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

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

Prepared by: CCyber Editorial Team

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

Short answer

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

Last updated

July 2026

Who this article is for

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

Key takeaways

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

What does cybersecurity market growth show?

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

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

The market grows because companies need:

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

Why is cyber no longer only an IT cost?

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

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

Cyber affects:

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

Three main drivers of market growth

1. Increasing threat scale

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

2. Regulatory pressure

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

3. Cloud, SaaS and digitalisation

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

How is the market structure changing?

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

In practice, demand is growing for:

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

What does market growth mean for customers?

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

The customer should buy cyber based on risk, not trend

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

Questions before purchase

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

What does market growth mean for IT and cyber providers?

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

Providers must prepare:

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

What will distinguish a good provider?

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

Most promising market segments

1. NIS2 and national cybersecurity readiness

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

2. Managed services, MSS, MDR and SOC

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

3. Backup and recovery

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

4. Identity and access

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

5. Cloud and SaaS security

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

6. OT security

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

7. Training and cyber awareness

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

AI in cybersecurity: opportunity and risk

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

AI can support security through:

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

AI can increase risk through:

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

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

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

Funding may drive:

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

Most important funding rule

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

How should the board plan a cyber budget?

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

The budget should be split into:

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

CFO questions for the cyber budget

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

How not to waste the cyber budget?

1. Start with risk

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

2. Build the basics

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

3. Plan maintenance

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

4. Test

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

5. Measure outcomes

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

How to assess a cybersecurity provider?

1. Sector competence

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

2. Evidence of the provider’s own security

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

3. Delivery capability

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

4. Board reporting

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

5. Exit plan

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

Action plan for a company buying cybersecurity

First 30 days

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

Days 31 to 60

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

Days 61 to 90

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

Action plan for an IT and cyber provider

First 30 days

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

Days 31 to 60

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

Days 61 to 90

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

Metrics for the customer’s board

Risk metrics

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

Protection metrics

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

Supplier metrics

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

Compliance metrics

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

Metrics for a cyber provider

Sales metrics

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

Delivery metrics

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

Service quality metrics

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

Common customer mistakes

Mistake 1: buying under headline pressure

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

Mistake 2: no owner inside the organization

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

Mistake 3: tools without maintenance

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

Mistake 4: no restore test

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

Mistake 5: missing evidence

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

Mistake 6: no next-year budget

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

Common provider mistakes

Mistake 1: selling the tool instead of the outcome

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

Mistake 2: weak regulatory understanding

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

Mistake 3: underestimating delivery

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

Mistake 4: weak own security

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

Mistake 5: no recurring services

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

Business example

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

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

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

Related CCyber resources and services

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

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

How can ccyber.io help?

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

We can support your organization with:

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

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

FAQ

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

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

What drives the cyber market in Poland most?

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

Is SOC as a Service worth buying?

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

Are tools enough to meet NIS2?

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

How to assess whether a cyber provider is good?

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

Will AI reduce or increase cyber spending?

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

Can public funding reduce cyber costs?

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

Where should cyber budget planning start?

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

Summary

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

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

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

Sources

75% Funding for SME Cyber Resilience: How to Prepare a Digital Europe Project?

Funding of up to 75% of cybersecurity project costs for SMEs is a major opportunity, but only for organizations that can clearly describe the problem, beneficiary, outcome, budget, risks and delivery evidence. Programmes such as Digital Europe do not fund random tool purchases. They fund projects that help SMEs increase cyber resilience, implement CRA and NIS2, use cyber toolkit as a service, develop response services, training, hotlines, risk assessment automation, SaaS integrations and AI-based cybersecurity tools. The key conclusion: the project should start with real risk and measurable impact, not a licence list.

Prepared by: CCyber Editorial Team

Note: This article is educational and strategic. It is not legal, tax or grant advisory advice. Every call must be checked against the current competition documentation.

Short answer

Cyber resilience funding for SMEs can cover a very significant part of project costs, but only when the project is well designed and aligned with the call objective. In the DIGITAL-ECCC-2025-DEPLOY-CYBER-09-UPTAKE call, support of up to 75% of costs for SMEs and up to 50% for other entities was indicated for projects focused on uptake of innovative cybersecurity solutions for small and medium-sized companies. This is not a grant for any hardware or licence purchase. The best project should help SMEs manage risk, identify assets, assess vulnerabilities, support incident reporting, integrate with SaaS tools, train employees, support NIS2 and CRA compliance and reduce incident response time. The key is a clear problem, measurable outcome, strong team, realistic budget, delivery evidence and sustainability plan after funding ends.

Last updated

July 2026

Who this article is for

  • SMEs looking for funding for cybersecurity, CRA, NIS2, backup, MFA, training or cyber tools
  • cybersecurity startups planning a project, MVP, pilot or commercialization
  • software houses, SaaS providers, MSPs, MSSPs, SOC, MDR and integrators building solutions for SMEs
  • technology companies developing AI-based cybersecurity products
  • universities, research organizations and consortia planning Digital Europe or FENG projects
  • boards, CFOs, CTOs, CIOs, CISOs, vCISOs and people responsible for cyber budgets
  • compliance, risk, legal and project documentation owners
  • companies that want to connect funding with real cyber resilience, not one-time tool purchases

Key takeaways

  1. 75% funding for SMEs is attractive, but requires a project aligned with the call objective and properly documented.
  2. The key UPTAKE call focused on practical tools, platforms, hotlines and training modules supporting SMEs with CRA, NIS2 and risk management.
  3. CYBERAI supported AI-based cybersecurity projects, but only where AI had a clear function, data, control and secure deployment model.
  4. Startup Platforms and Ścieżka SMART can be alternative paths for startups and R&D projects, but they do not replace specialized cyber calls.
  5. The biggest mistake is writing a project for the money. The best projects start from a real problem, beneficiary, proof of need and measurable outcome.

First distinction: active call or project pattern?

