI deployment in business processes
  • building or modernizing a digital product
  • backup and recovery implementation
  • identity and access management
  • OT and IT network segmentation
  • application security testing
  • vulnerability management process implementation
  • customer audit, NIS2, CRA or ISO 27001 readiness

A good funding strategy therefore starts by finding the right programme objective, and then showing why cybersecurity is necessary to achieve that objective.

Where to look for funding in 2026?

1. European Funds for company digitalization

The European Funds portal indicates that company digitalization may be supported through grants, subsidies and preferential loans. In practice, support may cover ready-made solutions, licenses, technologies, software development work and pre-implementation advisory. This is important because cybersecurity is often part of secure digitalization, not a separate product.

What to check?

  • whether the programme finances digital technology implementation
  • whether security costs are eligible as part of implementation
  • whether advisory, audit or diagnosis can be financed
  • whether the project must include a production, service, R&D or innovation component
  • whether own contribution is required
  • whether costs are reimbursed after implementation or an advance is possible

Example costs to consider

  • secure configuration of a new system
  • MFA and SSO integration
  • backup and recovery for the implemented solution
  • security testing of the system
  • access management
  • monitoring and logging
  • user training

2. Dig.IT and digital transformation grants

Dig.IT is an example of an instrument where cybersecurity may appear as part of modern digital technology implementation. The programme is addressed to micro, small and medium-sized enterprises from the manufacturing and production services sector. Its description includes big data, AI and cybersecurity.

Why does this matter?

For manufacturing companies, cybersecurity is often connected with automation, system integration, production data, cloud, IoT, MES, ERP or SCADA systems. If a digitalization project increases dependency on digital systems, security should be included in the scope.

Example project elements

  • secure implementation of a production system
  • network segmentation for new technologies
  • access control for production data
  • backup of configurations and data
  • availability and security monitoring
  • employee training on safe use of technology

3. Loans for digital and green transformation

Loan instruments may be a good option for larger projects where cybersecurity is part of broad digital modernization. Loans for digital and green transformation are available to companies across Poland, and the digital part may include transformation toward Industry 4.0, automation, robotization, cloud, data analytics and digital systems.

When is a loan worth considering?

  • the project is too large for a small grant
  • the company plans process transformation, not a single purchase
  • implementation requires equipment, systems, services and integration
  • cybersecurity is part of operational modernization
  • the company can service repayable financing

Example cyber components in such a project

  • Industry 4.0 infrastructure cybersecurity
  • secure cloud and hybrid architecture
  • protection of production and logistics systems
  • identity management
  • secure system integration
  • backup and recovery of critical services

4. EDIH, European Digital Innovation Hubs

EDIH is an especially important path for SMEs that are not ready for a large investment project yet. EDIHs offer audits, advisory, test before invest, training, skills development, funding support, networking and access to the innovation ecosystem. Cybersecurity is also part of the Polish EDIH offer.

Why start with EDIH?

  • the company can verify needs before a large investment
  • digital maturity can be diagnosed
  • advisory and training services are available
  • SMEs can use services free of charge under de minimis aid
  • EDIH can help identify further funding sources

How to use EDIH in a cyber project?

  • perform digital and security maturity assessment
  • check risks before implementing new technology
  • test a solution before investing
  • train the team
  • prepare a digitalization and cybersecurity roadmap

5. Regional programmes

In 2026, regional programmes should be monitored closely because some support for digitalization and SME growth is available at voivodeship level. The European Funds portal lists examples of regional loans and instruments for company digitalization.

What to check?

  • whether the programme concerns a specific region
  • whether the company or project is located in an eligible region
  • whether support is a grant, loan, mixed instrument or advisory service
  • whether cybersecurity can be part of digitalization
  • whether indicators for digitalization, innovation or efficiency are required

6. Digital Europe Programme and international projects

The Digital Europe Programme is an important source of funding for cybersecurity, AI, digital skills and digital infrastructure projects. For many companies, this path will be more difficult than national programmes because it often requires a consortium, international partners, larger scope and alignment with programme objectives.

Who may benefit?

  • cybersecurity technology providers
  • companies developing cyber or AI security products
  • companies participating in European consortia
  • competence centers, clusters and technology partnerships
  • solution providers for critical sectors
  • organizations building cyber capabilities at sector or cross-border level

How to prepare?

  • monitor the Funding and Tenders Portal
  • look for partners early
  • prepare a clear technology and European value proposition
  • prepare team experience and references
  • show scalability, interoperability and impact on market security

7. EIB, BGK, PFR and repayable instruments

Not every cybersecurity project must be grant-funded. Larger projects may use repayable funding, preferential loans, guarantees, technology leasing or investment financing. In 2026, it will be especially important to connect cybersecurity with business resilience, technology, automation and digital sovereignty.

When can repayable funding make sense?

  • the company is investing in a large IT modernization programme
  • the project increases revenue or reduces downtime cost
  • the company needs a faster decision than a grant process allows
  • costs include infrastructure, licenses, implementation and services
  • the project is too operational or too broad for a typical grant call

What cybersecurity can be financed?

1. Diagnosis and audit

  • cyber risk assessment
  • NIS2 readiness assessment
  • CRA readiness for digital products
  • Microsoft 365 or Google Workspace audit
  • backup and recovery audit
  • OT or industrial audit
  • ICT supplier assessment

2. Protective technologies

  • MFA, SSO and IAM
  • PAM for privileged accounts
  • EDR or XDR
  • backup and disaster recovery
  • SIEM or log management
  • email protection
  • DLP and encryption
  • network segmentation
  • secure cloud configuration

3. Digital product security

  • secure SDLC
  • threat modeling
  • SBOM
  • vulnerability management
  • application security testing
  • product update process
  • vulnerability disclosure handling
  • technical documentation for CRA compliance

4. Operational resilience

  • business continuity plan
  • disaster recovery plan
  • recovery tests
  • ransomware exercises
  • crisis communication plan
  • critical system redundancy
  • manual operation plan

5. People and processes

  • phishing training
  • NIS2 training for the board
  • secure coding training
  • administrator training
  • incident response procedures
  • payment and second-channel verification procedure
  • password and access policy
  • cyber awareness programme

How to prepare a stronger project?

1. Start with risk diagnosis

The application should not start with “we want to buy a tool”. It should start with a problem: ransomware risk, lack of tested backup, broad access, customer requirements, NIS2, CRA, OT risk or lack of secure product update process.

2. Show the business connection

Cybersecurity is easier to finance when it is connected to a specific business outcome.

  • less downtime
  • greater production resilience
  • ability to serve larger customers
  • meeting regulatory requirements
  • secure cloud implementation
  • secure digital product
  • lower incident cost

3. Define eligible and non-eligible costs

Not every cyber cost is eligible in every programme. Check the rules, cost catalogue, state aid, limits, own contribution, timelines, payment mechanism and sustainability requirements.

4. Prepare measurable outcomes

Funding institutions want to see results. For cybersecurity, practical indicators are useful.

