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.

Ransomware Checklist for Companies

A ransomware checklist helps a company prepare for an attack, reduce the impact of data encryption and return to operations faster. The key elements are backups, MFA, patching, segmentation, monitoring, incident response plan, crisis communication, contact list, recovery testing and clear board decisions before an incident happens.

Prepared by: CCyber Editorial Team

Short answer

A ransomware checklist for companies should cover three stages: preparation before an attack, response in the first hours and safe recovery. Before an attack, the company needs tested backups, MFA, patching, segmentation, monitoring, contact list and communication plan. After ransomware is detected, the company must quickly isolate infected systems, preserve evidence, activate the crisis team, assess the attack scope, protect backups and recover systems only from clean sources.

Last updated

July 2026

Who this article is for

  • boards
  • business owners
  • IT directors
  • CISOs and security leaders
  • helpdesk teams and administrators
  • legal, compliance and data protection teams
  • business continuity leaders
  • SMEs and companies without large security teams
  • manufacturing, services, SaaS and e-commerce companies
  • organizations preparing for NIS2, KSC, ISO/IEC 27001, SOC 2 or customer audits

Key takeaways

  1. Ransomware is not only file encryption. It increasingly includes data theft, extortion, pressure on management and threats to publish information.
  2. The most important protection is tested backups separated from the main environment and a recovery plan for critical services.
  3. In the first hours, the priorities are limiting spread, protecting backups, preserving evidence and activating the crisis team.
  4. Decisions about contacting criminals, paying, communicating with customers and regulatory notifications should be prepared before the incident, not under pressure.
  5. The company should regularly exercise a ransomware scenario because a plan that has not been tested often fails in a real crisis.

What is ransomware?

Ransomware is a type of malware or attack that blocks access to systems or encrypts data and demands payment to unlock it. In many modern attacks, criminals also steal data and threaten publication, contact with customers, media exposure or further business disruption.

Ransomware impact may include:

  • no access to files and systems
  • production or service stoppage
  • inability to issue invoices
  • no access to email and documents
  • leakage of customer or employee data
  • contract delivery problems
  • legal, technical and communication costs
  • difficult relationships with customers, insurers and regulators

Ransomware is a business problem, not only a technical one. It affects the board, finance, operations, legal, communications, IT, security, customers and suppliers.

Ransomware checklist: quick overview

Before the attack

  • identify critical systems and data
  • implement MFA for email, VPN, cloud and administrators
  • regularly patch systems and edge devices
  • disable or strongly restrict unnecessary remote access
  • apply least privilege
  • segment the network
  • create backups separated from the production environment
  • regularly test recovery
  • monitor unusual logins, file encryption and lateral movement
  • prepare an incident response plan
  • prepare an emergency contact list
  • exercise a ransomware scenario

In the first hour

  • activate the crisis team
  • disconnect infected devices from the network
  • do not shut everything down without technical and evidence-related decision
  • protect backups
  • block suspicious accounts
  • terminate suspicious remote sessions
  • preserve logs and system images
  • identify affected systems
  • activate alternative communication

In the first 24 hours

  • determine the attack scope
  • check whether data was stolen
  • check whether the attack is still active
  • identify the entry point
  • set recovery priorities
  • check whether backups are clean
  • prepare internal and external communication
  • assess legal and regulatory obligations
  • contact the insurer if applicable
  • decide whether external incident response support is needed

During recovery

  • restore critical systems first
  • do not restore from backups before checking they are clean
  • first rebuild identity, administrator accounts and core infrastructure
  • change passwords and secrets that may have been compromised
  • monitor the environment after recovery
  • do not reconnect old devices without verification
  • document decisions and actions

Preparation checklist before an attack

1. Identify critical systems

The company must know which systems determine its survival after an attack. Not all systems are equally important. Email, finance, production, CRM, sales systems, ERP, code repositories and management documents require different treatment.

Prepare a list of:

  • critical systems
  • business owners
  • technical owners
  • dependencies between systems
  • minimum recovery time
  • minimum operating level after an attack
  • data whose loss would stop the company

Evidence to prepare: critical system register with recovery priority.

2. Implement MFA

MFA should cover email, VPN, remote access, cloud systems, administrator accounts, financial systems and developer tools. A stolen password without MFA may be enough for an attacker to enter the environment.

Protect first:

  • administrators
  • board
  • finance
  • HR
  • IT and security
  • VPN
  • Microsoft 365 or Google Workspace
  • code repositories
  • systems with customer data

Evidence to prepare: report of users and applications covered by MFA and exception list.

3. Restrict remote access

Ransomware often starts with compromised remote access, vulnerable VPN, exposed remote desktop or a supplier account. Remote access should be limited to what is necessary.

Check:

  • whether remote desktop is exposed to the internet
  • whether VPN has MFA
  • whether suppliers have permanent access
  • whether access is logged
  • whether remote accounts use least privilege
  • whether supplier access is removed after work is completed

Evidence to prepare: remote access, supplier and exception register.

4. Patch systems and edge devices

Vulnerabilities in VPNs, firewalls, mail servers, remote access systems and public applications are especially dangerous. These are often the first places attackers check.

Patch priority:

  • VPN
  • firewalls
  • mail gateways
  • public servers
  • remote access systems
  • domain controllers
  • backup systems
  • device management systems

Evidence to prepare: vulnerability report and patch status of critical systems.

5. Apply least privilege

Ransomware spreads faster when users and administrators have excessive permissions. The more access a compromised account has, the greater the impact.

Check:

  • who has administrator permissions
  • who has access to backup systems
  • who has access to customer data
  • who can install software
  • who can create new accounts
  • who has access to network shares

Evidence to prepare: access review report and removed excessive permissions list.

6. Segment the network

Segmentation limits ransomware spread. If the whole company works in one flat network, attackers can more easily move between computers, servers, backups and production systems.

Separate:

  • user workstations
  • servers
  • backup systems
  • financial systems
  • production environments
  • OT environments if present
  • development environments
  • guest network

Evidence to prepare: segmentation diagram and list of allowed connections between segments.

7. Prepare ransomware-resistant backups

Backups are one of the most important controls. They must be regular, tested, separated from the main environment and protected against deletion by attackers.

A good backup strategy includes:

  • copies of the most important data
  • copies of system configurations
  • offline or immutable backups
  • copies in more than one location
  • separate administrative accounts for backup systems
  • MFA for backup administrators
  • regular recovery tests
  • backup scanning before recovery

Evidence to prepare: latest recovery test report and critical system backup list.

8. Monitor signs of attack

Ransomware usually does not start with encryption. Before that, there may be phishing, account takeover, network scanning, lateral movement, disabling security tools, data theft and backup deletion.

Monitor:

  • unusual logins
  • logins from new countries
  • new administrator accounts
  • mass file changes
  • security tool disabling
  • backup deletion attempts
  • unusual data transfers
  • traffic between segments
  • administrative tool use outside normal working hours

Evidence to prepare: ransomware alert list and escalation procedure.

9. Prepare a ransomware response plan

The plan should be short, practical and available even when the company cannot access email, network drives or the ticketing system.

The plan should include:

  • roles and responsibilities
  • emergency contact list
  • system isolation decisions
  • evidence preservation procedure
  • communication procedure
  • criteria for external support activation
  • insurer contact procedure
  • regulatory notification procedure
  • recovery priorities

Evidence to prepare: ransomware response plan available offline.

10. Prepare crisis communication

During an attack, normal communication channels may not work. Email, chat, internet telephony or ticketing may be unavailable. The company needs an alternative communication plan.

Prepare:

  • contact list for board and crisis team
  • alternative communication channels
  • employee communication templates
  • customer communication templates
  • authorized media spokesperson
  • supplier communication rules
  • incident status update rules

Evidence to prepare: crisis communication plan and message templates.

First 60 minutes after ransomware detection

1. Activate the crisis team

Do not start with chaotic calls to everyone. Activate the predefined crisis team. It should include IT, security, board, legal, communications, operations and owners of critical systems.

Goal: one decision structure, one priority list, one version of the truth.

2. Isolate infected devices

If infected devices are known, disconnect them from wired networks, Wi-Fi and other connections. Do not connect backup media to suspicious devices.

Note: do not blindly shut everything down if this may destroy evidence or make analysis harder. The shutdown decision should be made with the technical incident lead.

3. Protect backups

Immediately check whether the attacker has access to backup systems. If needed, separate backups from the production environment, block suspicious accounts and preserve backup metadata.

4. Block suspicious accounts

Block accounts used in the attack, accounts with suspicious logins and accounts whose credentials may have been compromised. Priorities are administrators, VPN, email, cloud accounts and supplier accounts.

5. Terminate suspicious remote sessions

Check VPN, remote desktop, administrative tools and supplier access. If an active attacker session is suspected, terminate it and preserve logs.

6. Preserve evidence

Save the ransom note, screenshots, encrypted file names, wallet addresses, attacker website addresses, logs, affected host list and detection time.

7. Activate alternative communication

If corporate email is affected or may be monitored by attackers, switch the crisis team to an alternative communication channel.

First 24 hours checklist

1. Determine the attack scope

Answer:

  • which systems are encrypted?
  • which systems are suspicious?
  • which accounts were used?
  • is the attack still active?
  • are backups safe?
  • was data stolen?
  • are customer systems affected?

2. Identify the entry point

Common entry points are phishing, compromised account, vulnerable VPN, exposed remote desktop, public application vulnerability, supplier or stolen credentials.

If the entry point is not identified, the company may restore systems and the attacker may return through the same path.

3. Check for data theft

Many ransomware attacks include data theft before encryption. Check unusual data transfer, access logs, archives created on servers, outbound connections and communication with unusual locations.

4. Set recovery priorities

Not everything must be restored at once. First restore the minimum ability for the company to operate.

Example sequence:

  • identity and administrator accounts
  • network and core infrastructure
  • backup systems
  • email or alternative communication
  • operational systems critical for the business
  • financial systems
  • customer systems
  • remaining business applications

5. Assess legal and regulatory obligations

Ransomware may trigger incident notification, personal data breach notification, customer notification, insurer notification, regulator notification, CSIRT notification or law enforcement reporting.

Involve legal, data protection, compliance and the board. Do not rely only on IT’s technical assessment.

6. Prepare communication

Communication must be clear, consistent and careful. Do not promise that data was not stolen if analysis is still ongoing. Do not publish technical details that may help attackers.

Prepare communications for:

  • employees
  • board
  • customers
  • suppliers
  • insurer
  • regulators
  • media if the incident becomes public

Recovery checklist after ransomware

1. Recover only from clean backups

Do not restore systems from a backup that has not been checked. Ransomware or attacker tools may have entered backups before the company detected the incident.

Before recovery, check:

  • backup date
  • backup integrity
  • whether the backup contains malware
  • whether the backup contains attacker accounts
  • whether the entry point has been closed

2. Rebuild secure foundations first

Recovering business systems does not make sense if the core infrastructure is still compromised.

First rebuild:

  • identity and directory services
  • administrator accounts
  • MFA policies
  • network and segmentation
  • monitoring systems
  • backup system
  • secure administrative workstations

3. Change passwords and secrets

Assume that some passwords and secrets may have been compromised. This includes user passwords, administrator passwords, service accounts, API keys, tokens, cloud credentials and supplier credentials.

4. Monitor the environment after recovery

After recovery, attackers may try to return. Monitoring should be increased for at least several weeks after the incident.

Monitor:

  • new administrator accounts
  • unusual logins
  • traffic to known attacker infrastructure
  • reappearance of attacker tools
  • backup deletion attempts
  • mass file changes
  • traffic between network segments

5. Do not return to the vulnerable state

Recovery is not the end. If the company restores the environment with the same passwords, same remote access, no MFA and the same vulnerabilities, the risk of attacker return is high.

Should the company pay the ransom?

The decision to pay a ransom is a board, legal, operational and ethical decision. It should be made after consultation with legal counsel, insurer, incident response specialists and law enforcement where applicable.

Key facts:

  • payment does not guarantee data recovery
  • payment does not remove malware
  • payment may fund criminal groups
  • payment may encourage future attacks
  • some payments may create legal or sanctions risk
  • criminals may still publish data

The best strategy is to prepare the company so that paying is not the only survival option.

What documents and evidence should be prepared?