The Digital Europe calls from the DIGITAL-ECCC-2025-DEPLOY-CYBER-09 series had a defined application deadline and, according to ECCC information, are now closed. This does not reduce their value for companies planning future projects. Such calls show which types of cybersecurity projects are currently prioritized in the EU and how scope, budget, consortium and outcomes should be prepared.

This article should therefore be read in two layers. The first is a practical explanation of UPTAKE and CYBERAI. The second is guidance on how to prepare for future similar calls, because many EU requirements, evaluation logic and project expectations repeat across funding rounds.

What does 75% funding for SME cyber resilience mean?

Funding of up to 75% for SMEs means that a company or consortium may obtain coverage of a significant part of eligible project costs. This is a major advantage compared with many programmes where the standard support rate is lower.

However, this does not mean the project is cheap or simple. The applicant still needs own contribution, cash flow, team, documentation, reporting, risk management, delivery evidence and post-project sustainability.

In practice, 75% support means:

  • lower own contribution for SMEs
  • ability to deliver a more ambitious project
  • better access to advanced cyber technologies
  • opportunity for pilots and deployments in multiple companies
  • stronger pressure on documentation and outcomes
  • need to sustain results after the project ends

What did the UPTAKE call fund?

UPTAKE was focused on the uptake of innovative cybersecurity solutions for SMEs. Its purpose was not for every company to buy a separate tool. It was about developing practical solutions that help small and medium-sized companies manage security daily.

Main logic of the call

SMEs often do not have a large IT department, internal CISO, SOC, GRC, compliance team or enterprise budget. They need solutions that are easy to use but technologically mature. Solutions that help diagnose risk, prioritize actions, report incidents, integrate with SaaS and prepare compliance evidence.

Example UPTAKE project areas

  • cyber toolkit as a service
  • automation of cyber risk assessment
  • mapping SME digital assets
  • vulnerability and external exposure assessment
  • supply chain risk management
  • integration with SaaS tools such as HR, CRM, accounting and invoicing
  • alerts on vulnerabilities and threats
  • incident reporting interface
  • connection with CSIRT or Cyber Hub
  • cyber hotline for SMEs
  • training modules for first responders
  • tools for OT in SMEs where relevant

What is cyber toolkit as a service?

Cyber toolkit as a service is a practical set of services and tools helping SMEs perform basic cybersecurity actions without building a full security department. A good cyber toolkit is not only a dashboard with reports. It should guide the company from diagnosis to action.

A good cyber toolkit should help with:

  • identifying systems, accounts and data
  • assessing cyber risk
  • detecting basic vulnerabilities
  • assessing suppliers
  • preparing remediation recommendations
  • collecting compliance evidence
  • reporting incidents
  • training employees
  • monitoring action progress
  • reporting to management

What should cyber toolkit not do?

  • pretend to be a full SOC if it has no real monitoring
  • generate reports without remediation actions
  • create fake compliance without evidence
  • replace board risk decisions
  • promise security without people, process and maintenance

Which SME projects make the most sense?

The best SME projects solve a scale problem. A single small company will not build its own SOC, but it can use a service. It will not hire a full GRC team, but it can use a tool and consultation. It may not have a NIS2 expert, but it can have a compliance workflow, checklists, evidence repository and vCISO support.

Examples of good projects

  • NIS2 and CRA readiness platform for SMEs
  • asset and supplier inventory tool
  • managed MFA, backup and EDR service for SMEs
  • cyber hotline for SMEs with first incident response support
  • incident reporting portal with cyber first-aid instructions
  • phishing, BEC, AI scams and MFA training module
  • automated assessment of domains, email and cloud exposure
  • security assessment tool for SaaS used by SMEs
  • compliance evidence platform for enterprise customers and insurers
  • package for SMEs in critical sectors: manufacturing, healthcare, logistics, food, retail

CYBERAI: when does AI in a cyber project make sense?

CYBERAI focused on cybersecurity based on artificial intelligence. In practice, this means solutions where AI is not a marketing addition, but a real mechanism improving detection, analysis, automation, response or resilience.

AI can support cybersecurity by:

  • detecting anomalies in network traffic
  • analyzing SOC alerts
  • prioritizing incidents
  • analyzing malware
  • generating and correlating CTI
  • automating response through SOAR
  • supporting first-line analysts
  • monitoring vulnerabilities and exposure
  • analyzing supplier risk
  • detecting phishing and deepfake attacks

An AI cyber project must answer:

  • which problem does AI solve?
  • which data is used?
  • is the data legal, secure and high quality?
  • how do we limit hallucinations and wrong decisions?
  • does a human oversee critical decisions?
  • how do we protect the model against attack?
  • how does the project comply with AI Act, GDPR and sector requirements?
  • how do we measure AI effectiveness?

AI in cyber: opportunity or risk for SMEs?

For SMEs, AI can simplify cybersecurity because it helps analyze alerts, explain risk, generate recommendations and support first response. At the same time, it can increase risk if the company enters confidential data into public AI tools, trusts automated recommendations without verification or uses models without supplier control.

An AI project for SMEs should include:

  • data policy
  • secure processing of confidential information
  • recommendation verification mechanism
  • clear limits of AI responsibility
  • decision audit trail
  • output quality monitoring
  • prompt and integration security
  • model resilience testing

Startup Platforms: when are they a good path for a cyber startup?

Startup Platforms support individuals and teams that want to develop an innovative business idea in Eastern Poland with experts and business mentors. The programme helps prepare an MVP, validate the business model and establish a company. After incubation, the best startups may apply for non-repayable funding of up to PLN 600,000.

Startup Platforms may fit:

  • a new cyber product idea
  • SaaS tool for SMEs
  • AI security solution at MVP stage
  • digital hygiene or phishing reporting application
  • supplier risk assessment tool
  • solution for a specific sector such as healthcare, food, OT or retail

Startup Platforms are not best when:

  • the company already has a ready product and revenue
  • the project requires a large enterprise deployment
  • a large infrastructure budget is needed
  • the main goal is buying tools for an existing company

Ścieżka SMART: when should a cyber project go through R&D?