  • number of systems covered by MFA
  • critical system recovery time
  • number of trained employees
  • number of high-risk vulnerabilities closed after implementation
  • number of systems covered by backup
  • number of security tests performed
  • number of suppliers assessed for risk

5. Show project sustainability

A one-time purchase is not enough. The company must show who will maintain the solution, who will respond to alerts, who will update procedures, who will perform tests and how results will be sustained after funding ends.

Key questions before submitting an application

  • does the project address real cyber risk?
  • do we have a current-state diagnosis?
  • do we know which systems and data are critical?
  • does the project match the programme objective?
  • is cybersecurity an eligible cost?
  • do we have own contribution?
  • does the project require post-completion reimbursement?
  • do we have suppliers and offers?
  • do we know who owns implementation?
  • do we have indicators and evidence of outcomes?

What documents should be prepared?

Strategic documents

  • cybersecurity diagnosis
  • cyber risk register
  • critical systems map
  • business impact analysis of an incident
  • cybersecurity roadmap
  • justification linked to NIS2, CRA, DORA, ISO 27001 or customer requirements

Technical documents

  • current architecture description
  • planned implementation scope
  • integration description
  • description of data and systems covered by the project
  • security requirements
  • technical schedule
  • test and acceptance plan

Financial documents

  • project budget
  • offers or cost estimation
  • cost justification
  • own contribution financing plan
  • downtime or incident cost analysis
  • post-project maintenance plan

Implementation documents

  • schedule
  • milestones
  • roles and responsibilities
  • change management plan
  • training plan
  • internal communication plan
  • result sustainability plan

Which projects may be difficult to finance?

Tool purchase without diagnosis

If the company wants to buy a tool but does not show risk, purpose and outcome, the project may look like an ordinary operating cost.

License replacement without security change

Replacing one tool with another may be difficult to justify if it does not show improved resilience, compliance or maturity.

Project without a business owner

Grant-funded cybersecurity should have an owner inside the company, not only a technology supplier.

Project without sustainability

If the company does not show who will maintain the solution after implementation, the project may be evaluated weaker.

Project disconnected from the programme objective

Not every programme finances everything. Even a good cyber project may not fit a programme if it does not meet its objective.

Common company mistakes in cybersecurity funding

Mistake 1: looking for a grant after choosing the tool

First check programme objective, cost eligibility and requirements. Only then define the technical scope.

Mistake 2: no diagnosis

Without an audit or risk assessment, it is difficult to justify why the project is needed.

Mistake 3: overly broad scope

“Improving cybersecurity” is too broad. It is better to identify specific risks, systems, controls and outcomes.

Mistake 4: no measurable indicators

The project should show how the company will measure security improvement.

Mistake 5: ignoring maintenance

EDR, SIEM or backup implementation without people, processes and maintenance may not create lasting value.

Mistake 6: collecting offers too late

A good budget requires time, option comparison and alignment between scope and programme rules.

Mistake 7: ignoring regulations

NIS2, CRA, DORA, ISO 27001 and customer requirements may strongly justify a project. They should be shown.

Mistake 8: no cooperation between IT, finance and the board

A cybersecurity funding application requires technical, financial and business perspectives. One person rarely sees the full picture.

A simple cyber project model for funding

1. Problem

The company has ransomware risk, no tested backup, no MFA on critical accounts, customer requirements or regulatory duties.

2. Objective

Increase digital resilience, reduce downtime risk, meet NIS2 or CRA requirements, securely implement digital technologies.

3. Scope

Diagnosis, technology implementation, procedures, tests, training, documentation and evidence.

4. Outcome

MFA on critical systems, restore test, shorter recovery time, closed vulnerabilities, more secure product, trained team.

5. Sustainability

Control owner, recurring tests, maintenance budget, procedures, board reporting.

30, 60 and 90-day action plan

First 30 days

  • assign a cybersecurity funding owner
  • check current national, regional, EDIH, FENG, KPO and EU calls
  • prepare a short cybersecurity diagnosis
  • identify the 3 biggest cyber risks for the company
  • check customer, NIS2, CRA, DORA or ISO 27001 requirements
  • choose 2 or 3 project scenarios
  • prepare an initial budget and cost list
  • contact EDIH, European Funds information point or advisor

Days 31 to 60

  • select the best funding source
  • align the project with programme objectives
  • collect offers and technical descriptions
  • prepare schedule and milestones
  • define outcome indicators
  • prepare result sustainability plan
  • obtain board decision on own contribution
  • prepare application documents

Days 61 to 90

  • complete application and attachments
  • check cost eligibility
  • perform consistency review of budget, schedule and outcomes
  • prepare answers to evaluator questions
  • define implementation plan after funding approval
  • prepare evidence repository
  • plan progress reporting to the board
  • build an alternative plan if the application is not funded

Which metrics are worth showing in the application?

Risk metrics

  • number of critical systems without MFA
  • number of systems without tested backup
  • number of high-risk vulnerabilities
  • critical system recovery time
  • cost of one day of downtime
  • number of suppliers with administrative access

Outcome metrics

  • percentage of critical accounts covered by MFA after the project
  • number of systems covered by backup and restore testing
  • number of closed vulnerabilities
  • number of trained employees
  • reduced recovery time
  • number of procedures implemented and tested

Business metrics

  • reduced downtime risk
  • ability to meet customer requirements
  • audit readiness
  • safer implementation of new technology
  • ransomware resilience
  • product readiness for CRA requirements

How to connect funding with NIS2, CRA and DORA?

NIS2

For companies in scope of NIS2 or working with regulated entities, the project may cover risk management, incident response, backup, suppliers, training, logs, MFA, vulnerabilities and compliance evidence.

CRA

For software and hardware producers, the project may cover product security: SBOM, secure SDLC, testing, vulnerability management, update process, vulnerability disclosure and technical documentation.

DORA

For financial companies and ICT providers, the project may cover digital resilience, testing, supplier register, ICT contracts, incident reporting, backup, business continuity and auditability.

ISO 27001

For companies preparing for certification, the project may cover risk register, policies, controls, audits, training, supplier management and evidence repository.

Business example

A manufacturing company has 120 employees. It plans to implement MES, ERP integration, automated production data collection and a B2B customer portal. Initially, the project is described as production digitalization. After analysis, however, it becomes clear that the new solution will increase dependency on cloud, industrial network, user accounts, API integrations and production data.

The company expands the project with cybersecurity: network segmentation, MFA for critical accounts, configuration backup, restore testing, monitoring, administrator training and incident procedure. The application does not describe cyber as an add-on, but as a condition of secure digital transformation.

This makes the project consistent: automation improves efficiency, while cybersecurity reduces downtime, data loss and operational error risk. The company also prepares indicators: number of systems covered by MFA, recovery time, number of trained people and restore test after implementation.

How can ccyber.io help?

ccyber.io helps companies prepare cybersecurity projects for funding from grants, subsidies, loans and digitalization programmes. We combine security, regulatory, funding, technology and business perspectives.