Documents before the incident

  • ransomware response plan
  • business continuity plan
  • disaster recovery plan
  • critical system register
  • backup register
  • emergency contact list
  • crisis communication plan
  • supplier list and support contracts

Technical evidence

  • system logs
  • remote access logs
  • email logs
  • cloud logs
  • disk or memory images where needed
  • ransom note screenshots
  • addresses and identifiers used by attackers
  • affected system list
  • blocked account list

Business evidence

  • detection time
  • crisis team activation time
  • board decision list
  • customer impact
  • production or service impact
  • incident costs
  • communications to customers and employees
  • regulator or authority notifications where applicable

30, 60 and 90-day ransomware readiness plan

First 30 days

  • assign a ransomware readiness owner
  • identify critical systems and data
  • check whether administrators have MFA
  • review remote access and VPN
  • check where backups are stored
  • perform the first recovery test of a selected system
  • prepare an emergency contact list
  • prepare a short response plan

Days 31 to 60

  • implement MFA for email, VPN and critical systems
  • restrict supplier remote access
  • prepare segmentation for key systems
  • protect backups against deletion
  • start basic ransomware monitoring
  • prepare crisis communication templates
  • review legal and regulatory obligations

Days 61 to 90

  • run a ransomware tabletop exercise
  • test recovery of a critical system
  • prepare a readiness report for the board
  • remove excessive permissions
  • close unnecessary remote services
  • prepare a customer communication plan
  • define the improvement plan for the next 6 months

How to measure ransomware readiness?

Backup metrics

  • percentage of critical systems covered by backups
  • time to recover a critical system
  • date of the latest recovery test
  • number of backups separated from the main environment
  • number of backups protected against deletion

Access metrics

  • percentage of users with MFA
  • percentage of administrators with MFA
  • number of privileged accounts
  • number of shared accounts
  • number of active MFA exceptions

Vulnerability metrics

  • number of critical vulnerabilities in public systems
  • time to remediate critical vulnerabilities
  • number of outdated systems
  • number of exposed remote services

Response metrics

  • time to detect suspicious activity
  • time to isolate an infected system
  • time to activate the crisis team
  • time to prepare the first communication
  • time to restore minimum business operation

Common ransomware mistakes

Mistake 1: backups without recovery testing

A backup that has not been tested is hope, not a strategy. The company must regularly check whether it can restore data and systems within an acceptable time.

Mistake 2: backups constantly connected to the network

Attackers often try to delete or encrypt backups. Backups should be protected against deletion, offline or immutable.

Mistake 3: no MFA for administrators and VPN

Without MFA, a stolen password may give an attacker access to critical systems. Administrators and remote access must be protected first.

Mistake 4: response plan available only in an encrypted system

The plan, contact list and procedures must also be available offline. If they are only on an encrypted network drive, they will not help during a crisis.

Mistake 5: chaotic communication

Lack of consistent communication may deepen the crisis. Employees, customers, media and regulators should receive clear, approved and current information.

Mistake 6: recovery without closing the entry point

If the company does not know how the attacker entered, it may restore the environment and be attacked again.

Mistake 7: no board decisions before the incident

The hardest decisions should not be made for the first time at 3 a.m. The board should define principles for communication, payment, recovery priorities and authority contact earlier.

Business example

A manufacturing company has 250 employees. It has ERP, file server, cloud email, several production systems and remote access for suppliers. The board assumes backups work because the backup system sends positive daily notifications.

During a ransomware exercise, it turns out that nobody has tested ERP recovery for more than a year, file server backups are accessible from the same domain, a supplier has permanent VPN access without MFA and the response plan exists only on a network drive.

The exercise shows that the biggest problem is not the lack of one tool. The problem is lack of operational readiness.

The company implements MFA for administrators and VPN, separates critical data backups from the main environment, prepares an offline contact list, tests ERP recovery and creates a first 24-hour response plan.

After 90 days, the board sees a concrete change: the company knows what to recover first, how long it takes, who makes decisions, how to communicate with customers and which gaps still need to be closed.

How can ccyber.io help?

ccyber.io helps companies prepare for ransomware practically, without excessive theory and without assuming that one tool solves the problem. We focus on operational readiness, backups, response plan, communication, board decisions and recovery testing.

We can support your organization with:

  • ransomware readiness assessment
  • backup and recovery testing review
  • ransomware response plan
  • tabletop exercise for board and IT
  • MFA, VPN and remote access review
  • segmentation and permissions review
  • contact list and crisis communication preparation
  • notification obligation review
  • first 24-hour attack response plan
  • 30, 60 and 90-day ransomware readiness roadmap

The best first step is a short ransomware readiness assessment. It helps check whether the company has working backups, a recovery plan, access control, prepared communication and board decisions for a real attack.

FAQ

What is ransomware?

Ransomware is an attack where criminals block access to systems or encrypt data and demand payment. In many cases, they also steal data and threaten to publish it.

What is the most important protection against ransomware?

The most important protections are tested backups, MFA, patching, remote access restriction, segmentation, monitoring and an exercised response plan.

Are backups enough?

Not always. Backups must be offline or protected against deletion, regularly tested and checked before recovery. The company must also close the attacker’s entry point.

What should be done first after ransomware is detected?

Activate the crisis team, isolate infected devices, protect backups, block suspicious accounts, preserve evidence and determine the scope of the attack.

Should the company pay the ransom?

There is no guarantee of data recovery after payment. The decision requires legal, operational and board-level analysis. The best strategy is to prepare the company so that payment is not the only option.

Does ransomware need to be reported?

It depends on sector, country, data type and incident impact. Notification may be required to a regulator, CSIRT, data protection authority, insurer, customers or law enforcement.

How often should a ransomware plan be tested?

At least once a year, and more often in higher-risk companies. Both the technical side and board decisions, communication and system recovery should be exercised.

What should the board receive in a ransomware report?

The board should receive information about critical systems, backup status, recovery test results, MFA level, remote access, major gaps and the budget needed to reduce risk.

Summary

A ransomware checklist for companies should not be only a document in a security folder. It should be a practical tool that helps prepare the company, make quick decisions and return to operation after an attack.

The key elements are ransomware-resistant backups, MFA, patching, segmentation, monitoring, remote access restriction, response plan, crisis communication and regular exercises.

Companies that prepare these elements earlier do not eliminate risk completely, but significantly improve their chances of limiting losses, recovering faster and managing the crisis more calmly.

Sources

MFA for Companies: How to Implement It Without Chaos?

MFA, or multi-factor authentication, makes account takeover much harder even when a password is stolen. A good MFA rollout is not just switching it on for everyone at once. Companies need to prepare users, applications, backup methods, emergency access, administrators, exceptions, monitoring and a phased implementation plan.

Prepared by: CCyber Editorial Team

Short answer

MFA for companies should be implemented in stages: first administrator accounts and critical systems, then email, VPN, cloud applications, financial systems and remaining users. To avoid chaos, companies should first prepare a list of users and applications, choose the right MFA methods, provide backup methods, define account recovery, train employees, run a pilot and only then enforce MFA in waves. The best long-term direction is phishing-resistant MFA, such as security keys and passkeys.

Last updated

July 2026

Who this article is for

  • boards
  • business owners
  • IT directors
  • CISOs and security leaders
  • Microsoft 365, Google Workspace and cloud administrators
  • helpdesk and IT support teams
  • HR and internal communication teams
  • SMEs implementing baseline cybersecurity
  • companies preparing for NIS2, KSC, ISO/IEC 27001, SOC 2 or customer audits
  • organizations that want to reduce phishing, account takeover and ransomware risk

Key takeaways

  1. MFA should be standard for email, VPN, cloud systems, administrator accounts, financial applications and systems containing customer data.
  2. The biggest mistake is enabling MFA for everyone without preparing communication, backup methods, helpdesk and account recovery.
  3. Not all MFA methods are equally secure. SMS and voice calls are better than no MFA, but high-risk accounts should use phishing-resistant methods.
  4. Administrators and users with privileged access should have stronger MFA methods than standard users.
  5. A good MFA rollout requires a plan: pilot, deployment waves, enrollment monitoring, exception handling, reporting and regular method review.

What is MFA?

MFA, or multi-factor authentication, is a login method that requires more than one proof of user identity. In simple terms: the password alone is not enough. The user must confirm the login using an additional factor.

Common authentication factors are:

  • something the user knows, such as a password or PIN
  • something the user has, such as a phone, authenticator app, security key or company device
  • something the user is, such as biometrics used locally on the device

MFA reduces account takeover risk because an attacker who steals a password still needs to pass additional verification. However, not every MFA method provides the same level of protection. Some methods can be bypassed through phishing, fake login pages, session theft, phone attacks or notification fatigue.

Why is MFA important for companies?

User accounts are one of the most common entry points into organizations. A compromised mailbox, administrator account, VPN account or cloud account may give an attacker access to data, documents, invoices, conversations, customers, systems and internal tools.

MFA helps reduce the risk of:

  • phishing
  • business email compromise
  • ransomware starting with stolen credentials
  • VPN access after password leakage
  • abuse of administrator accounts
  • logins from unknown locations
  • use of passwords stolen from other services
  • access to customer data through a compromised employee account

For boards, MFA is one of the most practical security controls because it directly reduces account takeover risk and is easier to implement than many advanced security projects.

Why do MFA deployments often become chaotic?

MFA itself is not difficult. The difficult part is deploying it across the organization without blocking employees, administrators, integrations, legacy applications and business processes.

Common causes of chaos:

  • no list of applications requiring MFA
  • no list of administrator and privileged accounts
  • no pilot
  • enabling MFA for everyone at once
  • no employee communication
  • no registration instructions
  • no backup methods
  • no account recovery procedure
  • unprepared helpdesk
  • legacy authentication protocols left enabled
  • too many exceptions
  • no monitoring of who actually registered for MFA

A good MFA rollout is an organizational project, not only an admin panel setting.

Which MFA methods should be chosen?

Best methods for high-risk accounts

For administrators, board members, finance, IT, remote access and critical systems, the best direction is phishing-resistant MFA.

Best methods:

  • FIDO2/WebAuthn security keys
  • passkeys based on WebAuthn
  • certificate-based authentication where the company has mature infrastructure
  • passwordless sign-in with strong device protection

Phishing-resistant methods matter because they do not rely on copying a code from a phone into a fake website. They are bound to a specific domain or service, which makes classic credential phishing significantly harder.

Good methods for most users

For most employees, an authenticator app is a good starting point, especially if it supports number matching, login context or passwordless sign-in.

Practical methods:

  • authenticator app with push notification and number matching
  • app-generated one-time codes
  • passkeys on company devices
  • security keys for higher-risk users

Transitional methods only

SMS and voice calls are better than no MFA, but they should not be the target method for privileged accounts and critical systems.

SMS and voice limitations:

  • risk of phone number takeover
  • risk of code phishing
  • roaming and coverage problems
  • lack of resistance to real-time phishing
  • weak control over personal devices

Practical recommendation: if a company starts with SMS, it should have a migration plan to stronger methods.

Where should MFA be implemented first?

Administrator accounts

Administrator accounts should be protected first. A compromised administrator account may allow an attacker to disable security controls, add accounts, change access rules or steal data.

Corporate email

Email is one of the most important systems. A compromised mailbox can be used for phishing, payment fraud, password resets and document access.

VPN and remote access

Remote access without MFA is high risk. If a user password leaks, an attacker may try to log in to the company network.

Cloud systems

Microsoft 365, Google Workspace, CRM systems, project tools, HR tools, code repositories and financial systems should be covered by MFA.

Financial and accounting systems

Finance, payment, invoice and banking accounts should use stronger methods because compromise may directly lead to financial loss.

Code repositories and developer tools

Software houses and SaaS companies should protect code repositories, CI/CD systems, cloud accounts, ticketing systems and deployment tools with MFA.

How to implement MFA step by step?

Step 1: assign an MFA rollout owner

The MFA project should have an owner. In a small company, this may be an IT administrator or security owner. In a larger organization, involve IT, security, helpdesk, HR, internal communication, system owners and the board.

The owner should coordinate:

  • deployment scope
  • MFA method selection
  • pilot
  • employee communication
  • helpdesk support
  • exception handling
  • progress reporting

Evidence to prepare: decision naming the MFA project owner, responsibility scope and supporting team list.