Ścieżka SMART supports research, development and innovation projects. It can make sense for cyber companies that do not only want to implement an existing solution, but develop a new product, technology, algorithm, detection method, AI tool or business process with at least national-level innovation.

Ścieżka SMART may fit:

  • development of a new cyber product
  • AI for threat detection
  • innovative vulnerability management system
  • new approach to OT security
  • automation tool for NIS2 and CRA compliance
  • solution with research, testing and validation component

Ścieżka SMART may be weak when:

  • the project only purchases ready licences
  • there is no real R&D component
  • innovation is only marketing language
  • the company lacks a team for research work
  • there is no clear commercialization plan

How to choose the right funding path?

Not every cyber project should go to the same programme. The right path depends on whether the company wants to implement security internally, build a product for SMEs, develop AI technology, build a startup or perform R&D work.

Deployment project for SMEs

A good direction is UPTAKE-type calls if the project delivers a practical solution for SMEs, helps with CRA and NIS2, integrates tools, trains users and supports incident handling.

AI cyber project

A good direction is CYBERAI-type calls if AI is the core of the solution and genuinely supports detection, response, data analysis, CTI, automation or AI protection.

Startup at idea stage

A good direction is Startup Platforms if the team is building an MVP, business model and early market validation.

Product requiring R&D

A good direction is Ścieżka SMART or similar FENG instruments if the project requires R&D and has potential for product or process innovation.

Company looking for internal security

A national, regional, digitalisation loan, FBiO, sector project or commercial cyber package may fit better, depending on the sector and company status.

How to prepare a cyber project for funding?

Step 1: describe the problem, not the tool

The project should not start with “we will buy a platform”. It should start with a problem: SMEs lack asset visibility, do not know how to report incidents, cannot assess suppliers, have no compliance evidence, do not understand CRA or are vulnerable to phishing.

Step 2: identify the beneficiary

SME is too broad. A better description is: small manufacturing companies with OT, accounting firms, clinics, software houses, e-commerce stores, municipal companies, logistics companies, SaaS providers or SMEs indirectly affected by NIS2 through enterprise customers.

Step 3: define the outcome

The outcome should be specific: platform, service, hotline, training modules, pilot, deployment in a defined number of SMEs, effectiveness report, SaaS integrations, risk assessment module or incident reporting tool.

Step 4: prepare the operating model

The project must show how the solution will work in practice. Who onboards SMEs? How is data collected? How is confidentiality protected? Who responds to a report? What happens after a risk is detected? What does the report for the business owner look like?

Step 5: prepare KPIs

It is not enough to write “we will improve cybersecurity”. Metrics are needed. How many companies will use the tool? How many risk assessments will be performed? How many vulnerabilities will be found? How many people will be trained? What will be the response time to reports?

Step 6: plan evidence

A grant must be reported. Already at application stage, you should know which evidence will confirm delivery: reports, protocols, logs, test results, participant lists, code repository, technical documentation and pilot reports.

What can be funded in a cyber project for SMEs?

Every call has its own eligibility rules, so the list below is a practical starting point, not a universal guarantee. In projects such as UPTAKE, costs directly linked to building, deploying and validating a solution for SMEs make sense.

Technology

  • development of cyber toolkit as a service platform
  • integrations with SaaS such as CRM, HR, accounting and invoicing
  • asset inventory module
  • vulnerability assessment module
  • supplier risk assessment module
  • incident reporting module
  • automation of remediation recommendations
  • SME panel and operator panel

Services

  • cyber hotline for SMEs
  • first incident response support
  • pilot deployments
  • security testing of the tool
  • audit of solution compliance with programme requirements
  • NIS2, CRA and GDPR advisory within the project scope

Training and skills

  • digital hygiene modules
  • training for SME owners
  • training for first responders
  • phishing, MFA, BEC and AI scams materials
  • incident reporting instructions
  • materials for sectors such as healthcare, finance, energy, transport and manufacturing

Validation and evidence

  • pilot with SMEs
  • pilot results report
  • usability tests
  • security tests
  • effectiveness metrics
  • impact assessment report

How to build the budget?

A good budget follows work packages. It should not be a wish list. Each cost should have justification, owner and connection to project outcome.

Practical budget structure

  • analysis and design work
  • product or platform development
  • technical integrations
  • security and quality testing
  • pilot with SMEs
  • training and educational materials
  • project management
  • reporting, communication and dissemination
  • pilot maintenance during the project

Budget control questions

  • is the cost eligible in this call?
  • is the cost connected with the programme objective?
  • is the cost assigned to a work package?
  • does the cost have an owner?
  • is the cost realistic for the market?
  • is own contribution included?
  • does the budget include reporting and management?
  • can the project survive cost growth or delay?

Consortium: when is it worth it and when does it hurt?

In Digital Europe projects, a consortium is often recommended because the project requires a combination of technology, research, deployment, sector and operational skills. A consortium may, however, slow the project if partner roles are unclear.

A consortium makes sense when:

  • one partner has technology
  • another partner has access to SMEs or a specific sector
  • a third partner has research or AI competence
  • a fourth partner owns training or hotline delivery
  • each partner has clear budget, tasks and outcomes

A consortium is risky when:

  • partners are selected only for image
  • there is no delivery leader
  • there is no shared evidence repository
  • IP ownership is unclear
  • no one knows who will maintain the solution after the project
  • partners have conflicting commercial interests

Which KPIs are worth planning?

KPIs should show that the project genuinely improves SME cyber resilience. They should not measure only the number of meetings or prepared slides.

Deployment KPIs

  • number of SMEs included in the pilot
  • number of active platform users
  • number of risk assessments performed
  • number of mapped assets
  • number of supplier assessments
  • number of incidents reported through the platform

Security KPIs

  • number of vulnerabilities found
  • number of closed recommendations
  • reduction in incident response time
  • increase in accounts protected by MFA
  • increase in backup tests
  • reduction in phishing success after training

Business KPIs

  • number of SMEs continuing use after pilot
  • cost of supporting one SME
  • time to onboard a new customer
  • post-project maintenance model
  • number of commercial or sector partners

Delivery evidence: what must be collected from day one?