We can support your organization with:

  • cybersecurity needs diagnosis for applications
  • cyber project scope for funding programmes
  • mapping the project to NIS2, CRA, DORA, ISO 27001 or customer requirements
  • cybersecurity budget and schedule
  • technical project description
  • business justification and risk analysis
  • outcome and sustainability indicators
  • evidence pack for the application
  • 30, 60, 90-day and 12-month cybersecurity roadmap
  • support in preparing projects for EDIH, FENG, regional programmes and repayable financing

The best first step is a Cyber Funding Readiness Workshop. In a short workshop, the company can determine what it wants to finance, which funding sources fit the project, which costs may be problematic and how to prepare a project that makes business and technical sense.

FAQ

Can a company get a grant only for cybersecurity in 2026?

It depends on the call. Often, cybersecurity is not a standalone objective, but it may be part of digitalization, digital transformation, Industry 4.0, regulatory compliance or digital product development.

Can a firewall purchase be eligible?

It may be, but only if it fits the rules of the specific programme and is justified in the project. A tool purchase without diagnosis and outcome may be harder to defend.

Can an SME use EDIH?

Yes. EDIHs offer SMEs services related to digital transformation, including audits, advisory, test before invest, training, funding support and cybersecurity services.

Can cybersecurity be combined with a production project?

Yes. ERP, MES, SCADA, IoT, AI, cloud and automation projects should include a security element because they increase the company’s dependency on digital technologies.

Can NIS2 readiness be financed?

In many cases, elements of NIS2 readiness may be part of a digitalization, resilience, risk management, training, backup, incident or supplier project. The rules of the specific programme must be checked.

What matters most in the application?

The most important elements are alignment with the programme objective, clear risk justification, measurable outcomes, realistic budget, schedule and sustainability of results.

Where should we start?

Start with cybersecurity diagnosis, risk list, critical systems map and current call review. Then match the project to the funding source, not the other way around.

Is an alternative plan useful?

Yes. Calls are competitive and timelines change. The company should have a minimum plan funded from own resources, a loan or staged financing.

Summary

Cybersecurity funding in 2026 requires a broad view. Polish companies should look not only for programmes called “cyber”, but also for digitalization, transformation, Industry 4.0, EDIH, FENG, regional programmes, Digital Europe, loans and repayable financing.

The best cyber projects are specific: they come from diagnosis, address real risk, connect with business, regulations and technology, have measurable outcomes and a maintenance plan. The weakest projects are shopping lists without justification.

The best rule is: do not ask first “what grant is available?”. Ask which cyber risk you reduce, which business outcome you achieve and which funding source best fits that objective.

Sources

10 Employee Mistakes That Most Often Lead to Incidents

The most common incidents do not start with a spectacular hack, but with small mistakes: clicking phishing links, sharing MFA codes, reusing passwords, sending data to the wrong recipient, approving a fake payment, ignoring updates or failing to report suspicious activity. The goal of training should not be to scare employees, but to teach simple behaviors: stop, verify through a second channel, never share codes, report quickly, use approved tools and ask when something looks unusual.

Prepared by: CCyber Editorial Team

Short answer

The most common employee mistakes leading to incidents are clicking phishing links, sharing passwords or MFA codes, reusing passwords, using unapproved tools, sending data to the wrong recipients, ignoring updates and alerts, bypassing payment procedures, working on personal devices without rules, failing to report suspicious activity and trusting messages, calls and requests that look “normal”. This is not about blaming people. Most mistakes come from time pressure, weak processes, unclear rules, poorly designed tools and training that teaches theory instead of behaviors. Good cyber awareness means the employee knows when to stop, how to verify a request, what not to share, where to report a problem and that reporting a mistake quickly is better than staying silent.

Last updated

July 2026

Who this article is for

  • boards and business owners
  • HR, compliance, risk, legal and training owners
  • CISOs, vCISOs, CTOs, CIOs and IT directors
  • sales, finance, customer service, HR and marketing managers
  • SMEs that want to reduce incidents caused by everyday mistakes
  • organizations preparing phishing training and cyber awareness programmes
  • companies preparing for NIS2, ISO 27001, cyber insurance or customer audits
  • software houses, SaaS companies, e-commerce and organizations working with customer data

Key takeaways

  1. Employees are not the “weakest link”. They are the last line of defense, but only when they have clear rules, good tools and a safe reporting culture.
  2. The highest-risk mistakes concern email, passwords, MFA, payments, customer data, remote access, private tools and delayed reporting.
  3. Training should teach specific workplace decisions, not only definitions of phishing, ransomware and malware.
  4. The key rule for employees is: stop, verify, report. Time pressure is part of many attacks.
  5. The company should measure not only phishing simulation clicks, but also reporting time, response quality, repeated mistakes and procedure effectiveness.

Why do employee mistakes lead to incidents?

Most employees do not make mistakes because they ignore security. Mistakes happen because everyday work requires speed, reacting to messages, serving customers, approving payments, handling documents, using many systems and making decisions under pressure.

Attackers exploit this. They do not always try to “hack the system”. They often try to convince a person to do something for them: click a link, share a code, open an attachment, approve a payment, share a file, reset a password or ignore an unusual signal.

Typical mechanisms attackers use

  • time pressure
  • authority of a manager, customer, supplier or bank
  • fear of consequences
  • curiosity
  • routine
  • alert fatigue
  • message overload
  • unclear procedures
  • lack of simple reporting channel

This is why the awareness programme should be designed like a security system, not a one-time presentation.

10 employee mistakes that most often lead to incidents

Mistake 1: Clicking a link or opening an attachment without checking

Phishing is still one of the most common ways to start an incident. A message may imitate a bank, supplier, customer, courier, public office, IT team, board member or known platform. It no longer has to look like a classic suspicious email full of spelling errors. It may be well-written, context-aware and sent from a compromised account of a real person.

What the mistake looks like

  • clicking a fake login link
  • opening an attachment with a macro or malware
  • downloading a file from an unknown site
  • logging in through a message link
  • scanning a QR code without verification
  • opening a link from SMS or messenger

What can happen?

  • email account takeover
  • password theft
  • malware installation
  • ransomware execution
  • customer data exposure
  • fake messages sent from the employee’s account

How to train?

  • do not teach only “spot phishing by spelling mistakes”
  • teach checking sender, context and message purpose
  • teach entering websites manually instead of using links
  • teach second-channel verification for money, data and access requests
  • teach fast reporting after a click

Simple employee rule

If a message requires login, payment, file download, data sharing or quick action, stop and verify it through a second channel.

Mistake 2: Sharing a password, MFA code or approving unexpected login

The password is no longer the only attacker target. Increasingly, the target is an MFA code, approval in an authentication app or convincing the employee that “IT” needs a code to fix a problem.

What the mistake looks like

  • sharing an MFA code by phone
  • sharing an MFA code in messenger
  • approving an MFA prompt the employee did not initiate
  • entering a password on a fake company login page
  • sharing an account recovery code

What can happen?

  • email takeover
  • cloud file takeover
  • CRM takeover
  • access to customer data
  • administrator account takeover
  • bypass of many other safeguards

How to train?