Step 2: prepare a list of users, accounts and applications

Do not start with configuration. First identify what the company has and what must be protected.

Prepare a list of:

  • users
  • administrators
  • privileged accounts
  • service accounts
  • cloud applications
  • VPN and remote access
  • financial systems
  • code repositories
  • legacy applications
  • systems that do not support modern authentication

Evidence to prepare: register of users, privileged accounts and applications covered by MFA.

Step 3: divide users into risk groups

Not all users have the same risk. An administrator, finance user, board member and standard office user should not have identical requirements.

Example grouping:

  • group 1: administrators and privileged accounts
  • group 2: board, finance, HR and users with confidential data access
  • group 3: remote access users
  • group 4: all remaining employees
  • group 5: partners, suppliers and external users

Evidence to prepare: user group list and required MFA methods for each group.

Step 4: choose MFA methods for each group

Match the method to risk, system and user experience. Do not choose a method only because it is the easiest to enable.

Example approach:

  • administrators: security key or passkey plus backup method
  • board and finance: phishing-resistant method or authenticator app with additional protections
  • standard users: authenticator app or passkey
  • employees without a work smartphone: security key or hardware token
  • suppliers: MFA, limited access and permission review

Evidence to prepare: MFA method matrix by user group and application type.

Step 5: prepare emergency access

The company must have a plan for situations where an administrator loses a phone, security key or MFA method. Emergency access must not become a backdoor for attackers, but lack of emergency access may block the company during a crisis.

Prepare:

  • emergency administrator accounts
  • strong protection for emergency accounts
  • separate storage of access data
  • monitoring of emergency account use
  • procedure for crisis use
  • regular emergency access test

Evidence to prepare: emergency access procedure and emergency account test report.

Step 6: prepare user account recovery

Users will lose phones, change devices, forget PINs, travel abroad and need help. Account recovery must be secure and fast.

The procedure should define:

  • how the user reports a problem
  • how helpdesk verifies the user’s identity
  • who can reset MFA methods
  • when temporary access can be issued
  • how long temporary access works
  • how MFA resets are documented
  • how recovery abuse is detected

Evidence to prepare: MFA recovery procedure, authorized staff list and reset register.

Step 7: prepare employee communication

MFA affects everyday work. Employees must know why the company is implementing MFA, what they need to do, by when, which method to choose and where to get help.

Communication should include:

  • what MFA is
  • why the company is implementing it
  • when the change happens
  • which method must be registered
  • step-by-step instructions
  • support contact
  • backup method information
  • warning about phishing of codes and push notifications

Evidence to prepare: employee communications, instructions and training materials.

Step 8: run a pilot

A pilot helps detect problems before deploying MFA across the whole company. The pilot should include different types of users, not only IT.

Include in the pilot:

  • administrators
  • office users
  • mobile workers
  • finance or HR
  • remote workers
  • users without a work phone
  • selected critical applications

Evidence to prepare: pilot report, issue list and decisions before broad deployment.

Step 9: deploy MFA in waves

Do not deploy MFA to everyone on one day if the organization is not ready. Deployment waves are better: administrators, high-risk groups, email, VPN, cloud applications and then the rest of the company.

Example sequence:

  • wave 1: administrators and privileged accounts
  • wave 2: board, finance, HR and IT
  • wave 3: email and cloud applications for everyone
  • wave 4: VPN and remote access
  • wave 5: business applications and suppliers

Evidence to prepare: deployment wave schedule, enrollment status and exception list.

Step 10: secure legacy applications and protocols

Some older applications may not support modern MFA. This does not mean they can be left unprotected. Risk must be reduced in another way.

Possible actions:

  • migration to modern authentication
  • publishing the application through an access gateway
  • enforcing MFA at VPN or conditional access level
  • restricting access to selected locations
  • disabling legacy authentication protocols
  • monitoring logins to legacy applications

Evidence to prepare: legacy application list and risk reduction plan.

Step 11: monitor enrollment and sign-ins

After MFA deployment, check who registered, which methods are used, who uses weaker methods and where login errors appear.

Monitor:

  • percentage of users with MFA
  • percentage of administrators with phishing-resistant MFA
  • users without backup method
  • sign-ins rejected by MFA
  • frequent MFA resets
  • policy exceptions
  • logins from high-risk locations
  • attempts to register new methods by an attacker

Evidence to prepare: MFA dashboard, enrollment report and exception report.

Step 12: review exceptions and improve methods

MFA exceptions should be rare, justified, time-limited and approved. Every permanent exception becomes a risk.

Regularly check:

  • who is excluded from MFA
  • why the exception exists
  • when the exception expires
  • whether it can be removed
  • whether SMS can be replaced by a better method
  • whether administrators use phishing-resistant methods

Evidence to prepare: MFA exception register and monthly exception review.

MFA in Microsoft 365: what to watch for?

Conditional Access

In Microsoft Entra, MFA is usually best enforced through Conditional Access policies. This allows MFA to depend on user, application, risk, location, device and access type.

Administrators first

Administrator accounts should have MFA from the beginning. For administrators, stronger methods such as security keys, passkeys or other phishing-resistant methods are recommended.

Backup methods

A user should have more than one method. This reduces lockouts and helpdesk tickets.

User registration

MFA registration should be communicated in advance. Users should know where to register a method and how to check their settings.

Legacy protocols

Legacy authentication protocols may weaken modern controls. Check whether the organization has applications or mail clients using older login methods.

MFA in Google Workspace: what to watch for?

Organizational units and groups

Google Workspace allows 2-Step Verification deployment for organizational units and groups. This supports phased implementation and pilots for selected teams.

Enrollment monitoring

Before enforcing MFA, check which users registered a method, who has not and which groups need support.

Methods for high-risk groups

For administrators, finance and high-risk users, security keys or passkeys should be required where available and well supported by the environment.

Avoiding lockouts

Before enforcement, users should be informed, given time to enroll and supported if they lose access to their MFA method.

MFA checklist for companies

Scope

  • do we have a list of applications covered by MFA?
  • does MFA cover email?
  • does MFA cover VPN?
  • does MFA cover administrator accounts?
  • does MFA cover financial systems?
  • does MFA cover code repositories and developer tools?

Methods

  • did we choose MFA methods based on risk?
  • do administrators have phishing-resistant methods?
  • do users have backup methods?
  • is SMS only transitional?
  • do we have a plan to move toward passkeys or security keys?

Process

  • do we have a pilot?
  • do we have deployment waves?
  • is helpdesk prepared?
  • do we have an account recovery procedure?
  • do we have a procedure for new employees?
  • do we have a procedure for departing employees?

Security

  • do we have emergency accounts?
  • do we monitor emergency account use?
  • do we block or restrict legacy authentication protocols?
  • do we monitor high-risk sign-ins?
  • are MFA exceptions time-limited?

Evidence

  • do we have an MFA enrollment report?
  • do we have an exception register?
  • do we have training evidence?
  • do we have MFA reset logs?
  • do we have a board report?

30, 60 and 90-day MFA implementation plan

First 30 days

  • assign an MFA project owner
  • prepare a list of users, administrators and applications
  • identify privileged accounts
  • choose target MFA methods
  • prepare employee communication
  • prepare account recovery procedure
  • secure administrator accounts
  • run a pilot

Days 31 to 60

  • review pilot results
  • improve instructions and communication
  • prepare helpdesk for requests
  • deploy MFA for board, finance, HR and IT
  • enable MFA for email and cloud applications
  • review legacy applications and protocols
  • prepare enrollment and exception dashboard

Days 61 to 90

  • expand MFA to all users
  • enable MFA for VPN and remote access
  • remove temporary exceptions
  • move users from SMS to stronger methods
  • introduce quarterly method and exception review
  • test emergency access procedure
  • prepare board report and improvement plan

What documents and evidence should be prepared?

Governance documents

  • MFA policy
  • scope of systems covered by MFA
  • MFA method matrix by risk group
  • exception procedure
  • emergency access procedure
  • account recovery procedure

Technical documents

  • MFA policy configuration
  • application list covered by MFA
  • privileged account list
  • emergency account list
  • legacy application list
  • legacy authentication protocol report
  • Conditional Access configuration, if applicable

Operational evidence

  • MFA enrollment report
  • MFA method report
  • MFA reset register
  • exception register
  • emergency account logs
  • pilot results
  • communication and training confirmations
  • board report

Common MFA rollout mistakes

Mistake 1: enabling MFA for everyone without a pilot

Without a pilot, the company may block users, applications, integrations and helpdesk. A pilot helps detect problems earlier.

Mistake 2: no backup methods

Users lose phones, change devices and travel. Without a backup method, lockouts and support tickets increase.

Mistake 3: weak recovery process

An attacker may try to bypass MFA through helpdesk. MFA reset must include strong identity verification and decision logging.

Mistake 4: administrators using weak methods

Administrators should have stronger methods than standard users. Security keys or passkeys are preferable for them.

Mistake 5: too many exceptions

Exceptions often start as temporary and become permanent. Every exception should have an owner, reason and expiration date.

Mistake 6: ignoring legacy applications

Legacy applications and protocols can weaken MFA deployment. They must be inventoried and a migration or compensating control plan should be prepared.

Mistake 7: poor employee communication

An employee who does not understand the change may click randomly, report issues or delay registration. Communication and instructions are part of security.

Mistake 8: treating SMS as the target solution

SMS may be a transitional method, but for high-risk accounts it should be replaced with stronger methods.

How to measure MFA effectiveness?

Deployment metrics

  • percentage of users with active MFA
  • percentage of administrators with phishing-resistant MFA
  • number of users without backup method
  • number of applications covered by MFA
  • number of legacy applications outside MFA

Security metrics

  • number of rejected high-risk sign-ins
  • number of MFA resets
  • number of MFA exceptions
  • number of emergency account uses
  • number of suspicious new method registrations

User metrics

  • number of helpdesk tickets related to MFA
  • time to resolve an MFA issue
  • number of user lockouts
  • number of users migrated from SMS to stronger methods
  • post-rollout survey results

Business example

A services company has 120 employees and uses Microsoft 365, CRM, VPN, a financial system and several SaaS applications. The board wants to “enable MFA as quickly as possible” because a customer requires evidence of email and remote access protection.

The IT team first performs a short review. It turns out that administrators do not have separate accounts, some users use personal phones, several applications use legacy authentication and helpdesk has no MFA reset procedure.

The company does not enable MFA for everyone on one day. It first protects administrators, prepares communication, runs a pilot, creates an account recovery procedure, defines emergency accounts and selects MFA methods.

After 90 days, MFA covers email, VPN, the financial system and most cloud applications. SMS remains only as a transitional method for selected users, administrators have stronger methods and the board receives a report on enrollment, exceptions and the next migration plan toward phishing-resistant methods.

How can ccyber.io help?

ccyber.io helps companies implement MFA without chaos, user lockouts and uncontrolled exceptions. We focus on a practical rollout plan, risk-based method selection, administrator protection, employee communication and evidence for customers and audits.

We can support your organization with:

  • MFA readiness assessment
  • application and privileged account inventory
  • MFA policy design
  • risk-based MFA method selection
  • MFA rollout plan for Microsoft 365 or Google Workspace
  • Conditional Access review
  • account recovery and emergency access procedure
  • employee communication and instructions
  • MFA deployment report for the board, customer or audit
  • roadmap toward phishing-resistant MFA

The best first step is a short MFA readiness assessment. It helps identify which accounts and applications are most important, which MFA methods are available, where problems may appear and how to deploy MFA in the first 30, 60 and 90 days.

FAQ

What is MFA?

MFA means multi-factor authentication. It means login requires more than a password, for example an authenticator app, security key, passkey or another additional factor.

Does MFA completely eliminate phishing?

Not all MFA eliminates phishing. SMS and one-time codes can be phished. The best protection comes from phishing-resistant methods such as FIDO2/WebAuthn security keys and passkeys.

Is SMS enough?

SMS is better than no MFA, but it should not be the target method for administrators, finance, board members and critical systems. It is better treated as transitional.

Where should MFA rollout start?

The best starting point is administrators, email, VPN, cloud systems and financial systems. Before broad deployment, prepare a pilot, communication, backup methods and account recovery.

Do all users need the same MFA method?

No. The method should depend on risk. Administrators and users with confidential data access should have stronger methods than standard users.