Grant projects most often fail not because technical work is missing, but because evidence is missing. In cybersecurity, evidence is especially important because it shows that the solution not only exists, but works and increases resilience.

Project evidence

  • grant agreement
  • application and budget
  • timeline
  • decision register
  • change register
  • project risk register
  • acceptance protocols

Technical evidence

  • architecture documentation
  • code or version repository
  • test reports
  • security reports
  • SaaS integration report
  • pilot logs
  • user manuals

Impact evidence

  • pilot report
  • usage metrics
  • risk assessment results
  • list of recommendations implemented by SMEs
  • training results
  • satisfaction surveys
  • final report

Common application mistakes

Mistake 1: project is too generic

“We will improve SME cybersecurity” is too weak. You must show which SMEs, what risks, what tools, what outcomes and what evidence.

Mistake 2: AI without justification

Adding AI to the project does not automatically improve chances. You must show how AI works, which data it processes, how it is tested and how errors are limited.

Mistake 3: unclear beneficiary

A project for all SMEs is often a project for nobody. A project for a specific sector, problem or process is stronger.

Mistake 4: budget disconnected from tasks

Costs must follow work packages. Evaluators will quickly see whether the budget is realistic or only a shopping list.

Mistake 5: no maintenance plan

Evaluators want to know what happens after funding ends. Who will maintain the platform? Who will pay for infrastructure? Will SMEs continue using it?

Mistake 6: weak team

A cyber project needs technical, security, UX, regulatory, project management and grant reporting competence. The idea alone is not enough.

Common mistakes after the grant is awarded

Mistake 1: no project manager

The project has many authors, but nobody controls timeline, budget, partners, risks and evidence.

Mistake 2: documentation at the end

Evidence collected at the last minute is incomplete, inconsistent and difficult to defend.

Mistake 3: MVP scope too large

The team tries to build everything at once. It is better to deliver a smaller but working module that can be tested with SMEs.

Mistake 4: no security testing of the product itself

A cyber project with security gaps loses credibility. Tests should be part of the timeline and budget.

Mistake 5: weak SME engagement

The platform may be technically good, but if SMEs do not understand its value or onboarding is too difficult, the project will not achieve impact.

Mistake 6: no commercialization owner

The project ends with a report, but nobody owns sales, maintenance and product development after the grant.

How to prepare for future calls?

First 30 days

  • choose a cyber problem that truly affects SMEs
  • define the sector or beneficiary group
  • check whether the project fits Digital Europe, Startup Platforms, Ścieżka SMART or another programme better
  • collect proof of need: SME interviews, surveys, incidents, customer requirements and regulations
  • describe MVP or final outcome
  • identify missing competencies
  • identify potential partners
  • prepare board decision to start work

Days 31 to 60

  • build project scope and work packages
  • prepare solution architecture
  • define KPIs
  • build budget and own contribution plan
  • define project risks
  • define consortium model if needed
  • prepare NIS2, CRA, GDPR and AI Act alignment where relevant
  • plan evidence and reporting

Days 61 to 90

  • write application and attachments
  • perform technical review
  • perform financial review
  • perform review against the call objective
  • check cost eligibility
  • check intellectual property rules
  • prepare document repository
  • submit before the last day

Action plan after receiving funding

First 30 days

  • read the agreement and funding conditions carefully
  • organize project kick-off
  • confirm partner roles
  • appoint project manager
  • create operational timeline
  • create risk, decision and change registers
  • create evidence repository
  • define technical and financial reporting format

Days 31 to 60

  • launch work packages
  • approve architecture
  • define secure development rules
  • plan security tests
  • recruit SMEs for pilot
  • prepare communication and dissemination plan
  • check cost compliance with budget

Days 61 to 90

  • check progress against milestones
  • prepare first versions of documentation
  • perform first risk review
  • prepare trial technical report
  • prepare trial financial report
  • check evidence completeness
  • prepare report for board or consortium

Metrics for the board

Application readiness metrics

  • programme selection status
  • consortium status
  • budget and own contribution status
  • number of confirmed pilot beneficiaries
  • documentation readiness level

Project delivery metrics

  • percentage of work package completion
  • number of milestones delivered on time
  • number of delays
  • budget utilization
  • number of active risks

Cyber resilience metrics

  • number of SMEs supported
  • number of risk assessments performed
  • number of identified gaps
  • number of closed recommendations
  • number of reported and handled incidents
  • number of trained people

Sustainability metrics

  • number of users after pilot ends
  • platform maintenance plan
  • post-project revenue model
  • number of partners continuing cooperation
  • number of features ready for commercialization

How to connect the grant with NIS2 and CRA?

The best SME cyber project should connect with real regulatory obligations. NIS2 concerns risk management, incidents, business continuity, suppliers, training and management accountability. CRA concerns cybersecurity of products with digital elements. A project may support both areas, but it must clearly show which problem it solves.

A project supporting NIS2 may include:

  • applicability assessment
  • risk register
  • asset register
  • incident procedure
  • supplier assessment
  • backup and restore test
  • MFA and access control
  • training and digital hygiene
  • evidence repository

A project supporting CRA may include:

  • secure by design
  • product vulnerability management
  • SBOM where relevant
  • security update process
  • technical documentation
  • vulnerability disclosure handling
  • product security testing
  • informing users about risks

How not to waste 75% funding?

1. Do not buy tools without process

A tool without owner, procedure and maintenance quickly becomes a cost, not resilience improvement.

2. Do not try to solve every problem at once

A project with clear scope that delivers impact is better than a project promising a complete cyber revolution without a realistic plan.

3. Test with real SMEs

If the solution is for SMEs, it must be tested with SMEs. Otherwise, it is easy to build a platform small companies will not use.

4. Plan maintenance

The grant ends, but the product, service, hotline, platform and data must be maintained. The post-project model is as important as the start.

5. Collect evidence continuously

Reports, protocols, logs, tests, participant lists and pilot results should be created during the project, not after it.