  • repeat that an MFA code is like a one-time password
  • exercise the “IT calling for a code” scenario
  • teach rejecting unexpected MFA prompts
  • define a clear channel for real IT contact
  • teach immediate reporting of suspicious MFA

Simple employee rule

Never share an MFA code and never approve a login you did not start.

Mistake 3: Reusing the same password across systems

Password reuse means a leak from one service can open access to other accounts. The problem grows when an employee uses the same password at work and privately.

What the mistake looks like

  • the same password for email, CRM and a private online shop
  • simple patterns such as company name plus year
  • passwords stored in spreadsheets
  • passwords sent by messenger
  • shared password to social media or invoicing system

What can happen?

  • credential stuffing
  • takeover of many accounts at once
  • former employee access to a shared account
  • inability to identify who performed an action
  • loss of control over company accounts

How to train?

  • deploy a password manager instead of expecting people to memorize many passwords
  • teach unique passwords for every system
  • do not force periodic password changes without reason
  • remove shared accounts where possible
  • check accounts of former employees

Simple employee rule

One account, one password. Store company passwords only in the approved password manager.

Mistake 4: Sending data to the wrong recipient or unapproved tool

An incident does not always begin with an attack. Sometimes it is a file sent by mistake, autocomplete selecting the wrong address, adding the wrong person to a thread, sharing a folder too broadly or pasting data into a public AI tool.

What the mistake looks like

  • sending a customer file to the wrong recipient
  • replying all with confidential information
  • sharing a folder with anyone who has the link
  • pasting personal data into an unapproved AI tool
  • sending a spreadsheet with hidden columns
  • sharing data through a private messenger

What can happen?

  • personal data breach
  • breach of customer contract
  • trade secret disclosure
  • loss of customer trust
  • incident notification duty

How to train?

  • teach data classification in plain language
  • define what must not be sent by email
  • teach checking recipients before sending
  • introduce AI tool use rules
  • exercise scenarios: wrong recipient, too broad link, wrong attachment

Simple employee rule

Before sending customer data, check the recipient, attachment, sharing scope and communication channel.

Mistake 5: Approving a payment or supplier bank account change under pressure

Payment attacks often do not require malware. A fake supplier email, compromised customer mailbox, phone call from someone pretending to be the board or a message asking for an “urgent transfer” may be enough.

What the mistake looks like

  • changing supplier bank account based on email
  • urgent transfer without second approval
  • using the phone number included in a suspicious message
  • bypassing procedure because “the board asked”
  • approving payment without checking invoice and supplier details

What can happen?

  • loss of money
  • dispute with the real supplier
  • cash flow problem
  • escalation to board and bank
  • reputational incident

How to train?

  • exercise fake invoices and supplier bank account changes
  • define two-person approval for payments above a threshold
  • teach second-channel verification
  • ban decisions under pressure
  • teach that board requests also follow the procedure

Simple employee rule

A new bank account, urgent payment or unusual payment request always requires a second channel and a second person.

Mistake 6: Ignoring updates, restarts and security warnings

Employees often delay updates because they interrupt work. Sometimes they ignore alerts about suspicious login, account lockout, risky file or browser warnings. This may open the door to known vulnerability exploitation or account loss.

What the mistake looks like

  • delaying updates for weeks
  • ignoring a login alert from an unusual place
  • clicking “continue” despite a browser warning
  • disabling antivirus because “it gets in the way”
  • installing an unknown app without approval

What can happen?

  • exploitation of a known vulnerability
  • device compromise
  • data exposure
  • ransomware
  • failure to detect an incident in time

How to train?

  • explain why updates matter
  • define update and restart windows
  • make it easy to report false or unclear alerts
  • teach that a security warning is a signal, not an obstacle
  • measure devices missing updates

Simple employee rule

Do not disable safeguards and do not ignore warnings. If a message blocks work, report it instead of bypassing it.

Mistake 7: Using personal devices, accounts and tools without rules

An employee may use private email, private cloud storage, messenger, phone or an unapproved tool because it feels faster. This often creates Shadow IT and Shadow AI, meaning an area outside organizational control.

What the mistake looks like

  • sending company files to private email
  • keeping customer documents on a private drive
  • using a private phone without PIN for company email
  • copying data into an unapproved app
  • using a private AI account for company data

What can happen?

  • lack of control over data
  • data loss after employee departure
  • leak through a private account
  • inability to audit
  • breach of customer contract

How to train?

  • define approved tools for work
  • give employees safe alternatives
  • describe BYOD and remote work rules
  • teach that “faster” does not mean “secure”
  • explain which data must not leave company tools

Simple employee rule

Process company and customer data only in approved tools and on devices that meet company rules.

Mistake 8: Poor handling of access after role change or departure

This mistake is often not spectacular, but very common. An employee changes role, a project ends, a supplier finishes work, but access remains. A former employee still has an account, or someone from a previous project still sees customer data.

What the mistake looks like

  • role change not reported
  • access left after project end
  • supplier access not removed
  • former employee account still active
  • shared passwords not changed after a person leaves

What can happen?

  • unauthorized access to data
  • customer information exposure
  • actions from an account of a person who no longer works there
  • privilege abuse
  • audit noncompliance

How to train?

  • teach managers that role change means access change
  • introduce an offboarding checklist
  • exercise employee departure process
  • review access quarterly
  • teach employees not to use access they no longer need

Simple rule for employees and managers

Access is needed only as long as there is a real business need.

Mistake 9: Failing to report suspicious activity or a personal mistake

This is one of the most dangerous mistakes because it turns a small incident into a large one. An employee clicked a link, shared a password, sent a file to the wrong recipient or approved suspicious MFA, but fears consequences and says nothing.

What the mistake looks like

  • employee does not report clicking phishing
  • employee does not say they entered a password
  • employee deletes the message and assumes the issue is over
  • employee does not report a lost phone
  • employee waits until the end of the day even though the event is urgent

What can happen?

  • attacker gets more time
  • incident spreads to other systems
  • scope becomes harder to determine
  • company loses evidence
  • response costs increase

How to train?

  • build a no-blame reporting culture
  • reward fast reporting
  • state clearly where to report incidents
  • use simple reporting channels
  • exercise the “I clicked, what now?” scenario

Simple employee rule

Fast reporting of a mistake protects the company. Hiding a mistake helps the attacker.

Mistake 10: Trusting a message, call, voice or image too much

Social engineering attacks do not end with email. An employee may receive a call from “the CEO”, a message from “a supplier”, a voice recording, a messenger request, meeting invite or material that looks real. AI and deepfakes make such attempts more convincing.

What the mistake looks like

  • following an instruction after a phone call without verification
  • trusting a message from a compromised supplier account
  • accepting an unusual request because it looks like it came from a manager
  • changing customer details without confirmation
  • giving information to someone impersonating IT

What can happen?

  • fake payment
  • data leak
  • account reset for an attacker
  • file sharing
  • bypass of security procedures

How to train?