How can user lockouts be avoided?

Run a pilot, inform employees in advance, monitor registration, provide backup methods, prepare helpdesk and define a secure account recovery procedure.

Is MFA needed with SSO?

Yes. Single sign-on simplifies access to many applications, but it also means one compromised account may provide access to many systems. MFA should protect the primary identity system.

Does MFA help with NIS2, KSC and ISO 27001?

Yes. MFA is a practical access management control and reduces account takeover risk. It can support requirements related to access control, system protection and risk management.

Summary

MFA is one of the most important foundations of company cybersecurity. It protects accounts even when a password is stolen, but only when it is planned, deployed and monitored properly.

The most important approach is staged implementation: administrators and critical systems first, then email, VPN, cloud and the rest of the users. At the same time, communication, helpdesk, backup methods, account recovery, emergency accounts and exception register must be prepared.

Companies that want to avoid chaos should treat MFA as an identity management project, not a one-time settings change. Long term, high-risk accounts should move toward phishing-resistant methods.

Sources

Shadow AI: The Hidden Risk of AI Tools in Organizations

Shadow AI means the use of AI tools in an organization without the company’s knowledge, approval or control. It may include personal AI accounts, unapproved apps, plugins, transcription tools, coding assistants and AI agents. The biggest risks are data leakage, confidentiality breaches, lack of vendor control, wrong decisions, legal issues and missing compliance evidence.

Prepared by: CCyber Editorial Team

Short answer

Shadow AI occurs when employees use AI tools without the organization’s knowledge, approval or control. This usually happens when the company does not provide safe tools, clear rules and a simple approval process. Shadow AI may lead to leakage of customer data, source code, confidential documents, personal data, company secrets and information covered by contracts. The best response is not a ban alone, but visibility, an AI use policy, data classification, approved tools, training, monitoring and an AI incident response process.

Last updated

July 2026

Who this article is for

  • boards
  • business owners
  • CISOs and security leaders
  • IT directors
  • compliance and risk management teams
  • legal and data protection teams
  • HR and training teams
  • AI, data science and automation teams
  • software houses and SaaS companies
  • SMEs using AI tools
  • companies using Microsoft 365, Google Workspace, ChatGPT, Copilot, Gemini, Claude or similar tools

Key takeaways

  1. Shadow AI does not necessarily mean employees want to break rules. Most often, it means they are looking for a faster way to work and the company has not provided a safe alternative.
  2. The main risk of Shadow AI is not AI use itself, but lack of knowledge about what data goes into tools, who can access it and whether the vendor meets security requirements.
  3. The highest-risk data includes customer data, personal data, contracts, financial information, source code, secrets, API keys, strategy documents and data covered by NDAs.
  4. A ban alone usually does not work. Companies need approved tools, clear rules, training and an easy process for requesting new AI use cases.
  5. The best start is an inventory of AI use, an acceptable AI use policy, data classification, vendor assessment, access control and risk monitoring.

What is Shadow AI?

Shadow AI means using AI tools in an organization outside official company control. It may involve personal accounts, free tools, browser extensions, mobile applications, transcription tools, coding assistants, presentation generators, chatbots or AI agents without approval from IT, security, compliance or legal teams.

Shadow AI is similar to Shadow IT, but the risk can be higher. With Shadow IT, an employee may store files in an unapproved application. With Shadow AI, an employee may enter data into a system that analyzes, processes, summarizes, stores it in chat history, uses it in integrations or passes it further through plugins and external connections.

Examples of Shadow AI:

  • an employee pastes a customer contract into a public AI chatbot
  • a developer sends source code to an unapproved coding assistant
  • a manager uses a personal AI account to analyze employee data
  • sales uses an AI tool to analyze call recordings without vendor assessment
  • HR uses AI to screen CVs without risk and compliance review
  • an employee installs an AI browser extension with access to company documents
  • a team uses a meeting transcription tool without checking where recordings go
  • someone creates an AI agent with access to email, files or CRM without permission control

Why does Shadow AI appear in companies?

Shadow AI appears because AI tools genuinely help employees work faster. Employees do not always want to bypass rules. They often want to write an email faster, prepare an offer, summarize a meeting, translate a document, analyze data or generate code.

Common causes:

  • the company has no approved AI tools
  • the company has tools, but they are too limited or hard to use
  • there are no clear rules on what is allowed and what is prohibited
  • approval of new tools is too slow
  • employees do not know which data is confidential
  • managers expect faster work but do not provide safe tools
  • business teams buy SaaS tools with AI features without consulting IT
  • employees do not understand risks related to chat history, training data, plugins and integrations

In practice, Shadow AI is a signal to the board: people want to use AI, but the organization has not yet created a safe and convenient operating model.

What data most often goes into unapproved AI tools?

Customer data

Employees may paste customer requests, contracts, correspondence, call recordings, project data, requirements, complaints or implementation documents into AI.

Personal data

AI tools may receive data about employees, candidates, customers, patients, users or contractors. This may create personal data protection risk.

Source code and technical data

Developers may send code fragments, logs, errors, configurations, secrets, API keys, database queries or diagnostic data to AI.

Confidential and strategic information

AI is often used to summarize strategy, sales plans, board documents, financial information, product roadmaps or business secrets.

Contract-protected data

Customer data, technical documentation, contract terms, project information and materials covered by NDAs should not go into tools without checking the legal basis, contract and processing rules.

The most important Shadow AI risks

1. Confidential data leakage

The most obvious risk is entering information into an AI tool that the company should not share with an external provider. This may include a contract, customer data, code, strategy document, financial information or technical secrets.

The problem is that the company may not know that such a data transfer happened. If the tool is used through a personal account, outside company control, it is hard to determine data scope, activity history and accountability.

2. Personal data protection issues

If an employee enters personal data into an unapproved AI tool, the company may not know who the provider is, where data is processed, how long it is stored, whether it is used to improve the service and whether the right data processing agreement exists.

3. Exposure of code, secrets and technical information

In technical teams, Shadow AI may lead to leakage of source code, API keys, tokens, configuration files, logs, database schemas and system architecture information.

This risk is especially important for software houses, SaaS companies and digital product manufacturers because code and architecture are part of business value and product security.

4. Lack of vendor control

An AI tool may look like a simple application, but behind it there is a vendor, models, infrastructure, subcontractors, data storage, terms of use and security posture. Without vendor assessment, the company does not know whether the tool meets security, privacy and compliance requirements.

5. Wrong decisions based on AI output

AI may generate answers that are convincing but incorrect. If an employee uses output without verification, the company may make a wrong legal, financial, technical, HR, sales or operational decision.

6. Overreliance on AI

Shadow AI can lead to employees treating AI output as truth. This is dangerous when analyzing contracts, vulnerabilities, code, financial data, HR decisions, customer communications and risk assessments.

7. Risk of AI features embedded in SaaS tools

Shadow AI is not only public chatbots. More SaaS applications include AI features by default. A business team may enable such a feature without IT knowing, and the tool may analyze documents, conversations, support tickets, CRM data or customer history.

8. AI agent risk

An AI agent may take actions, not only return text. If it has access to email, files, CRM, project systems, code repositories or calendars, its permissions should be controlled like the permissions of a technical user.

An unsafe AI agent may perform unauthorized actions, send data, download files, change records or act based on manipulated instructions.

9. Missing audit evidence

The company may have a security policy, but if it does not know which AI tools are used, it has no control evidence. This makes audits, customer discussions, compliance and incident response more difficult.

Shadow AI and prompt injection

Prompt injection is a technique for manipulating a language model application through specially crafted instructions. It may occur when AI processes user content, documents, websites, emails, files or data from external systems.

In the Shadow AI context, the problem is larger because the company may not know:

  • that employees are using an application vulnerable to prompt injection
  • that the tool has access to company data
  • that the tool uses plugins or integrations
  • that AI may perform an action on behalf of the user
  • that there are no logs or monitoring for these actions

Unapproved AI tools should therefore be treated not only as a privacy risk, but also as a cybersecurity risk.

What not to do: banning AI only

The simplest response is banning AI use. In practice, a ban alone often fails. Employees will continue to use tools if they see real value and the company does not provide a safe alternative.

A better approach:

  • understand where and why people use AI
  • approve safe tools for the most common use cases
  • clearly define which data must not be entered into AI
  • create a simple approval path for new tools
  • train employees using examples from their work
  • monitor risks and respond to policy violations

A ban without an alternative creates hiding. Good governance creates visibility.

How to reduce Shadow AI step by step

Step 1: assign an AI Security owner

Shadow AI affects IT, security, legal, data protection, HR, procurement, finance and business teams. Without an owner, the topic will be fragmented.

The owner should coordinate:

  • AI use policy
  • tool inventory
  • vendor assessment
  • risk classification
  • training
  • monitoring and reporting
  • AI incident process

Evidence to prepare: AI Security owner decision, responsibility scope and supporting team list.

Step 2: inventory AI use

You cannot control what you cannot see. The first practical step is determining which AI tools employees use and for what tasks.

Include:

  • AI chatbots
  • transcription tools
  • coding assistants
  • presentation and image generators
  • AI tools in CRM, HR, sales and marketing
  • browser extensions
  • email and document plugins
  • AI in SaaS applications
  • AI agents and automation

Evidence to prepare: AI tool register, business owner, data type, purpose of use and approval status.

Step 3: classify use cases

Not every AI use has the same risk. Improving the style of an email is very different from analyzing customer data, source code, CVs, medical documentation or contracts.

Example classification:

  • low risk: language correction without confidential data
  • medium risk: marketing content creation without customer data
  • high risk: analysis of customer data, contracts, code, personal data or confidential documents
  • critical risk: AI with access to systems, decisions, sensitive data or automated actions

Evidence to prepare: AI use case register with risk rating.

Step 4: define data prohibited in AI tools

Employees need to know what must not be entered into unapproved AI tools.

The prohibited list should include:

  • passwords
  • API keys
  • tokens
  • customer and employee personal data
  • medical and financial data
  • contracts and confidential documents
  • business secrets
  • source code without approval
  • data covered by NDAs
  • non-public financial data
  • customer data without a legal and business basis

Evidence to prepare: data classification rules and prohibited data list for unapproved AI tools.

Step 5: approve safe AI tools

The company should create a list of AI tools allowed for work. Employees should know which tool they can use for which task.

The approved tool list should show:

  • tool name
  • allowed use cases
  • prohibited data
  • business owner
  • terms of use
  • whether data may be used to train models
  • whether an enterprise version is available
  • whether access uses a company account
  • whether logging and access control are enabled

Evidence to prepare: approved AI tool list and usage rules.

Step 6: assess AI vendors

An AI vendor should be assessed like any important technology provider. The company should know where data is processed, how long it is stored, who can access it and which contractual terms apply.

Check:

  • data processing location
  • prompt and output retention
  • use of data for training or service improvement
  • provider administrator access
  • subprocessors
  • contractual terms and DPA
  • security certifications or reports
  • incident handling
  • data deletion options
  • enterprise features such as SSO, MFA, logs and access control

Evidence to prepare: AI vendor assessment, approval decision and usage terms.

Step 7: manage access to AI tools

AI tools should be managed like other company systems. Access should be granted, reviewed and removed when an employee leaves.

Minimum baseline:

  • company account login
  • MFA
  • roles and permissions
  • user list
  • access granting and removal process
  • separate administrator permissions
  • usage logs
  • access review at least quarterly

Evidence to prepare: AI tool user list, roles, MFA configuration and latest access review.

Step 8: monitor data movement

The company should monitor whether confidential data is sent to unapproved AI tools. This is not about reading every employee conversation, but about visibility into data movement and responding to policy violations.

Possible controls:

  • data loss protection
  • cloud application monitoring
  • browser extension control
  • blocking high-risk tools
  • alerts for personal data, code, secrets and confidential documents
  • AI tool usage logs
  • exception and violation reviews

Evidence to prepare: AI monitoring report, violation list and corrective actions.

Step 9: introduce rules for AI agents

AI agents need separate rules because they can perform actions in systems. They should not have more permissions than necessary.

Control:

  • which systems the agent can read
  • which systems the agent can change
  • whether the agent can send messages
  • whether the agent can download files
  • whether high-risk actions require human approval
  • whether actions are logged
  • whether agent permissions are reviewed

Evidence to prepare: AI agent register, permission scope, action logs and human approval points.