Business example

A Polish SaaS company provides accounting workflow software for SMEs. Its customers increasingly ask about NIS2, CRA, backup, MFA, cyber insurance and supplier security. The company considers a UPTAKE-style project: it wants to build a cyber toolkit as a service module for its customers.

The first concept says: “we will add a cybersecurity panel”. This is not enough. After a workshop, the project is refined. The module maps SaaS assets, checks MFA configuration, detects basic supplier risks, provides an NIS2 checklist for SMEs, enables incident reporting, delivers phishing training and generates a report for the business owner.

The project has a pilot with 100 SMEs, effectiveness metrics, integrations with accounting and CRM systems, security tests, evidence repository and commercialization plan. It is no longer only a “cyber add-on to a product”, but a real service improving customer cyber resilience and supporting regulatory requirements.

Related CCyber resources and services

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

  • CCyber Blog - related articles on grants, NIS2, CRA, DORA, AI, SME cyber resilience, MFA, backup, suppliers and audits.
  • Funded projects - support in selecting a programme, preparing scope, budget, application, delivery and evidence for cyber projects.
  • Cybersecurity funding - support in financing actions related to NIS2, CRA, ISO 27001, audits, training and security implementations.
  • EU regulatory compliance - preparation for NIS2, DORA, CRA, ISO 27001 and customer requirements.
  • NIS2 compliance programme - applicability assessment, gap assessment, documentation, evidence, roadmap and audit readiness.
  • Secure IT deployments - IT, AI, cloud, e-service and cyber tool deployments with security, access and compliance in mind.
  • vCISO - external CISO, strategy, governance, board reporting and risk oversight.
  • Cyber Academy and training - training for employees, boards, IT, project teams and AI tool users.

How can ccyber.io help?

ccyber.io helps companies, SMEs, startups, SaaS providers and consortia prepare cybersecurity projects for Digital Europe, FENG, Startup Platforms, Ścieżka SMART and other funding instruments. We combine cybersecurity, AI, regulation, product, budget, evidence and project delivery perspectives.

We can support your organization with:

  • cyber project idea assessment
  • selection of the right funding path
  • mapping the project to NIS2, CRA, DORA, AI Act, ISO 27001 and SME needs
  • scope, work package and outcome preparation
  • KPI and cyber resilience metric definition
  • budget review and cost justification
  • project risk analysis
  • cyber toolkit as a service design
  • AI security and cyber AI module design
  • product and architecture security testing
  • training, tabletop and educational materials for SMEs
  • evidence repository and reporting support
  • 30, 60, 90-day and full project-period roadmap

The best first step is a Cyber Grant Readiness Workshop. In a short workshop, the company can check whether the idea fits the funding programme, which outcomes should be planned, which costs are logical, whether a consortium is needed and which evidence should be collected from the first day of the project.

FAQ

Does 75% funding for SMEs mean the company pays only 25% of costs?

In simplified terms yes, but only for eligible costs and subject to the call rules. Own contribution, cash flow, non-eligible costs, reporting and post-project maintenance must also be considered.

Is the indicated Digital Europe call still active?

No. At the time of writing, the DIGITAL-ECCC-2025-DEPLOY-CYBER-09 calls are closed. Their description remains a strong model for future cybersecurity projects and calls.

Can the project be only about buying licences?

Usually not. A purchase must be part of a project with objective, outcome, beneficiary, deployment, tests, evidence and maintenance plan.

Does UPTAKE have to be only for cyber companies?

No. Depending on call rules, SMEs, public and private entities, universities and research organizations may participate. Alignment with objective and beneficiaries is what matters.

Does AI improve chances in a cyber project?

It can, but only when AI solves a specific problem. AI without data, validation, security controls and AI Act compliance may weaken the project.

Are Startup Platforms an alternative to Digital Europe?

They are a different path. Startup Platforms are good for teams at idea and MVP stage. Digital Europe is more suitable for deployment projects, consortia and solutions with broader impact.

Does Ścieżka SMART fit cybersecurity?

Yes, if the project has a real R&D component and develops an innovative product or process. It is not the best fit for simple purchases of existing tools.

Where should project preparation start?

Start with the problem and beneficiary. Then describe outcome, KPIs, architecture, budget, team, risks, evidence and post-funding maintenance plan.

Summary

Funding of up to 75% for SME cyber resilience is one of the most attractive paths for cyber project financing, but only for well-prepared organizations. Such programmes do not fund random purchases. They fund solutions that help SMEs genuinely improve security, manage risk, meet CRA and NIS2 requirements, respond to incidents and build sustainable skills.

UPTAKE shows the direction for cyber toolkit as a service, SaaS integrations, risk assessment, incident reporting and SME support. CYBERAI shows the direction for AI-based tools, but requires a mature approach to data, model security and regulatory compliance. Startup Platforms and Ścieżka SMART are important alternatives for startups and R&D projects.

The best rule is: do not write the project for the call. Write the project for a problem SMEs truly have, and treat funding as a way to solve that problem faster, better and with evidence.

Sources

Cybersecurity on the Warsaw Stock Exchange: How NIS2, KPO and FBiO Create Demand for IT Companies

NIS2, national cybersecurity rules, KPO, FBiO and the growing number of cyberattacks are creating a new wave of demand for cybersecurity services in Poland. For IT companies, integrators, cloud providers, managed services, SOC, MDR, consulting, training, audits, backup, IAM, EDR, SIEM and OT security providers, this may mean more projects, tenders and long-term services. However, not every IT company will automatically benefit from regulation. The biggest advantage will belong to companies that can deliver compliance, implementation, evidence, maintenance and real risk reduction. For customers, the key conclusion is simple: cyber budgets should not go into random purchases, but into resilience that works during an incident.