  • teach that realistic appearance is not proof
  • introduce phone passphrases or second channel for high-risk actions
  • exercise deepfake, vishing, smishing and MFA fatigue scenarios
  • ban bypassing procedures because of authority
  • teach that urgency and secrecy are red flags

Simple employee rule

An unusual request from an important person still requires verification. Authority does not cancel the procedure.

How to turn mistakes into a training programme?

Effective training should not start with a slide explaining “what is phishing”. It should start with real workplace situations. Employees need to practice decisions they make in everyday processes.

Training should cover:

  • phishing in email, SMS, QR codes and messengers
  • MFA and unexpected prompts
  • passwords and password manager
  • sending data and sharing files
  • payment and supplier bank account change procedure
  • rules for AI tools and private apps
  • mistake reporting without fear of punishment
  • response after clicking a link or entering a password

Best training formats

  • short scenarios instead of long presentations
  • exercises for high-risk departments
  • phishing simulations with debriefing
  • 5 to 10 minute micro-lessons
  • “what would you do here?” exercises
  • tabletops for finance, HR, sales and the board

Employee checklist

  • was this message expected?
  • are the sender and domain correct?
  • does the link lead where it should?
  • is someone asking for a password, MFA code, data or payment?
  • is the request urgent, secret or unusual?
  • should it be verified through a second channel?
  • is the attachment expected?
  • am I sending data to the right person?
  • am I using an approved tool?
  • should I report this to security or IT?

Manager checklist

  • did the new employee receive starter training?
  • does the employee after a role change have the right permissions?
  • did the former employee lose access on the same day?
  • does the team know the phishing procedure?
  • does the team know how to report mistakes?
  • does finance know the payment procedure?
  • does the team use approved tools?
  • is anyone bypassing procedures under time pressure?
  • are repeated mistakes discussed without blame?
  • do training lessons improve processes?

How to measure training effectiveness?

Many companies measure only how many people clicked in a phishing simulation. This is not enough. The goal is behavior change, not only reducing the click rate.

Better metrics

  • number of reported suspicious messages
  • time from message receipt to report
  • number of fast reports after clicking
  • number of unexpected MFA prompts reported by employees
  • number of second-channel confirmations in finance
  • number of data sending mistakes
  • number of shared accounts removed after training
  • number of employees after role-based training
  • number of remediation actions after exercises

What should the board see?

  • most common mistakes in the organization
  • highest-risk departments
  • phishing reporting trends
  • training status
  • key process gaps
  • remediation actions and deadlines

What documents and evidence should be prepared?

Documents

  • acceptable use policy
  • password and access policy
  • phishing reporting procedure
  • suspicious MFA procedure
  • payment and supplier bank account change procedure
  • AI tool use rules
  • incident reporting procedure
  • offboarding checklist

Training evidence

  • training plan
  • participant list
  • training materials
  • short test results
  • confirmation of procedure acknowledgment
  • scenario exercise report

Behavior evidence

  • suspicious message report register
  • incident and near miss register
  • phishing simulation report
  • suspicious MFA report
  • second-channel confirmation report
  • remediation action list

30, 60 and 90-day action plan

First 30 days

  • assign cyber awareness programme owner
  • identify high-risk teams: finance, HR, sales, customer service, IT and the board
  • prepare the top 10 mistake list for the company
  • launch a simple phishing and incident reporting channel
  • prepare rules for passwords, MFA, phishing, payments and data
  • train employees on key rules
  • communicate that mistake reporting is not punished
  • start measuring reports and response time

Days 31 to 60

  • run role-based training for finance, HR, sales and the board
  • exercise MFA code sharing scenario
  • exercise fake supplier bank account change
  • exercise data sent to wrong recipient
  • deploy or improve password manager use
  • remove or reduce shared accounts
  • perform access review in high-risk departments
  • prepare first board report

Days 61 to 90

  • run controlled phishing simulation
  • discuss results without public shaming
  • update procedures based on lessons learned
  • close the most common process gaps
  • prepare short reminder micro-lessons
  • build a cyber awareness dashboard
  • define quarterly training and exercise cycle
  • include training in onboarding and offboarding

Common cyber awareness training mistakes

Mistake 1: scaring instead of teaching behaviors

After training, employees should know what to do, not only what to fear.

Mistake 2: one training for everyone

Finance, HR, sales, IT and the board have different risks. Training should reflect roles.

Mistake 3: blaming people who click

Public shaming reduces reporting. Fast reporting is critical.

Mistake 4: measuring only clicks

It matters more whether employees report suspicious situations and whether procedures work.

Mistake 5: no simple reporting channel

If reporting is difficult, employees will delay it or not report at all.

Mistake 6: no manager support

If a manager demands speed over procedure, training will not work.

Mistake 7: no scenario updates

Attacks change. Training must include SMS, phone calls, QR codes, deepfakes, AI and compromised supplier accounts.

Mistake 8: no link to procedures

Training without phishing, payment, MFA and incident reporting procedures remains theory.

Business example

A services company has 60 employees. It uses Microsoft 365, CRM, invoicing system, cloud files and external accounting. After two incidents, a fake login link click and an attempted supplier bank account change, the board asks for “phishing training”.

A short review shows the problem is not only phishing. Employees do not know where to report suspicious messages. Finance has no second-channel procedure. MFA is enabled, but employees do not know what to do with an unexpected prompt. Some marketing accounts are shared. Managers push for quick task completion, even when a request is unusual.

The company prepares a 90-day programme. It introduces a reporting channel, trains employees using scenarios, creates a payment procedure, exercises suspicious MFA, reduces shared accounts and reports to the board not only clicks, but also reporting and response time. After three months, the number of reports increases, which initially looks like more problems. In practice, the company sees more risks earlier and can respond faster.

How can ccyber.io help?

ccyber.io helps companies build cyber awareness programmes that change behavior, not only check a training box. We combine training, procedures, simulations, metrics and board reporting.

We can support your organization with:

  • cyber awareness and employee behavior audit
  • cyber training programme for SMEs and regulated companies
  • phishing, MFA, password, ransomware and payment training
  • role-based training for finance, HR, sales, IT and the board
  • phishing simulations with debriefing
  • phishing and incident reporting procedure
  • payment and supplier bank account change procedure
  • deepfake, vishing, smishing and MFA fatigue exercises
  • cyber awareness dashboard for the board
  • training evidence pack for audit, ISO 27001, NIS2 and cyber insurance

The best first step is a Cyber Awareness Risk Workshop. In a short workshop, the company can identify which mistakes are most dangerous, which teams need role-based training and which procedures must be improved so employees can work safely.

FAQ

Are employees the weakest link in cybersecurity?

It is not helpful to frame it that way. Employees are part of the security system. If they lack clear rules, simple tools and a reporting culture, they will make mistakes more often.

Which employee mistake is the most dangerous?

The most dangerous mistake is quickly following an unusual request without verification: clicking a link, sharing an MFA code, changing a supplier bank account or sending data to the wrong person.

Do phishing simulations work?

They work best when combined with debriefing, reporting procedures and behavior-focused training. A simulation alone may only stress employees.