Step 10: train employees with practical examples

Shadow AI training should be practical. Employees need examples from their work, not generic slides about artificial intelligence.

Training should cover:

  • what Shadow AI is
  • which data is prohibited
  • how to use approved tools
  • how to verify AI outputs
  • how to request a new AI tool
  • how to report an AI incident
  • how to recognize deepfake and AI-enabled fraud risk
  • how to use AI safely in everyday work

Evidence to prepare: training materials, attendee list, knowledge test and confirmation of policy acceptance.

Step 11: prepare an AI incident process

The company should know what to do if an employee pasted confidential data into an unapproved tool, an AI agent performed an unwanted action or an AI tool disclosed data.

The process should define:

  • where to report an AI incident
  • who assesses the data scope
  • who contacts the vendor
  • who assesses legal obligations
  • who decides on customer communication
  • how evidence is preserved
  • how access is removed or tool use is stopped
  • how recurrence is prevented

Evidence to prepare: AI incident procedure and AI incident or policy violation register.

Step 12: report risk to the board

Shadow AI should be visible to the board because it affects data, compliance, reputation, vendors and work efficiency. The report should not be technical. It should show risk and decisions.

The report may include:

  • number of approved AI tools
  • number of unapproved AI tools
  • most common AI use cases
  • number of policy violations
  • most common risky data types
  • training status
  • key decisions required
  • 90-day action plan

Evidence to prepare: quarterly AI Security board report.

30, 60 and 90-day Shadow AI reduction plan

First 30 days

  • assign an AI Security owner
  • run a quick AI use survey
  • identify the most commonly used AI tools
  • define data prohibited in unapproved tools
  • prepare a short AI use policy
  • approve the first list of safe tools
  • run short employee training

Days 31 to 60

  • assess vendors of key AI tools
  • enable company login and MFA for approved tools
  • define a process for requesting new AI tools
  • classify use cases by risk
  • check AI tools embedded in SaaS applications used by business teams
  • prepare an AI incident process
  • start basic policy violation monitoring

Days 61 to 90

  • implement an AI tool and use case register
  • prepare rules for AI agents and automation
  • introduce regular access reviews for AI tools
  • connect AI Security with data protection, procurement and vendor assessment
  • prepare a board report
  • run a Shadow AI incident exercise
  • plan the AI governance roadmap for the next 6 months

Shadow AI checklist for companies

Visibility

  • do we know which AI tools employees use?
  • do we know which tools are used through personal accounts?
  • do we know AI tools embedded in SaaS?
  • do we have an AI tool register?
  • do we know which departments use AI most often?

Data

  • do we have a list of data prohibited in AI?
  • do employees know what must not be pasted?
  • do we monitor personal data, code, secrets and confidential documents?
  • do AI tools have access to files, email or CRM?
  • do we have rules for meeting recordings and transcriptions?

Vendors and access

  • are AI vendors assessed?
  • do we have contracts and data processing terms?
  • do we use company accounts?
  • is MFA enabled?
  • do we remove access when employees leave?

People

  • do employees know approved tools?
  • do they have an easy process to request a new tool?
  • does training show practical examples?
  • do managers understand Shadow AI risk?
  • are policy violations discussed and corrected?

Incidents and audit

  • do we have an AI incident procedure?
  • do we have an incident and policy violation register?
  • can we determine what data went into an AI tool?
  • do we have control evidence for audits or customers?
  • do we report AI risk to the board?

What documents and evidence should be prepared?

Governance documents

  • AI use policy
  • approved AI tool list
  • prohibited data list
  • AI tool register
  • AI use case register
  • AI Security roles and responsibilities
  • new AI tool approval process

Technical documents

  • SSO and MFA configuration
  • AI tool user list
  • AI vendor assessment
  • AI tool usage logs
  • data monitoring rules
  • AI agent register
  • AI integration list with company systems

Organizational evidence

  • training confirmations
  • training materials
  • AI policy acceptance confirmation
  • AI tool approval decisions
  • policy violation register
  • board reports
  • AI incident notes

Common Shadow AI mistakes

Mistake 1: total ban without an alternative

If employees need AI for work, a ban alone usually moves use to personal accounts and unapproved tools. A better approach combines rules, approved tools and monitoring.

Mistake 2: no prohibited data list

Employees often do not know whether they can paste a contract, CV, customer data, code fragment or internal document into AI. Without a clear list, they will decide on their own.

Mistake 3: treating AI only as an IT topic

Shadow AI affects legal, data protection, HR, procurement, sales, customer support and the board. IT alone cannot solve the problem without business support.

Mistake 4: ignoring AI in SaaS tools

A company may block public chatbots while still using AI features in CRM, HR, marketing, customer support and document systems. These features also require assessment.

Mistake 5: no control over AI agents

An AI agent with system access should have limited permissions, logs, approval points and an owner. It should not operate like an invisible unmanaged user.

Mistake 6: no process for requesting new tools

If the approval process is unclear or too slow, employees will use tools without approval. The process should be simple, fast and understandable.

Mistake 7: no evidence

The company may have good intentions, but without a tool register, vendor assessments, training, logs and reports, it is difficult to show customers or auditors that AI is under control.

How to measure Shadow AI risk?

Visibility metrics

  • number of detected AI tools
  • number of approved AI tools
  • number of unapproved AI tools
  • number of departments using AI
  • number of AI use cases in the register

Data metrics

  • number of data policy violations
  • number of attempts to send confidential data to AI
  • number of incidents involving personal data
  • number of AI tools with access to files, email or CRM
  • number of AI policy exceptions

People metrics

  • percentage of trained employees
  • AI Security knowledge test score
  • number of new AI tool requests
  • time to approve a new AI tool
  • number of questions and consultations about AI

Governance metrics

  • number of assessed AI vendors
  • number of tools with SSO and MFA
  • number of AI incidents
  • AI incident response time
  • number of AI Security board reports

Business example

A services company has 180 employees. Employees use AI to write offers, translate emails, summarize meetings, analyze contracts and create marketing content. The board believes the company does not officially use AI because it has not bought any enterprise AI tool.

A short assessment shows that employees are using more than a dozen AI tools through personal accounts. Contract fragments, customer data, meeting notes, candidate CVs, code and proposal documents have been entered into these tools. There is no tool list, no vendor assessment, no AI policy and no training.

The problem is not that employees want to use AI. The problem is that the company has not provided them with a safe operating model.

Within 90 days, the company creates an approved tool list, prohibits confidential data in unapproved tools, assesses vendors, enables company login, trains employees and creates a process for requesting new AI tools.

After implementation, the company does not block innovation. Employees still use AI, but in a more controlled way, aligned with risk and explainable to customers and auditors.

How can ccyber.io help?

ccyber.io helps companies identify and reduce Shadow AI without blocking sensible use of artificial intelligence. We focus on visibility, data, vendors, employees, AI agents, processes and control evidence.

We can support your organization with:

  • Shadow AI assessment
  • AI tool inventory
  • AI acceptable use policy
  • approved and prohibited AI tool lists
  • data classification for AI
  • AI vendor assessment
  • rules for AI agents and automation
  • employee AI Security training
  • AI incident process
  • board report
  • 30, 60 and 90-day AI governance roadmap

The best first step is a short Shadow AI assessment. It helps determine which AI tools are already used, what data is at risk, which departments need support and which actions should come first.

FAQ

What is Shadow AI?

Shadow AI is the use of AI tools in an organization without the company’s knowledge, approval or control. It may include personal AI accounts, public chatbots, browser extensions, transcription tools, coding assistants and AI features in SaaS applications.

Is Shadow AI always bad?

Not every AI use is bad. The problem is lack of control over the tool, data, vendor, permissions and outputs. The goal should not be blocking AI, but managing AI use safely.

Which data is most risky?

The highest-risk data includes customer data, personal data, financial data, confidential documents, business secrets, non-public financial information, restricted source code, passwords, API keys and technical secrets.

Does banning AI solve the problem?

Usually not. A ban alone may move AI use to personal accounts and hidden tools. A better approach is approved tools, clear rules, training, monitoring and a simple approval process.

Is Shadow AI only about ChatGPT?

No. Shadow AI may include many tools: chatbots, content generators, meeting tools, coding assistants, AI features in SaaS, plugins, browser extensions and AI agents.

How can Shadow AI be detected?

The best approach combines surveys, business team interviews, SaaS application analysis, traffic monitoring to AI tools, procurement review, browser extension control and employee reporting.

How is Shadow AI different from AI governance?

Shadow AI is uncontrolled AI use. AI governance is a system of rules, roles, processes, risk assessments, approvals and monitoring that enables controlled AI use.

Where should Shadow AI reduction start?

The best starting point is an AI tool inventory, AI use policy, prohibited data list, approved safe tools, vendor assessment and employee training.

Summary

Shadow AI is one of the most important new organizational risks because AI entered daily work faster than policies, training and security controls.

The biggest problem is not artificial intelligence itself. The biggest problem is lack of visibility: the company does not know which tools employees use, what data goes into them, who has access and what vendor terms apply.

The best strategy combines security and usability: approved tools, clear rules, data classification, vendor assessment, access control, monitoring, training and board reporting. This allows the company to use AI faster, but without uncontrolled risk.

Sources

PLC, DCS and SCADA Security: A Simple Explanation for Boards

PLC, DCS and SCADA are systems that control production, industrial installations and critical processes. For boards, the key point is that a cyberattack on OT may mean not only data leakage, but downtime, operational losses, human safety risk, process failure and regulatory issues. We explain what management needs to know and where to start.

Prepared by: CCyber Editorial Team

Short answer

PLC, DCS and SCADA are core elements of OT environments, meaning operational technologies that control physical processes. A PLC controls a machine or part of a process. A DCS coordinates a larger industrial process distributed across multiple controllers. SCADA provides supervision, visualization and data collection from installations or sites. For boards, the key point is that a cyberattack on these systems may stop production, disrupt quality, damage equipment, create human safety risk and trigger regulatory obligations.

Last updated

July 2026

Who this article is for

  • boards
  • owners of industrial companies
  • production directors
  • technical directors
  • operations directors
  • IT directors
  • CISOs and security leaders
  • OT managers
  • automation and maintenance teams
  • manufacturing companies
  • energy, water, transport, healthcare and critical infrastructure organizations
  • organizations preparing for NIS2, KSC, IEC 62443 or customer audits

Key takeaways

  1. PLC, DCS and SCADA are not normal IT. They are systems that can directly affect machines, installations, production and human safety.
  2. The main board-level risk is not only data leakage, but downtime, loss of process control, loss of visibility, wrong operator decisions and business continuity impact.
  3. The biggest OT gaps are usually lack of inventory, uncontrolled remote access, weak IT-OT segmentation, legacy systems, lack of monitoring and no tested configuration backups.
  4. The board does not need to know industrial protocol details, but it should require clear answers to: what do we have, what is critical, who has access, how do we monitor it and how do we recover after an incident?
  5. The best start is a simple OT Security programme: asset inventory, connection mapping, remote access review, segmentation, configuration backups, monitoring and OT incident response plan.

What are PLC, DCS and SCADA?

PLC, DCS and SCADA are elements of the OT environment. OT means operational technology, systems used to monitor or control physical processes. In practice, these systems may affect production, energy, water, transport, buildings, industrial installations, equipment and human safety.

PLC: programmable logic controller

A PLC, or Programmable Logic Controller, controls a specific machine, line, pump, valve, motor, conveyor, robot or part of a process.

A PLC receives signals from sensors, executes programmed logic and sends commands to actuators.

Example:

  • a sensor shows that temperature is too high
  • the PLC executes its programmed logic
  • the PLC sends a command to a valve, pump or cooling system

For the board, a PLC means one thing: if someone changes controller logic or gains unauthorized access to it, they may affect a real physical process.

DCS: distributed control system

DCS, or Distributed Control System, is used in larger process installations where many controllers work together as part of one process.

DCS is common in energy, chemicals, refineries, pharmaceuticals, food production, paper industry and other continuous process environments.

For the board, DCS means control of an entire process, not only one machine. Disruption of a DCS may affect product quality, installation safety, production continuity and downtime cost.