Prepared by: CCyber Editorial Team

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

Short answer

Cybersecurity has become a stock market topic because regulation, public funding and real threats create demand for IT and security projects. NIS2 and national cybersecurity rules require many organizations to implement risk management, ISMS, incident procedures, backup, MFA, supplier assessment, monitoring and training. KPO, FBiO, the Digital Europe Programme and other funding instruments provide money for digitalisation, security and resilience. For IT companies, integrators, managed service providers, cloud providers, SOC, MDR, IAM, EDR, backup, SIEM, OT security and consulting providers, this may create market growth. However, this does not mean that every IT company will automatically win. The biggest beneficiaries will be providers that understand regulation, can deliver projects in critical sectors, have delivery capabilities, maintain services and provide compliance evidence.

Last updated

July 2026

Who this article is for

  • boards and business owners planning cybersecurity budgets
  • CFOs, finance directors and people planning investments in compliance and security
  • CIOs, CISOs, vCISOs, CTOs, IT managers and people responsible for selecting suppliers
  • IT companies, integrators, software houses, MSPs, MSSPs, cloud providers, SOC and MDR providers
  • companies preparing for NIS2, national cybersecurity rules, DORA, CRA, AI Act, ISO 27001 or cyber insurance
  • public entities and local governments using KPO, FBiO and cybersecurity funding programmes
  • investors and analysts who want to understand cybersecurity demand without treating this text as investment advice
  • customers buying cyber services who want to distinguish real resilience from security marketing

Key takeaways

  1. NIS2 and national cybersecurity rules create cybersecurity demand by turning cyber from a technical topic into a management and regulatory obligation.
  2. KPO, FBiO and EU programmes may accelerate projects that were previously delayed because of cost.
  3. For IT companies, the biggest opportunity is not only tool sales, but long-term implementation, maintenance, monitoring, audits and compliance evidence.
  4. For customers, the biggest risk is spending the budget on tools without processes, owners, tests and maintenance.
  5. The best providers will combine technology, regulation, OT, cloud, managed services, training, incident response and board reporting.

Why has cybersecurity become a stock market topic?

For many years, cybersecurity was seen as an IT department cost. Today it is becoming part of business strategy, compliance, financing, reputation and operational resilience. This changes how boards, investors, auditors, insurers and enterprise customers view it.

On the public market, this creates a simple mechanism: the more organizations must implement cybersecurity, the greater the demand for companies that can design, deliver and maintain such projects. This is why NIS2, national cybersecurity rules, KPO and FBiO matter not only for regulated entities, but also for IT and cyber service providers.

Cyber becomes a stock market topic because:

  • regulations raise the minimum level of requirements
  • boards must oversee cyber risk
  • customers require security evidence from suppliers
  • insurers ask about MFA, backup, EDR and procedures
  • KPO and FBiO funds finance digital and resilience projects
  • more public and private entities are looking for providers
  • managed services create recurring revenue

NIS2 as a demand generator

NIS2 does not tell companies to buy a specific product. It says: manage risk, secure systems, report significant incidents, oversee suppliers, train people, measure effectiveness and involve management. This means demand includes not only tools, but entire cyber transformation programmes.

NIS2 creates demand for:

  • regulatory applicability assessment
  • gap assessment
  • ISMS and security documentation
  • risk and asset registers
  • incident response procedures
  • backup and restore testing
  • MFA, IAM and PAM
  • EDR, XDR, SIEM, SOC and MDR
  • supplier assessment
  • penetration tests and audits
  • board and employee training
  • compliance reporting and evidence

KPO and FBiO as market accelerators

Regulation creates the obligation, but funding enables delivery. KPO, FBiO, Digital Europe, NCC-PL grants and digitalisation loans help organizations finance investments that may previously have been postponed.

Key sources of publicly funded demand

  • KPO as a broad transformation and resilience programme
  • digitalisation loans for local governments, universities and enterprises
  • FBiO for security, defence and cyber resilience
  • cyber programmes for SMEs
  • Digital Europe and ECCC
  • projects for hospitals, water utilities, local governments and critical infrastructure
  • OT and industrial cybersecurity projects

For IT providers, this means more tenders, requests, consulting projects, deployments, training and maintenance services. For customers, it means the need to prepare scope carefully, because funding should not lead to random purchases.

Who may benefit from rising demand?

This is not only about classic cyber companies. The cybersecurity market has many layers. Some revenue will go to consulting firms, some to integrators, some to software providers, some to managed service providers and some to companies operating infrastructure, cloud, data centres and OT.

Key provider groups

  • IT integrators - deployments, configuration, maintenance, migrations and infrastructure projects
  • cyber vendors - EDR, XDR, SIEM, SOAR, IAM, PAM, DLP, backup, WAF, SASE, NDR
  • MSSP and MDR providers - monitoring, SOC, alert handling, incident response and reporting
  • cloud and data centre providers - secure infrastructure, backup, disaster recovery, hosting and compliance
  • consulting firms - NIS2, national cybersecurity rules, DORA, ISO 27001, audits, gap assessment and governance
  • software houses - secure applications, DevSecOps, portals, automation, APIs and compliance tools
  • OT security companies - segmentation, industrial monitoring, remote access, IEC 62443 and production security
  • training companies - digital hygiene, phishing, boards, IT, OT and AI security

Why will not every IT company automatically benefit?

Regulations increase demand, but they do not guarantee success for every provider. Customers will increasingly ask not only about the product, but about sector experience, implementation quality, references, the provider’s own security, SLA, documentation, evidence, maintenance and accountability.

Providers with an advantage may include those that:

  • understand NIS2, national cybersecurity rules, DORA, CRA and ISO 27001
  • can implement in critical sectors
  • have IT and OT skills
  • deliver recurring services, not only one-off projects
  • can report to the customer’s board
  • have their own security at the right level
  • can work with public procurement and funded projects
  • can deliver compliance evidence

Weaker-positioned providers may include those that:

  • sell tools without process
  • lack regulatory competence
  • cannot work with the customer’s board
  • do not have maintenance services
  • cannot handle public or funded projects
  • have gaps in their own security
  • cannot scale delivery

Which market segments may grow fastest?

1. NIS2 and national cybersecurity readiness

Companies must check whether they are in scope, what gaps they have and how to prepare evidence. This creates demand for consulting, audits, gap assessment, documentation, ISMS and board reporting.