How often should employees be trained?

Shorter and more frequent is better. Starter training during onboarding, short quarterly reminders and role-based training for high-risk teams are more practical than one long presentation per year.

What should an employee do after clicking phishing?

They should report immediately without fear of punishment. The company should change the password, review sessions, MFA, logins, mail rules and the possible attacker access scope.

Should employees be punished for mistakes?

Punishment usually reduces reporting. Clear rules, quick response, training and consequences only for deliberate, repeated procedure bypass are better.

How do you measure cyber awareness?

Measure reports, response time, number of suspicious MFA prompts reported, second-channel effectiveness, data sending mistakes, exercise results and remediation actions.

Where should we start?

Start with three things: a simple reporting channel, phishing and MFA training, and second-channel verification for payments, data and access changes.

Summary

The most common incidents often begin with everyday employee decisions: clicking a link, sharing a code, sending a file, approving a payment, using a private tool or ignoring an unusual signal. This does not mean the person alone is at fault. It means the company must design processes so that safe behavior is easy.

The key actions are role-based training, reporting procedure, MFA, password manager, second-channel verification, clear rules for data and tools, secure offboarding and a culture where fast mistake reporting is appreciated.

The best rule is: do not expect employees to be perfect. Give them clear rules, simple tools, permission to pause a process and a safe reporting path before a small mistake becomes a large incident.

Sources

Cyber Insurance: What Should Be Implemented Before the Insurer Starts Asking Questions

Cyber insurance does not replace cybersecurity. Before the insurer starts asking questions, a company should have the basics implemented and documented: MFA, backup with restore testing, email protection, updates, EDR or endpoint protection, administrator account control, access reviews, training, incident response procedure, business continuity plan, supplier register, payment procedure and an evidence pack. The key point is that answers in the insurance questionnaire must match reality, because declarations without evidence may become a problem during policy renewal or claim handling.

Prepared by: CCyber Editorial Team

Short answer

Before speaking with an insurer, a company should have basic safeguards implemented and evidence that they work. The most important items are: MFA for email, administrator accounts, cloud and remote access, tested backups, endpoint protection, updates, vulnerability management, incident response procedure, business continuity plan, employee training, access review, supplier control, payment procedure and an organized evidence pack. Cyber insurance may help cover part of incident costs, but it does not prevent attacks and does not replace the need for reasonable safeguards. The biggest mistake is writing in the insurance questionnaire that a control is in place when it is not implemented in practice or there is no evidence for it.

Last updated

July 2026

Who this article is for

  • boards and business owners
  • CFOs, COOs, CEOs and risk or budget owners
  • CISOs, vCISOs, CTOs, CIOs and IT directors
  • compliance, risk, legal, DPO and internal audit teams
  • SMEs preparing for their first cyber policy
  • companies renewing cyber insurance
  • organizations after an incident that want to improve insurance conditions
  • IT providers, software houses, SaaS companies and processors of customer data
  • companies preparing for customer audits, NIS2, ISO 27001 or cyber risk assessment

Key takeaways

  1. Cyber insurance is not a replacement for cybersecurity. It is part of risk management and works better when the company has basic controls in place.
  2. The insurer will ask not only about tools, but also processes, evidence, tests, incident history, suppliers, backup and incident response.
  3. The most common questions concern MFA, backup, EDR, updates, vulnerabilities, training, phishing, administrator accounts, remote access and incident response plans.
  4. Answers in the questionnaire must match reality. If the company declares a safeguard, it should have evidence: report, configuration, test, procedure or review record.
  5. The best preparation is an insurance evidence pack: asset register, MFA report, restore test, access review, training records, incident response plan and remediation list.

Why does a company need cyber insurance?

Cyber insurance is designed to help a company reduce the financial impact of a cyber incident. It may cover response costs, expert services, legal support, data recovery, crisis communication, downtime, third-party claims or other costs listed in the policy. The scope depends on the contract, exclusions, limits, deductibles and conditions met by the company.

Cyber insurance may be especially useful when the company does not have an internal response team, a large legal department or wants access to vetted providers after an incident. However, this does not mean the policy solves the security problem.

Cyber insurance may help with:

  • ransomware
  • data breach
  • email takeover
  • system downtime
  • forensic expert costs
  • legal costs
  • crisis communication
  • customer or third-party claims, if covered by the policy
  • recovery after an incident

Cyber insurance does not replace:

  • MFA
  • backups
  • email protection
  • access control
  • updates
  • training
  • incident response plan
  • supplier management
  • board risk decisions

Why does the insurer ask technical questions?

The insurer assesses risk. Just as property insurance may involve questions about alarms, fire protection and the condition of installations, cyber insurance involves questions about protection of systems, data and processes. The goal is to understand whether the company is exposed to high risk and whether it can limit the impact of an incident.

Technical questions are not a formality. Answers may affect:

  • policy availability
  • premium level
  • liability limits
  • deductible
  • exclusions
  • requirements before renewal
  • claim assessment after an incident

This is why the insurance questionnaire should be completed jointly by the board, IT, security, legal, finance and risk owner. One person should not complete it based on assumptions.

The key rule: declare only what you can prove

The biggest cyber insurance risk is the gap between declaration and reality. A company may state that it has MFA, backup, EDR and an incident response plan, but after an incident it turns out MFA does not cover administrators, backup was not tested, EDR does not cover all devices and the incident plan was never exercised.

A good questionnaire answer should include three elements:

  • status: implemented, partly implemented, planned, not applicable
  • scope: which systems, accounts, locations and users are covered
  • evidence: report, configuration, test, procedure, protocol or screenshot from the system

Weak answer example

“We have MFA”.

Good answer example

“MFA is enabled for Microsoft 365, administrator accounts, VPN, finance system and password manager. Exceptions are described in the register. The latest MFA report is dated 15 June 2026.”

What does an insurer usually ask about?

The questionnaire depends on the insurer, industry, company size, revenue, data and incident history. In practice, most questions concern recurring areas.

Typical question areas

  • MFA
  • backup and recovery
  • ransomware readiness
  • EDR, antivirus and endpoint protection
  • updates and vulnerabilities
  • access control
  • administrator accounts
  • remote access
  • email protection
  • phishing training
  • incident response
  • business continuity
  • encryption and data protection
  • suppliers and cloud
  • incident history
  • regulatory compliance

20 things to implement before the insurer’s questionnaire

1. MFA for critical accounts

MFA is one of the first controls insurers ask about. Email, administrator accounts, VPN, cloud, banking, CRM, finance systems, backup and remote access are especially important.

Minimum

  • MFA for email
  • MFA for administrators
  • MFA for remote access
  • MFA for cloud and critical systems
  • exception register
  • access removal process after employee departure

Evidence: MFA report from identity system, exception list and risk acceptance decisions.

2. Backup with restore test

The insurer will want to know not only whether backup exists, but whether the company can recover data. Restore testing is more important than simply declaring that backups run.