SCADA: supervision and data acquisition

SCADA, or Supervisory Control and Data Acquisition, provides supervision, visualization and data collection. It allows operators to see process status, alarms, measurements and events. In some cases, it also allows control commands.

SCADA often connects many sites or devices, including geographically distributed ones.

Examples:

  • water utilities monitoring pumping stations and treatment facilities
  • energy companies monitoring substations and grids
  • transport organizations monitoring technical infrastructure
  • manufacturing plants monitoring lines, alarms and process parameters

For the board, SCADA means visibility and supervision over the process. If SCADA shows false data or operators lose visibility, operational decisions may be wrong.

PLC, DCS and SCADA: the simplest difference

  • PLC controls a specific machine or part of a process.
  • DCS controls a larger distributed industrial process.
  • SCADA provides supervision, visualization, alarms and process data.

In practice, these systems often work together. A PLC may control equipment, SCADA may show the operator the status of that equipment, and DCS may coordinate a larger process where many controllers work together.

Why should the board care?

PLC, DCS and SCADA security is not only an automation or IT topic. It is a board-level topic because it affects business continuity, downtime cost, human safety, regulatory accountability, reputation and customer relationships.

A cyberattack on OT may cause:

  • production stoppage
  • product quality reduction
  • equipment damage
  • loss of process visibility
  • operator disruption
  • false alarms or missing alarms
  • uncontrolled process parameter change
  • risk to people and environment
  • delivery delays to customers
  • emergency recovery costs
  • issues with auditors, regulators or insurers

In traditional IT, boards often ask about data, privacy and continuity of business systems. In OT, they must also ask about the physical process, safety, availability, configuration recovery and decisions to stop an installation.

What are the most important risks for PLC, DCS and SCADA?

1. Not knowing what actually runs in the plant

Many organizations do not have a full list of controllers, operator panels, SCADA servers, engineering workstations, software versions, IT connections and vendors with OT access.

This is a basic governance issue: the company cannot protect systems it cannot see.

2. Uncontrolled remote access

Automation vendors, integrators and maintenance teams often need remote access. The problem begins when access is permanent, shared, without MFA, without approval, without logs and without time limits.

From a board perspective, remote access to OT should be treated like access to critical systems.

3. Weak IT-OT segmentation

If office and industrial networks are connected without proper controls, an IT incident may move into OT. Ransomware, a compromised account or a compromised laptop may then affect production.

Segmentation is not only one firewall. It means controlling traffic between zones, clear communication rules and exception monitoring.

4. Legacy systems and difficult updates

OT systems often run for many years. Some devices cannot be updated easily because they are part of a process, have vendor restrictions or require a maintenance window.

The board should understand that lack of patching is not always negligence. Sometimes it requires compensating controls: segmentation, monitoring, access restriction and additional procedures.

5. No backups of configurations and controller programs

In OT, normal office file backup is not enough. The company needs copies of PLC programs, DCS configurations, SCADA projects, HMI configurations, recipes, parameters and technical documentation.

Without these copies, recovery after an incident may take much longer than the board expects.

6. No monitoring of OT changes

In IT, logins and files are often monitored. In OT, the company also needs to see controller logic changes, commands to devices, new devices in the network, unusual vendor sessions and communication between zones.

If nobody sees changes in PLC, DCS and SCADA, the company may discover the problem only when production stops or the operator sees an alarm.

7. No OT incident response plan

An IT incident response plan is not enough for OT. OT decisions must include production, automation, maintenance, safety, vendors and the board.

The key question is: who can decide to isolate a segment, stop the process or operate in emergency mode?

What should the board know about PLC?

A PLC is close to the physical process. It controls what actually happens to a machine, line or device. An attack on a PLC may mean changing control logic, stopping a process, incorrect parameters or loss of control over equipment.

Key PLC risks

  • unauthorized controller program change
  • no current backup of the program
  • uncontrolled service access
  • old or shared passwords
  • no change logging
  • lack of engineering workstation control
  • ability to upload unapproved logic

Board questions about PLC

  • do we have a list of PLCs?
  • do we know which PLCs are critical for production?
  • do we have current PLC program backups?
  • who can change controller logic?
  • are changes approved and documented?
  • do we detect unauthorized changes?

What should the board know about DCS?

A DCS controls a larger process, often continuous and critical. Failure or compromise of a DCS may affect many elements at once. In such environments, availability, stability, process safety and vendor cooperation are critical.

Key DCS risks

  • uncontrolled process parameter change
  • operator visibility loss
  • false alarms or missing alarms
  • operator or engineering workstation failure
  • vendor dependency
  • no safe recovery procedure
  • no testing of changes before implementation

Board questions about DCS

  • which processes are controlled by DCS?
  • what is the impact of DCS outage on production and safety?
  • do we have an emergency procedure for loss of visibility or control?
  • does the vendor have controlled access?
  • are DCS changes tested and approved?
  • do we have current configuration backups?

What should the board know about SCADA?

SCADA provides visibility, alarms, historical data and sometimes control. If SCADA stops working, the operator may lose situational awareness. If SCADA shows false data, the operator may make the wrong decision.

Key SCADA risks

  • loss of process visibility
  • false data on the operator screen
  • missing alarms or too many false alarms
  • operator or administrator account compromise
  • uncontrolled connections with IT
  • vulnerable servers and operator workstations
  • no SCADA project backups

Board questions about SCADA

  • is SCADA critical for plant operation?
  • do operators have an emergency mode if SCADA is lost?
  • are operator and administrator accounts protected?
  • do we have SCADA project and configuration backups?
  • do we monitor unusual SCADA actions?
  • does SCADA have controlled connections to IT, cloud or vendors?

Minimum PLC, DCS and SCADA security programme

Step 1: OT inventory

First, understand what exists in the environment. The inventory should include devices, systems, versions, locations, owners, vendors and connections.

Include:

  • PLC
  • DCS
  • SCADA
  • HMI
  • engineering workstations
  • operator workstations
  • historians
  • recipe systems
  • industrial networks
  • vendor remote access
  • IT-OT connections

Evidence to prepare: OT asset register with owner, location, criticality and vendor.

Step 2: IT-OT connection map

The board should know how OT connects to IT, vendors, cloud, ERP, MES, reporting systems and the internet. Many risks come from connections created over years and poorly documented.

Evidence to prepare: IT-OT connection diagram and data flow list.

Step 3: remote access control

Remote access to PLC, DCS and SCADA should be limited, approved, monitored and time-bound. A vendor should not have permanent uncontrolled access to critical systems.

Minimum controls:

  • MFA
  • no shared accounts
  • session approval
  • access only for the time needed
  • session logging
  • activity monitoring
  • access removal after work is complete

Evidence to prepare: register of vendors with OT access and latest remote access review.

Step 4: segmentation and zones

The OT environment should be divided into zones. Not every office computer should communicate with control systems. Not every OT system should communicate with every other OT system.

Practical actions:

  • separate IT from OT
  • create an intermediate zone between IT and OT
  • limit communication to required services
  • control access to engineering workstations
  • separate critical systems from less critical systems
  • document exceptions

Evidence to prepare: zone description, communication rules and exception list.

Step 5: configuration backups and recovery testing

In OT, backups must cover not only data, but also configurations and control logic. Without the current PLC program or SCADA project, recovery may be difficult, expensive and slow.

Check backups of:

  • PLC programs
  • DCS configurations
  • SCADA projects
  • HMI configurations
  • engineering workstations
  • recipes
  • process parameters
  • industrial network configuration

Evidence to prepare: configuration backup register and recovery test result.

Step 6: OT change management

An OT change can stop the process. Every change in PLC logic, DCS configuration, SCADA project, network rules or vendor access should be controlled.

The change process should include:

  • change description
  • reason for change
  • risk assessment
  • test
  • process owner approval
  • rollback plan
  • maintenance window
  • post-implementation confirmation

Evidence to prepare: OT change register and approvals for critical changes.

Step 7: OT monitoring

OT monitoring should cover not only Windows systems and servers, but also industrial traffic, logic changes, new devices, unusual vendor sessions and communication between zones.

Monitor:

  • new devices in the OT network
  • unauthorized IT-OT connections
  • PLC program changes
  • DCS configuration changes
  • SCADA project changes
  • unusual vendor logins
  • high-risk commands
  • OT network scanning attempts

Evidence to prepare: OT monitoring scope, alert list and escalation procedure.

Step 8: OT incident response plan

An OT incident response plan must include production, automation, maintenance, safety, IT, security, vendors and the board. A procedure written for an office IT incident is not enough.

The plan should answer:

  • who coordinates an OT incident?
  • who assesses risk to people and process?
  • who decides on shutdown or isolation?
  • who contacts the vendor?
  • how do we preserve evidence?
  • how do we restore configurations?
  • when do we notify the board, customers, CSIRT or regulator?

Evidence to prepare: OT incident response plan and tabletop exercise result.

10 questions the board should ask about PLC, DCS and SCADA

  1. Do we have an up-to-date list of PLC, DCS and SCADA systems?
  2. Which of them are critical for production, human safety and business continuity?
  3. Who has remote access to OT and how is that access controlled?
  4. Is OT separated from IT and do we know the exceptions?
  5. Do we have current backups of PLC programs, DCS configurations and SCADA projects?
  6. Have we tested recovery of OT systems?
  7. Do we monitor control logic and configuration changes?
  8. Do we have an OT incident response procedure?
  9. Do automation vendors have security requirements in contracts?
  10. Is OT included in enterprise risk, budget and business continuity planning?

What documents and evidence should be prepared?

Governance documents

  • OT Security policy
  • OT risk register
  • OT Security roadmap
  • IT, OT, production and safety responsibility split
  • board report
  • OT Security funding plan

Technical documents

  • OT asset register
  • OT network diagram
  • PLC, DCS, SCADA and HMI list
  • engineering workstation list
  • vendors with OT access list
  • zone and connection description
  • configuration backup list
  • OT change register

Operational evidence

  • remote access review report
  • configuration recovery test result
  • vendor access logs
  • OT monitoring report
  • approvals for critical system changes
  • OT incident exercise note
  • segmentation review report

OT, NIS2 and KSC: what should the board know?

If the organization is an essential or important entity, or operates in a regulated sector, OT may be part of cybersecurity obligations. This is especially relevant for sectors such as energy, transport, water, wastewater, healthcare, manufacturing, chemicals, food and digital infrastructure.

The board should treat PLC, DCS and SCADA as part of cyber risk if these systems are important for service delivery, production or business continuity.

In practice, this means preparing:

  • OT risk assessment
  • technical, operational and organizational measures
  • incident response procedure
  • access management evidence
  • segmentation and monitoring evidence
  • supplier cooperation process
  • board reports
  • audit or security assessment plan, if applicable

30, 60 and 90-day action plan

First 30 days

  • assign an OT Security owner
  • identify critical physical processes
  • collect an initial list of PLC, DCS and SCADA systems
  • review vendor remote access
  • check IT-OT connections
  • check whether configuration backups exist
  • prepare the first risk list for the board

Days 31 to 60

  • prepare an OT network diagram
  • prepare a list of critical systems
  • define zones and key connections
  • define remote access rules
  • check privileged OT accounts
  • prepare the configuration backup process
  • define the minimum OT monitoring scope

Days 61 to 90

  • implement remote access control for key vendors
  • test recovery of selected configurations
  • start monitoring a selected OT segment
  • prepare an OT incident response plan
  • run a tabletop exercise for ransomware in production
  • prepare a segmentation and investment roadmap
  • prepare a board report with priorities and budget

How to measure PLC, DCS and SCADA security?

Visibility metrics

  • percentage of inventoried OT assets
  • number of systems without owner
  • number of undocumented IT-OT connections
  • number of vendors with OT access

Access metrics

  • percentage of remote access paths with MFA
  • number of shared accounts
  • number of permanent vendor accesses
  • number of vendor sessions without logging

Resilience metrics

  • percentage of critical configurations with backup
  • number of configuration recovery tests
  • time to recover a critical OT system
  • number of systems with an emergency plan

Monitoring metrics

  • number of monitored OT segments
  • number of unauthorized changes detected
  • number of remote access alerts
  • time to escalate an OT incident

Common board-level OT Security mistakes

Mistake 1: treating PLC, DCS and SCADA like normal IT

OT systems have different priorities than IT. Not every update, scan or restart can be performed like in the office. Process, safety, availability and production must be considered.