2. Managed services, MDR and SOC

Many organizations will not build their own SOC. They will look for monitoring, alert handling, incident response and monthly reporting services. This segment may be attractive because it generates recurring revenue.

3. Backup and disaster recovery

Ransomware makes backup, restore testing, DRP and BCP a board priority. This concerns companies, hospitals, local governments, water utilities, manufacturing and logistics.

4. IAM, PAM and MFA

Identity is one of the first implementation areas. MFA, access reviews, privileged accounts, supplier accounts and secure remote access will appear in most NIS2 projects.

5. OT security

Manufacturing, energy, water utilities, transport and industry need OT protection. This segment is harder than classic IT, but has high advisory and implementation value.

6. Training and cyber awareness

NIS2 and national rules require training and digital hygiene. Demand will cover employees, boards, IT, OT, finance, HR and incident response owners.

7. Testing, audits and evidence

Organizations will need to prove that safeguards work. This creates demand for penetration testing, technical audits, supplier assessments, tabletop exercises, reports and evidence repositories.

What should a cybersecurity buyer understand?

A cyber budget should not be spent under fear or regulatory pressure. The worst scenario is buying many tools that nobody operates, integrates or measures. A good cyber purchase starts with risk, not a sales offer.

Before choosing a provider, ask:

  • which business problem are we solving?
  • which critical services or systems are we protecting?
  • does the solution support NIS2, national rules, DORA or ISO 27001?
  • who will own it on the customer side?
  • which evidence will be created after implementation?
  • who will handle alerts and maintenance?
  • what SLA applies?
  • what does the exit plan look like?
  • does the provider meet baseline security requirements?

What should an IT provider understand?

Customers no longer need only a provider of hardware, licences or configuration. They need a partner that understands risk, regulation, processes, people and evidence. An IT provider that wants to benefit from rising demand must be able to speak the language of the board, compliance and operations.

The provider should prepare:

  • NIS2 and national cybersecurity readiness offer
  • customer board reporting model
  • post-implementation evidence pack
  • SLA and incident playbooks
  • clear maintenance model
  • sector references
  • own safeguards and certifications
  • supplier incident handling procedure
  • ability to work in KPO, FBiO and EU-funded projects

Cybersecurity as one-off and recurring revenue

From a market perspective, it is important to distinguish between a one-off project and recurring service. MFA deployment, audit or gap assessment can be one-off. Monitoring, SOC, MDR, vulnerability management, backup as a service, vCISO and recurring reporting can create stable revenue.

One-off revenue

  • NIS2 audit
  • gap assessment
  • tool deployment
  • penetration test
  • initial training
  • documentation project

Recurring revenue

  • MDR
  • SOC as a Service
  • managed EDR
  • managed backup
  • vCISO
  • vulnerability management
  • recurring training
  • recurring supplier audits
  • SIEM, IAM, PAM and cloud maintenance

For customers, this means cyber cost does not end with implementation. For providers, it means the most valuable business model may be tied to maintaining security capability, not only selling licences once.

Risks for IT companies using the NIS2 wave

Market growth does not remove risk. Providers may face shortages of specialists, delivery quality issues, margin pressure, long tender cycles, contractual liability, risk of their own incident and underestimated cost of maintaining services.

Key provider risks

  • not enough cyber specialists
  • delivery scaling too fast
  • low margin on public projects
  • long sales and tender cycles
  • contractual penalty risk
  • insufficient security of the provider itself
  • dependency on a few large customers
  • underestimated SOC or MDR operating costs
  • rising customer expectations for evidence and SLA

Risks for customers buying under regulatory pressure

Customers can waste significant money if they treat NIS2 as a procurement race. The worst model is buying tools, postponing documentation, assigning no owners and not testing operation.

Common customer mistakes

  • buying tools without risk assessment
  • no internal owner
  • no integration between tools and incident process
  • no backup test
  • no access review
  • no supplier assessment
  • no board reporting
  • no audit evidence
  • no maintenance budget after implementation

How should the board plan a cyber budget?

A good cyber budget should be connected with risk, regulation, critical services and downtime cost. It should not copy a supplier’s tool list.

The budget should be divided into:

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

How to assess a cyber provider?

1. Check sector experience

A provider that knows healthcare, water utilities, manufacturing, finance or public administration will understand real risks, systems and constraints faster.

2. Check evidence of the provider’s own security

A security provider should itself have MFA, access control, incident procedures, backup, audits and appropriate safeguards. A cyber provider can also be an attack target.

3. Check delivery, not only sales

The key question is: who will actually implement the project, who will maintain it and what experience do they have?

4. Check reporting

The provider should report not only alert counts, but risk, impact, decisions, SLA, gaps and remediation actions.

5. Check exit plan

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

Action plan for a company buying cybersecurity

First 30 days

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

Days 31 to 60

  • prepare NIS2 or national cybersecurity project scope
  • define provider requirements
  • compare offers by risk, not only price
  • perform restore test for a critical system
  • perform access review
  • launch baseline training
  • prepare incident response plan
  • plan monitoring or MDR service

Days 61 to 90

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

Action plan for an IT or cyber provider

First 30 days

  • define which NIS2 or national cybersecurity problem you solve
  • prepare offer for specific sectors
  • check your own security and evidence
  • prepare sample customer board reports
  • build a list of post-implementation evidence
  • prepare SLA and escalation model

Days 31 to 60

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

Days 61 to 90

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

Metrics for the customer’s board

Risk metrics

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

Protection metrics

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

Supplier metrics

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

Compliance metrics

  • percentage of NIS2 requirements with owner
  • percentage of requirements with evidence
  • number of outdated evidence items
  • audit readiness status
  • status of national cybersecurity obligations where applicable

Metrics for an IT or cyber provider

Sales metrics

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

Delivery metrics

  • number of projects delivered on time
  • number of deployments with complete evidence
  • delivery team utilization
  • number of certified specialists
  • number of complaints or post-acceptance corrections

Quality metrics

  • customer NPS
  • number of SLA incidents
  • average alert triage time
  • average escalation time
  • number of customers with current monthly report

Common market mistakes

Mistake 1: confusing regulatory demand with guaranteed profit

Just because the market grows does not mean every IT company will improve results. Margins, skills, delivery, people costs, customer retention and service quality matter.