Minimum

  • backup of critical data
  • backup of email, files, CRM and finance systems where critical
  • backups separated from production
  • backup account protection
  • restore test
  • backup error report

Evidence: backup report, restore test report and remediation list.

3. Ransomware protection

Ransomware is one of the most important scenarios for insurers. The company should show that it reduces both the likelihood and impact of an incident.

Minimum

  • MFA
  • backup
  • EDR or endpoint protection
  • updates
  • administrator reduction
  • removal of unnecessary RDP and remote access
  • ransomware plan
  • scenario exercise

Evidence: ransomware plan, exercise report, EDR report and restore test.

4. EDR, antivirus or endpoint protection

The insurer may ask whether the company protects endpoints, who monitors alerts and whether protection covers all laptops, servers and workstations.

Minimum

  • protection on all company devices
  • current signatures or detection mechanisms
  • alerting for high-risk events
  • defined response process
  • list of devices without protection

Evidence: EDR or antivirus coverage report, exception list and alert report.

5. Updates and vulnerability management

Update questions cover operating systems, applications, network devices, servers, VPN, firewall, cloud and internet-facing systems. The company should have a process, not only a declaration.

Minimum

  • automatic updates where possible
  • monitoring high-risk vulnerabilities
  • remediation timelines
  • risk-accepted exceptions
  • scanning internet-facing systems
  • retest after remediation

Evidence: vulnerability report, patch management report and exception list.

6. Administrator account control

Administrator accounts are especially important for insurers because their compromise may lead to a broad incident.

Minimum

  • administrator list
  • MFA for administrators
  • named accounts
  • no shared accounts where avoidable
  • separate accounts for administration and daily work
  • quarterly review

Evidence: administrator account report and access review report.

7. Access review

Access review shows that the company controls who has access to systems and data. It is useful evidence for the questionnaire, audit and claim handling.

Minimum

  • user account review
  • administrator review
  • supplier review
  • former employee account removal
  • decisions: keep, reduce, remove, investigate

Evidence: access review report and list of removed permissions.

8. Secure remote access

Remote access is a common attacker entry path. The insurer may ask about VPN, RDP, remote support tools and supplier access.

Minimum

  • MFA for remote access
  • no publicly exposed RDP unless necessary
  • supplier access control
  • administrative session logging
  • time-bound supplier access
  • regular review of remote accounts

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

9. Email and phishing protection

Email is one of the most important risk points. The insurer may ask about MFA, anti-phishing protections, SPF, DKIM, DMARC and training.

Minimum

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

Evidence: email configuration report, SPF/DKIM/DMARC status, training report and reporting register.

10. Payment procedure and business email compromise

Not every policy covers losses from payment fraud. The company should have a procedure that reduces fake transfer and supplier bank account change risk.

Minimum

  • second-channel confirmation for bank account changes
  • two-person approval for larger payments
  • ban on decisions under pressure
  • do not use contact details from suspicious messages
  • supplier data change register
  • finance training

Evidence: payment procedure, bank account change register and second-channel confirmations.

11. Incident response plan

The insurer may ask whether the company has a response plan, who activates it and whether it was tested. The plan should be simple, current and known by decision-makers.

Minimum

  • roles and responsibilities
  • emergency contact list
  • ransomware playbook
  • email takeover playbook
  • log preservation procedure
  • board escalation path
  • insurer contact

Evidence: incident response plan and tabletop exercise report.

12. Business continuity and recovery plan

Cyber insurance often concerns downtime costs, but the company must show that it reduces the length and impact of downtime.

Minimum

  • critical service list
  • RTO and RPO
  • system recovery plan
  • crisis communication plan
  • manual procedures where needed
  • plan test

Evidence: BCP, DRP, restore test report and action list after test.

13. System and data inventory

The insurer may ask what the company protects, what data it processes, where systems are and which systems are critical. Without inventory, answers are guesses.

Minimum

  • system list
  • critical data list
  • system owners
  • data owners
  • suppliers
  • backup status
  • MFA status

Evidence: asset, system and data register.

14. Data protection and encryption

If the company processes personal data, customer data, financial information or trade secrets, the insurer may ask about encryption and access control.

Minimum

  • data classification
  • laptop encryption
  • encryption in transit
  • restricted access to sensitive data
  • secure data deletion
  • data sharing register

Evidence: data classification policy, device encryption report and data access report.

15. Employee training

The insurer may ask about training on phishing, MFA, ransomware, passwords and payment procedures. A presentation alone is not enough. Participation and effectiveness evidence are needed.

Minimum

  • starter training
  • phishing training
  • finance training
  • board training
  • short knowledge tests
  • recurring reminders

Evidence: participant list, materials, test results and phishing reporting report.

16. Supplier management

A supplier attack or outage may cause a loss. The insurer may ask about IT, cloud, hosting, backup, finance system and managed service providers.

Minimum

  • critical supplier register
  • supplier risk assessment
  • contracts with security requirements
  • supplier incident reporting rules
  • supplier access control
  • exit plan

Evidence: supplier register, risk assessments and security clauses in contracts.

17. Incident and near miss history

The insurer may ask about previous incidents, notifications, losses, ransomware, data breaches, payment fraud and remediation actions.

Minimum

  • incident register
  • near miss register
  • root cause reports
  • remediation actions
  • evidence of action closure
  • board lessons learned

Evidence: incident register and post-incident action report.

18. Regulatory compliance

The company should know whether it is subject to NIS2, DORA, KSC, GDPR, customer requirements or industry standards. The insurer may ask about legal duties and potential penalties.

Minimum

  • applicability assessment
  • legal and contractual requirements register
  • data breach procedure
  • incident reporting procedure
  • legal and DPO contacts
  • training and review evidence

Evidence: applicability assessment, requirements register and notification procedures.

19. Board report

Cyber insurance is a board decision. The board should know the risks, policy scope, exclusions, limits, insurer requirements and gaps that may affect coverage.

Minimum

  • security status
  • top risks
  • gaps against insurance questionnaire
  • remediation cost
  • policy scope
  • exclusions
  • decision recommendation

Evidence: board report and budget decisions.

20. Evidence repository

In insurance, time and consistency matter. The company should have one place for evidence for the broker, insurer, auditor and claims team.

Minimum

  • MFA report
  • backup report
  • restore test report
  • EDR report
  • access review
  • procedures
  • training records
  • supplier register
  • incident register
  • remediation report

Evidence: evidence matrix with owners, dates and freshness status.

What should be checked in the policy itself?

In cyber insurance, price and limit are not enough. You must understand what is covered, what is excluded, which payment conditions apply and what duties the company has before and after an incident.

Check:

  • whether the policy covers first-party costs
  • whether it covers third-party claims
  • whether it covers ransomware
  • whether it covers business email compromise and fake payments
  • whether it covers business interruption
  • whether it covers supplier incidents
  • whether it covers legal and regulatory costs
  • whether it covers PR and crisis communication
  • whether it covers forensics and incident response
  • whether it has a 24-hour breach hotline

Check exclusions:

  • war and state actions
  • lack of required safeguards
  • inaccurate or incomplete declarations in the questionnaire
  • incidents known before policy start
  • administrative penalties where excluded or uninsurable
  • fake payments where not covered
  • incidents at specific suppliers where excluded

How to prepare answers for the insurance questionnaire?