Mistake 2: no owner for OT risk

If OT sits “between IT and production”, nobody makes decisions. The board should clearly define responsibility for OT security.

Mistake 3: ignoring vendors

Automation vendors and integrators often have broad access. Without control, vendors may become one of the most important risk paths.

Mistake 4: no configuration backups

Companies often have office data backups, but not current backups of PLC programs, SCADA projects and DCS configurations.

Mistake 5: no exercises

An OT incident response plan that has not been exercised usually does not work well in crisis. A tabletop exercise helps test roles, decisions and communication.

Mistake 6: no budget for fundamentals

Advanced tools do not replace fundamentals. The first investments should cover inventory, segmentation, access control, configuration backups, monitoring and procedures.

Business example

A manufacturing company has several lines, a SCADA system, dozens of PLCs, an automation vendor with remote access and an older DCS in its most important process. The board believes cybersecurity is under control because the company has a firewall, antivirus and office data backups.

An initial review shows that the controller list is not current, the vendor has permanent VPN access, PLC program copies are stored locally on an engineering workstation and nobody has tested SCADA recovery. The OT network has several IT connections that are not on the diagram.

The problem is not the lack of one tool. The problem is lack of visibility, access control and recovery planning.

The company starts with fundamentals. It creates an OT register, maps IT-OT connections, restricts vendor remote access, backs up PLC and SCADA configurations, tests recovery of one critical process and prepares an incident exercise for a ransomware scenario.

After 90 days, the board receives the first real report: which systems are critical, where the biggest risks are, which actions have been completed and what budget is needed for further segmentation and monitoring.

How can ccyber.io help?

ccyber.io helps boards and technical teams understand and organize PLC, DCS, SCADA and OT security in a practical, business-focused and risk-based way.

We can support your organization with:

  • initial OT Security assessment
  • PLC, DCS, SCADA and HMI inventory
  • vendor remote access review
  • IT-OT connection mapping
  • OT segmentation review
  • board-level OT risk assessment
  • IEC 62443 gap analysis
  • configuration backup and recovery plan
  • OT incident response plan
  • tabletop exercise for ransomware or loss of process control
  • 30, 60 and 90-day OT Security roadmap

The best first step is a short OT Security board workshop. It helps quickly determine what is critical, where visibility is missing, which vendors have access and what decisions the board should make.

FAQ

What is a PLC?

A PLC is a programmable logic controller that controls a machine, device or part of a process. It receives signals from sensors, executes logic and sends commands to actuators.

What is a DCS?

A DCS is a distributed control system used in larger industrial processes. It coordinates many process elements and is often critical for production continuity and installation safety.

What is SCADA?

SCADA is a supervision and data acquisition system. It provides operators with process visibility, alarms, measurements and often the ability to control selected elements.

Are PLC, DCS and SCADA IT?

Not in the traditional sense. They are elements of OT, or operational technology. They affect the physical process, so they require a different approach than normal office systems.

What is the biggest board-level risk?

The biggest risk is downtime, loss of process control, loss of visibility, human safety risk, equipment damage, quality issues, delivery delays and regulatory obligations.

Where should OT security start?

The best starting point is asset inventory, IT-OT connection mapping, remote access review, configuration backups, segmentation, monitoring and an OT incident response plan.

Does the board need to know PLC and SCADA technical details?

No. The board should understand business impact and ask the right questions: what do we have, what is critical, who has access, how do we monitor changes and how do we recover?

Do NIS2 and KSC apply to OT?

They may apply if OT systems support the activity of an essential or important entity, critical services, production, infrastructure or a regulated sector. In that case, OT should be included in risk assessment, security measures, incidents and audits.

Summary

PLC, DCS and SCADA are not hidden technical details inside a plant. They are systems that may determine production, human safety, product quality, service availability and business continuity.

For the board, the most important approach is simple: first know what the company has, which systems are critical, who has access, how the environment is separated, whether configuration backups exist and whether the company can respond to an incident.

Good OT Security does not start with buying a tool. It starts with visibility, responsibility, access control, segmentation, configuration backups, monitoring and the board’s decision that OT security is part of business risk.

Sources

  • NIST SP 800-82 Rev. 3: Guide to Operational Technology (OT) Security - the main methodological source for this article. It supports the definition of OT, differences between IT and OT, the importance of PLC, DCS and SCADA, and requirements related to OT security, reliability and availability.
  • ISA/IEC 62443 Series of Standards - a source for industrial automation and control systems security, stakeholder roles, risk-based approach, lifecycle, segmentation, zones and cooperation between OT, IT and process safety.
  • MITRE ATT&CK for ICS Matrix - a technical source for tactics and techniques against industrial control systems, including loss of view, loss of control, manipulation of control, loss of availability and safety impact.
  • ENISA Threat Landscape 2025 - a source for the current EU threat context, incident scale, trends and the need to build organizational resilience.
  • European Commission: NIS2 Directive - a regulatory source for essential sectors, cybersecurity risk management, incident reporting and management accountability.
  • Gov.pl: Amendment to the Polish National Cybersecurity System Act - a Polish regulatory source on KSC, essential and important entities, expanded sectors, technical, operational and organizational obligations, management accountability and audits.

Digital Europe Programme for Cybersecurity: A Guide for Companies

The Digital Europe Programme can fund projects related to cybersecurity, deployment of innovative solutions, AI in cybersecurity, SME cyber resilience, preparedness testing, post-quantum technologies, NIS2, CRA and critical infrastructure protection. Learn how a company should prepare its project, partners, budget and documents before submitting an application.

Prepared by: CCyber Editorial Team

Short answer

The Digital Europe Programme is an EU funding programme supporting the deployment of digital technologies in the economy, public administration and society. In cybersecurity, it can be particularly relevant for companies that develop or deploy cyber solutions, support SMEs, build AI-based cybersecurity tools, prepare projects for NIS2, CRA, cyber resilience, post-quantum technologies, preparedness testing or critical infrastructure protection. A company should start from the project, not the form: objective, scope, partners, budget, outcomes and alignment with a specific call.

Last updated

July 2026

Who this article is for

  • cybersecurity companies
  • software houses and SaaS companies
  • SMEs looking for cybersecurity funding
  • providers of solutions for NIS2, CRA, DORA and critical infrastructure
  • companies building AI tools for cybersecurity
  • companies developing digital product security solutions
  • industrial and OT companies
  • hospitals, healthcare, water utilities, transport and energy organizations
  • public institutions and regulated entities
  • boards, CTOs, CISOs, business development teams and people responsible for project funding

Key takeaways

  1. The Digital Europe Programme is not a simple grant for buying any tool. It funds projects aligned with specific programme objectives, calls and outcomes.
  2. In cybersecurity, the most important directions include innovative solution deployment, AI, SME cyber resilience, preparedness testing, post-quantum technologies, Cyber Solidarity Act, NIS2, CRA and critical infrastructure.
  3. A company should first prepare a strong project: problem, objective, scope, partners, budget, timeline, outcomes and evidence of implementation capacity.
  4. Proposals are assessed, among other things, on alignment with the call, project maturity, implementation quality, team capacity and project impact.
  5. Calls and deadlines change, so current documents should always be checked on the Funding & Tenders Portal, ECCC, NCC-PL and CPPC websites.

What is the Digital Europe Programme?

The Digital Europe Programme is a European Union funding programme focused on deploying and expanding key digital capacities. It is not a typical research programme. Its main role is to support practical deployment of digital technologies, infrastructure, skills and solutions.

The programme covers, among other areas:

  • high-performance computing
  • artificial intelligence
  • cybersecurity and trust
  • advanced digital skills
  • deployment and best use of digital capacities and interoperability

For companies, the most important point is that the Digital Europe Programme funds deployment, scaling and uptake of technologies. In cybersecurity, this means projects that strengthen cyber resilience, the market, skills, infrastructure and response capabilities in the EU.

What is Digital Europe - Cybersecurity?

The cybersecurity area in the Digital Europe Programme is implemented as Specific Objective 3: Cybersecurity and Trust. For 2025-2027, the cybersecurity work programme is handled by the European Cybersecurity Competence Centre, or ECCC, in cooperation with the network of National Coordination Centres, including NCC-PL in Poland.

The Digital Europe Cybersecurity Work Programme 2025-2027 covers, among other areas:

  • new technologies and AI in cybersecurity
  • cybersecurity solutions supporting SMEs
  • post-quantum technologies and migration to post-quantum cryptography
  • Cyber Hubs and cooperation mechanisms in the EU
  • preparedness testing and resilience exercises
  • supporting compliance with regulations such as NIS2 and CRA
  • cybersecurity of hospitals and healthcare
  • actions supporting critical infrastructure
  • projects strengthening the European cybersecurity market

For a company, this means a funding opportunity, but only if the project matches a specific call. It is not enough to write “we want to improve cybersecurity”. The proposal must show what problem the company solves, what outcome it will deliver and why the project matters for the market, users, SMEs, regulated sectors or EU resilience.

Which companies may find the Digital Europe Programme relevant?

Cybersecurity companies

Providers of cybersecurity services, tools and technologies can look for calls related to deployment of innovative solutions, AI in cybersecurity, preparedness testing, SME support, NIS2, CRA, critical infrastructure protection and skills.

SaaS companies and software houses

Companies developing digital products can look for funding related to CRA, product security, Secure SDLC, vulnerability management, SBOM, security testing, secure updates and customer cyber resilience.

SMEs

SMEs can be project beneficiaries, participants in support programmes, recipients of cascade funding or users of deployed cybersecurity solutions. In many calls, SMEs are an important target group, even if they do not always apply directly as coordinators of large projects.

Companies building AI solutions for cybersecurity

The programme supports directions related to AI in cybersecurity, such as threat detection, incident response, threat intelligence, automation of security processes and protection of AI systems themselves.

Industrial companies and critical infrastructure

Entities in OT, manufacturing, energy, transport, water, healthcare or other regulated sectors can participate in projects related to preparedness testing, resilience, monitoring, NIS2, Cyber Hubs or critical infrastructure protection.

Technology companies and consortia

Many projects in the Digital Europe Programme require cooperation between different entities. Companies can participate in consortia with universities, research institutes, public administration, technology providers, end users and industry organizations.

Which cybersecurity projects may fit the Digital Europe Programme?

AI in cybersecurity

Projects may involve tools and services using AI for threat detection, incident analysis, response automation, threat intelligence processing, AI system security and compliance with EU regulations.

Example topics:

  • AI for anomaly detection
  • AI for incident analysis
  • AI for SOC automation
  • security of AI systems
  • protection against malicious use of AI
  • tools supporting compliance with the AI Act, GDPR and cybersecurity requirements

SME cyber resilience

The programme may support projects that make cybersecurity tools, services and skills more accessible to small and medium-sized companies. For technology companies, this may mean creating or deploying solutions for SMEs.

Example projects:

  • cybersecurity packages for SMEs
  • cyber resilience self-assessment tools
  • MFA, backup, EDR, monitoring or baseline control deployment
  • platforms for vulnerability and incident handling
  • solutions helping SMEs meet CRA or NIS2 requirements

Cyber Resilience Act and digital product security

Companies developing software, IoT, hardware or products with digital elements may look for calls related to CRA preparation, standards, testing, technical documentation, vulnerability management, SBOM and lifecycle product security.

NIS2 and regulated sector resilience

Projects may support NIS2-covered organizations or their suppliers: risk assessment, preparedness testing, incident response, information sharing, exercises, monitoring and cross-sector cooperation.

Preparedness testing and resilience exercises

The programme may support preparedness testing, simulations, exercises, crisis scenarios and preparing organizations for cyberattacks.

Post-quantum technologies

A separate direction concerns migration to post-quantum cryptography, testing solutions, validation, infrastructure and system migration.

Critical infrastructure protection

The programme also covers projects related to critical infrastructure protection, Cyber Hubs, submarine cables, cyber solidarity mechanisms and cross-border cooperation.

How should project preparation start?

Step 1: do not start from the form

The most common mistake is starting with the application form itself. First, the company needs a project that makes business, technical and programme sense.

At the beginning, answer:

  • what cybersecurity problem are we solving?
  • who are we solving it for?
  • why does this problem fit the Digital Europe Programme?
  • what outcome will be created?
  • will the outcome be deployed or only described?
  • who will use the project results?
  • how will the project strengthen cyber resilience, the market or skills?