Step 1: gather the team

IT, security, finance, legal, risk, HR and the board should participate. One person usually does not know the full picture.

Step 2: answer according to the actual state

Do not answer “yes” if the control is only partially implemented. It is better to describe scope, exceptions and remediation plan.

Step 3: collect evidence

Every “yes” answer should have evidence. Every “partly” answer should have an improvement plan.

Step 4: describe exceptions

Exceptions do not necessarily prevent insurance, but they must be visible, justified and managed.

Step 5: update answers when circumstances change

A change of cloud provider, supplier, backup, incident or major change of business scope may require discussion with the broker or insurer.

Minimum evidence pack before speaking with the insurer

Technical evidence

  • MFA report
  • EDR or antivirus report
  • backup report
  • restore test report
  • vulnerability report
  • update report
  • device encryption report
  • administrator account list

Organizational evidence

  • information security policy
  • password and access policy
  • incident response procedure
  • backup procedure
  • payment procedure
  • phishing reporting procedure
  • business continuity plan
  • emergency contact list

Process evidence

  • access review
  • offboarding checklists
  • supplier register
  • supplier risk assessments
  • incident register
  • tabletop report
  • remediation action list
  • board report

Training evidence

  • training plan
  • participant list
  • training materials
  • knowledge test results
  • phishing simulation report, if used
  • finance training confirmation on payment fraud

30, 60 and 90-day action plan

First 30 days

  • assign cyber insurance readiness owner
  • collect the latest questionnaire or broker question list
  • check MFA on critical accounts
  • check backup scope
  • prepare critical systems and data register
  • review administrator accounts
  • check endpoint protection
  • prepare urgent gap and action list

Days 31 to 60

  • perform data restore test
  • perform access review
  • remove former employee accounts
  • update incident response plan
  • prepare payment and bank account change procedure
  • train employees on phishing and MFA
  • assess critical suppliers
  • collect first evidence pack

Days 61 to 90

  • run ransomware or email takeover exercise
  • close key gaps against the questionnaire
  • prepare board report
  • compare policy scope with real risk scenarios
  • review exclusions and post-incident duties
  • define procedure for contacting insurer after incident
  • launch evidence repository
  • prepare action plan for renewal

How to measure cyber insurance readiness?

Technical metrics

  • percentage of critical accounts with MFA
  • percentage of devices with EDR or antivirus protection
  • date of latest restore test
  • number of overdue high-risk vulnerabilities
  • number of administrator accounts
  • number of systems without owner

Process metrics

  • date of latest access review
  • time to remove access after employee departure
  • number of open remediation actions
  • number of suppliers without risk assessment
  • number of incidents and near misses
  • date of latest incident exercise

Insurance metrics

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

Common company mistakes

Mistake 1: treating the questionnaire as a formality

The insurance questionnaire is a risk document. Answers should be verified and reflect reality.

Mistake 2: declaring MFA without checking scope

MFA may work for users, but not for administrators, VPN, suppliers or emergency accounts. This is a major difference.

Mistake 3: backup without testing

The insurer may ask about backup, but after an incident what matters is whether the company can restore data and systems.

Mistake 4: no post-incident procedure

After an attack, the company starts looking for the insurer, lawyer and response provider contact details. This extends chaos.

Mistake 5: ignoring business email compromise

Not every cyber policy covers fake payments. This must be checked separately.

Mistake 6: no supplier control

A supplier may have administrator, backup or customer data access. The insurer may ask whether the company manages that risk.

Mistake 7: no board report

The board buys the policy but does not know the exclusions, gaps, requirements and actions needed for renewal.

Mistake 8: no update when circumstances change

The company changes cloud, supplier, backup or operating model, but does not update information provided to the broker or insurer.

Business example

A services company has 80 employees and wants to buy cyber insurance. The questionnaire includes questions about MFA, backup, EDR, ransomware, training, incidents, suppliers and response planning. The board initially assumes most answers are “yes” because the company has an external IT provider.

A short review shows that MFA works in Microsoft 365, but does not cover the supplier’s administrator accounts. Backup exists, but has not been tested for more than a year. EDR does not cover all laptops. Access review has not been performed. There is no payment procedure, and phishing training happened only once.

The company does not enter uncertain answers into the questionnaire. Within 60 days, it improves MFA, performs a restore test, prepares access review, completes EDR coverage, creates a payment procedure and trains employees. It attaches evidence and a remediation plan to the questionnaire. The result: the conversation with broker and insurer is based on facts, not assumptions.

How can ccyber.io help?

ccyber.io helps companies prepare for cyber insurance in a practical, risk-based and evidence-driven way. We do not start with the questionnaire alone. We start by checking whether the company has the safeguards it declares and whether it can prove them.

We can support your organization with:

  • cyber insurance readiness assessment
  • insurance questionnaire review
  • MFA, backup, EDR and remote access verification
  • data restore test
  • administrator account review and access review
  • incident response plan and ransomware playbook
  • payment and business email compromise procedure
  • 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 Readiness Workshop. In a short workshop, the company can check which questionnaire answers are reliable, where evidence is missing, which gaps may affect coverage and what should be implemented before speaking with the insurer.

FAQ

Does cyber insurance replace cybersecurity?

No. Cyber insurance can help after an incident, but it does not prevent attacks. The company still needs basic safeguards, procedures, tests and evidence.

What does the insurer usually check?

MFA, backup, restore testing, EDR, updates, administrator accounts, remote access, training, incident response, incident history, suppliers and data protection.

Is MFA required?

In practice, MFA is one of the most important expectations. It should cover email, administrator accounts, cloud, remote access and critical systems.

Is backup enough?

No. The company needs restore testing, backup account protection, backups separated from production and a critical system recovery plan.

What if the company does not have all safeguards?

Do not pretend they are implemented. State the actual situation, exceptions, remediation plan and deadlines. This is better than unsupported declarations.

Does the policy cover fake payments?

Not always. Business email compromise, social engineering fraud and fake payments may need separate coverage or special conditions. This must be checked in the policy.

Which evidence should be prepared before speaking with a broker?

MFA report, backup report, restore test, EDR report, access review, administrator account list, incident response plan, training records, supplier register and remediation report.

Where should we start?

Start by comparing the insurance questionnaire with the actual security state. Mark answers as confirmed, partial or missing evidence, then close the most important gaps.

Summary

Cyber insurance is an important element of risk management, but it works best when the company has real safeguards and evidence. A policy does not replace MFA, backup, EDR, training, procedures, access control and incident response planning.

Before the insurer starts asking questions, the company should prepare the minimum: MFA, tested backup, endpoint protection, updates, administrator control, access review, email protection, payment procedure, incident response, BCP, training, supplier control and evidence repository.

The best rule is: do not buy a policy based on wishful answers. First check the actual state, collect evidence and show the insurer that the company truly manages cyber risk.

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.