Evidence to prepare: short project card with problem, objective, target users and expected outcomes.

Step 2: match the project to a specific call

The Digital Europe Programme has different calls, and each has its own scope, conditions, budget, action type, evaluation criteria, eligibility and deadlines. A project that fits one call may not fit another.

Check in call documents:

  • call objective
  • expected activities
  • expected outcomes
  • action type
  • eligible entities
  • consortium requirements
  • budget
  • funding rate
  • submission deadline
  • security requirements and participation restrictions

Evidence to prepare: table mapping the project to call requirements.

Step 3: decide whether to apply alone or in a consortium

In many European projects, a consortium increases credibility and impact. It is not always formally required, but often helps show that the project has real users, technology partners and implementation capacity.

Typical partners:

  • cybersecurity technology providers
  • SMEs as solution users
  • public institutions
  • universities and research institutes
  • industry organizations
  • critical infrastructure operators
  • hospitals and healthcare providers
  • CSIRT, competence centres or cybersecurity hubs where the topic requires them

Evidence to prepare: list of partners, their roles, contributions and justification for why they are needed.

Step 4: prepare the project value proposition

A good project must clearly show why it should receive funding. In the Digital Europe Programme, the private interest of one company is not enough. The project should show broader impact: for the market, SMEs, a sector, users, EU resilience or regulatory implementation.

Show:

  • solution scalability
  • impact on SMEs
  • impact on a regulated sector
  • alignment with NIS2, CRA, Cyber Solidarity Act or other EU priorities
  • practical deployment, not only concept
  • European added value
  • use of results after project completion

Evidence to prepare: impact justification and measurable outcome description.

Step 5: prepare the budget

The budget must follow the activities, not the amount the company would like to receive. Each task should have a cost, justification and responsible partner.

The budget may include, depending on the call:

  • personnel
  • subcontracting
  • purchase of tools and services
  • pilots
  • testing
  • integrations
  • training
  • communication and dissemination
  • project management
  • financial support to third parties, if the action type allows it

Evidence to prepare: budget by tasks, partners, costs and outcomes.

Step 6: prepare timeline and work packages

The proposal should show that the project is feasible. The timeline cannot be a list of generic statements. It should include tasks, milestones, deliverables and dependencies between partners.

Example work packages:

  • project management
  • requirements and regulatory analysis
  • technical design
  • solution development or deployment
  • pilot
  • security testing
  • integration with user organizations
  • training and materials
  • dissemination of results
  • impact monitoring

Evidence to prepare: work plan with milestones, deliverables and responsibilities.

Step 7: prepare evidence of capacity to deliver

Evaluators must believe that the team can deliver the project. The company should show skills, experience, partner roles, resources and implementation readiness.

Prepare:

  • team description
  • cybersecurity experience
  • project references
  • technology description
  • pilot user description
  • product or service readiness status
  • project risks and mitigation plan
  • plan for maintaining results after funding ends

Evidence to prepare: team profile, experience, references and project risk management plan.

How are proposals evaluated?

General evaluation criteria in the Digital Europe Programme include three areas: relevance, implementation and impact. Specific criteria may vary by call, so call documents should always be checked.

1. Relevance

The project must fit the call objective. Evaluators check whether the project responds to the described needs, supports EU policies and strategies, strengthens the digital technology supply chain or helps overcome financial barriers where relevant.

2. Implementation

The project must be realistic. Project maturity, quality of the plan, efficient use of resources and the ability of applicants or consortium to deliver are important.

3. Impact

The project must matter. Evaluators consider whether it will achieve expected outcomes, strengthen competitiveness, bring societal benefits, disseminate results and remain useful after funding ends.

Funding rates: what must be checked?

The funding rate depends on the action type and the specific call. A single funding rate should not be assumed for the whole programme.

The work programme includes, among others:

  • simple grants, often with 50% funding of eligible costs
  • SME support actions, where SMEs may have a higher funding rate
  • coordination and support actions, which may have a different funding rate
  • actions with financial support to third parties
  • procurement, which is a different mode than grants

The most important point: funding rate, own contribution, eligible costs, subcontracting limits and reporting rules must always be checked in the documents of the specific call.

Which documents should a company prepare before a call?

Strategic documents

  • project card
  • business justification
  • programme alignment justification
  • market and user needs analysis
  • European added value description
  • plan for sustainability of results

Technical documents

  • solution description
  • architecture
  • technology or product readiness level
  • pilot plan
  • testing plan
  • security and data protection plan
  • integration description
  • regulatory alignment description, if applicable

Project documents

  • work packages
  • timeline
  • milestones
  • deliverables
  • budget
  • partner role split
  • risk management plan
  • communication and dissemination plan

Organizational documents

  • company data
  • SME status, if applicable
  • financial statements or financial data, if required
  • experience description
  • profiles of key people
  • letters of intent from partners or pilot users
  • information on operational and financial capacity

Which projects should be prepared first?

Project for SMEs

A strong direction may be a project that helps many SMEs deploy specific cybersecurity controls or meet NIS2, CRA or B2B customer requirements.

Product project for CRA

Companies developing software, IoT or products with digital elements can prepare projects on product security: SBOM, vulnerabilities, updates, testing, documentation and Secure SDLC.

AI project for cybersecurity

If the company has a real AI technology supporting threat detection, analysis or response, it can prepare a deployment project with partners and pilot users.

Incident preparedness project

Regulated organizations can prepare projects involving exercises, preparedness testing, crisis communication, response plans and sector cooperation.

OT or critical infrastructure project

Industrial companies and cybersecurity providers can prepare projects on segmentation, monitoring, remote access, resilience testing and protection of physical processes.

What should be avoided in the Digital Europe Programme?

Mistake 1: treating the programme as simple reimbursement for a purchase

The Digital Europe Programme funds projects aligned with programme objectives and specific calls. A tool purchase without a broader project, outcome and impact will usually be weak.

Mistake 2: project not aligned with the call

Even a good project can lose if it does not address the call topic. Alignment with objective, scope and expected outcomes is critical.

Mistake 3: description too generic

Statements such as “we will increase cybersecurity” are too weak. The proposal must show what exactly will be created, for whom, how it will work and how impact will be measured.

Mistake 4: no partners or pilot users

In many topics, technology alone is not enough. Users, deployment organizations, sector partners or recipients are needed to show real demand.

Mistake 5: budget without justification

Costs must follow tasks and outcomes. The budget cannot look like a wish list.

Mistake 6: starting too late

Preparing a strong project, partners and documents takes time. Waiting until the last week of the call usually results in a weak proposal.

Mistake 7: no post-funding plan

Evaluators want to know what will happen to the results after the project. The project should include a plan for maintaining, scaling or using the outcomes.

30, 60 and 90-day action plan

First 30 days

  • assign a person responsible for cybersecurity funding
  • check current calls on the Funding & Tenders Portal
  • review the Digital Europe Cybersecurity Work Programme 2025-2027
  • select 2 or 3 topics where the company may realistically fit
  • prepare short project cards
  • check whether the company has SME status or other relevant qualifications
  • contact potential partners
  • check NCC-PL and National Contact Point support

Days 31 to 60

  • choose one priority project
  • match it to a specific call
  • prepare the problem and solution description
  • define outcomes and success metrics
  • define partners and roles
  • prepare the initial budget
  • prepare timeline and work packages
  • collect organizational and technical documents

Days 61 to 90

  • prepare the full project description
  • prepare the implementation and impact plan
  • refine budget and own contribution
  • check cost eligibility
  • obtain partner confirmations
  • prepare attachments
  • review the evaluation criteria checklist
  • plan submission earlier than the final day

Digital Europe readiness checklist for companies

Strategic alignment

  • does the project fit a specific call?
  • does the project address a real cybersecurity problem?
  • does the project matter for the market, SMEs, regulated sectors or EU resilience?
  • does the project support NIS2, CRA, AI, cyber resilience or another programme priority?

Project maturity

  • do we have a solution description?
  • do we have an implementation plan?
  • do we have partners?
  • do we have pilot users?
  • do we know the outcomes?
  • do we have success metrics?

Budget and implementation

  • are costs linked to tasks?
  • do we know the required own contribution?
  • have we checked the funding rate?
  • do we know eligible costs?
  • do partners have delivery capacity?

Proposal and formalities

  • do we have access to the Funding & Tenders Portal?
  • do we know the call deadline?
  • do we know the call documents?
  • do we have attachments?
  • do we have a plan to submit before the deadline?

Business example

A cybersecurity company is developing a tool that helps SMEs assess CRA readiness and manage vulnerabilities in digital products. The team wants to find funding from the Digital Europe Programme.

Instead of starting from the form, the company prepares a project: an SME platform, pilot with several dozen companies, SBOM process integration, vulnerability reporting module, training materials and readiness reports for digital products.

Then the company looks for partners: an SME organization, software houses, a research entity and an industry organization. The project is matched to a call on uptake of innovative cybersecurity solutions for SMEs.

The project’s main advantage is not the technology alone. It is alignment with the programme objective: SMEs, CRA, deployment, cyber resilience, measurable outcomes and scalability after funding ends.

How can ccyber.io help?

ccyber.io helps companies prepare cybersecurity projects for the Digital Europe Programme in a practical, business-focused way aligned with the logic of EU calls. We do not start from the form. We start from the problem, project value, call fit and delivery capacity.

We can support your organization with:

  • project fit analysis for the Digital Europe Programme
  • selection of the right funding direction
  • project card preparation
  • cybersecurity project scope design
  • budget and timeline preparation
  • outcome and impact metric description
  • project preparation for NIS2, CRA, AI Security, OT Security or SME cyber resilience
  • technical materials for the proposal
  • organization readiness review
  • project workshop for the board, technology and business development teams

The best first step is a short grant-readiness workshop. It helps determine whether the company has a project that realistically fits the Digital Europe Programme, which documents must be prepared and whether partners should be sought for a consortium.

FAQ

Does the Digital Europe Programme fund cybersecurity?

Yes. Cybersecurity and trust is one of the areas of the Digital Europe Programme. For 2025-2027, the cybersecurity work programme includes AI, post-quantum technologies, SME cyber resilience, preparedness testing, Cyber Hubs, NIS2, CRA and critical infrastructure.

Can a company get funding for its own cybersecurity tool?

It can, if the project fits a specific call and shows broader impact than developing one company’s product. Deployment, users, partners, market impact, SMEs, regulated sectors or EU resilience are important.

Is the Digital Europe Programme only for large companies?

No. The programme also supports SMEs, and many actions directly or indirectly concern small and medium-sized enterprises. In some action types, SMEs may have more favorable funding conditions.

Is a consortium required?

It depends on the call. Some topics may require a consortium, others may not. Even when a consortium is not mandatory, partners often strengthen the project, especially if they show real deployment and impact.

Where should current calls be checked?

Current calls should be checked primarily on the Funding & Tenders Portal. In Poland, NCC-PL and the National Contact Point for Digital Europe at CPPC are also worth monitoring.

Does the Digital Europe Programme fund research?

The Digital Europe Programme is more focused on deployment and uptake of digital capacities than classic research. Research and innovation projects more often fit Horizon Europe. In practice, the two programmes can complement each other.

What are the typical evaluation criteria?

General criteria include relevance, implementation and impact. In practice, this means call fit, project maturity, plan quality, team capacity, expected outcomes and broader project impact.

Where should proposal preparation start?

The best starting point is a project card: problem, objective, target users, solution, partners, outcomes, budget and alignment with a specific call. The application form should be the final stage, not the beginning of project thinking.

Summary

The Digital Europe Programme can be an important funding source for companies active in cybersecurity, but it requires strong preparation. It is not a programme for random tool purchases. It is a programme for projects that strengthen Europe’s digital capacities, cyber resilience, market, skills and technology deployment.

For cybersecurity companies, SaaS companies, software houses, AI providers, product companies and regulated entities, the strongest projects are well aligned with the call, measurable, deployment-oriented and based on real market or sector needs.

The best approach is simple: prepare the project early, find the right call, build partnerships, show impact, prepare the budget and submit before the deadline. In European funding, the winner is not the company that starts writing latest, but the one with a mature, justified and ready project.

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.