Mistake 2: buying cyber based on headlines

The customer hears about NIS2 and buys the first tool instead of starting with risk, critical services and formal requirements.

Mistake 3: no maintenance

Implementation without maintenance budget quickly loses value. Cybersecurity requires continuous work, not a one-time purchase.

Mistake 4: overly technical approach

The board needs information about risk, impact, costs and decisions. A report about alerts and vulnerability counts is not enough.

Mistake 5: underestimating the public sector

Public projects can be large, but they have long procedures, formal requirements, documentation, budget constraints and high evidence expectations.

Mistake 6: ignoring provider security

An IT or cyber provider can be an attack vector. The customer should assess the provider like any other critical supply chain risk.

Practical example

A mid-sized manufacturing company learns that it may fall under national cybersecurity rules and NIS2. The board wants to “buy compliance”, but does not know where to start. It receives three offers: one for a SIEM tool, one for documentation and one for a full programme with audit, MFA, backup, incident procedure, supplier assessment, training, monitoring and board reporting.

The cheapest offer looks attractive, but does not solve the problem. A tool without people does not create readiness. Documentation without tests does not stop ransomware. The company chooses a staged model: first applicability assessment, risks, MFA, backup and incident response, then monitoring, suppliers and tabletop. The budget is phased and outcomes are measurable.

The provider that won the project did not sell only licences. It sold a capability: implementation, evidence, maintenance, reports and recurring review. This is the mechanism through which regulation and funding can create a durable market for mature IT companies.

Related CCyber resources and services

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

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

How can ccyber.io help?

ccyber.io helps companies and institutions translate NIS2, national cybersecurity rules, KPO and FBiO into practical cybersecurity projects. We also help IT providers organize their cyber offer so it addresses real customer needs, not only regulatory slogans.

We can support your organization with:

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

The best first step is a NIS2 and Cyber Funding Strategy Workshop. In a short workshop, the organization can determine which obligations apply, which budgets are needed, which actions may be funded and how to select providers that deliver real resilience.

FAQ

Does NIS2 automatically increase revenue for all IT companies?

No. NIS2 increases demand, but provider results depend on skills, margins, delivery quality, maintenance model, sector experience and ability to scale services.

Can KPO and FBiO finance cyber projects?

Yes, selected KPO and FBiO instruments cover digitalisation, security, cybersecurity and resilience. However, every project must be checked against eligibility, programme objectives and financing rules.

Should the customer buy tools immediately after NIS2 analysis?

Not always. First, the customer should understand risks, critical systems, backup status, MFA, suppliers and procedures. Then it makes sense to select tools.

Which services will be most needed?

Applicability assessment, gap assessment, ISMS, MFA, backup, EDR, SOC/MDR, supplier assessment, training, incident response, tabletop, audit and evidence repository.

Can managed services be more important than one-off deployments?

Yes. Many organizations do not have 24/7 security teams, so monitoring, MDR, managed EDR, managed backup, vCISO and vulnerability management may become long-term needs.

Does an IT provider need to meet high security standards itself?

Yes. The provider may have access to customer systems, logs, administrator accounts and data. The customer should require MFA, access controls, incident procedures, action logging and provider security evidence.

Is this article investment analysis?

No. The article describes cybersecurity market mechanisms and regulatory demand. It is not a recommendation to buy, sell or hold shares of any company.

Where should the customer start?

Start with applicability assessment, critical services, risks, MFA, backup, suppliers, incident procedure and maintenance budget. Then select specific tools and providers.

Summary

NIS2, national cybersecurity rules, KPO and FBiO create a strong demand impulse for the Polish cybersecurity market. For IT companies, integrators, managed service providers, cloud providers, SOC, MDR, IAM, EDR, backup, SIEM, OT security and consulting firms, this means an opportunity for more projects and recurring services.

However, this is not an automatic boom for every provider. The market will reward those that combine regulation with practical implementation, technology with process, project with maintenance and technical reporting with customer board decisions.

The best rule is: do not look at cybersecurity only as a regulatory cost or stock market trend. Look at it as a capability that must work when an incident, audit, customer question or real business downtime appears.

Sources

NIS2 in the Food Industry: Will Cybersecurity Costs Increase Food Prices?

The food industry was not included in NIS2 and national cybersecurity rules by accident. Modern food production depends on ERP, MES, WMS, cold storage, quality systems, logistics, invoicing, OT, automation and digital suppliers. A cyberattack can stop production, disrupt the cold chain, delay deliveries, weaken batch traceability, block warehouses or force manual work. Implementing NIS2 and national cybersecurity rules means costs for food producers: risk management, ISMS, MFA, backup, monitoring, segmentation, supplier assessment, training, incident response and audits. Some costs may end up in product prices, but the cost of low resilience can be higher: downtime, lost batches, penalties, lost contracts and supply disruption.

Prepared by: CCyber Editorial Team

Short answer

Yes, cybersecurity costs in the food industry may indirectly affect food prices, especially among large producers, processors and wholesale distributors covered by national cybersecurity rules and NIS2. This does not mean that cybersecurity is an unnecessary regulatory cost. Food production is now dependent on IT, OT, automation, cold chain, warehouses, invoicing, quality systems, logistics, suppliers and data. A cyberattack may stop a plant, delay deliveries, disrupt production, block traceability, affect warehouses or force manual work. Implementing national cybersecurity rules and NIS2 means costs for risk management, ISMS, MFA, backup, monitoring, segmentation, supplier assessment, training, incident response and audits. Some of these costs may be passed through to contracts, price lists or consumers. However, the cost of a successful attack can be higher than the cost of well-planned resilience.

Last updated

July 2026

Who this article is for

  • boards and owners of food production, processing and distribution companies
  • operations directors, production directors, plant managers, quality managers and logistics managers
  • CIOs, CISOs, vCISOs, CTOs, IT managers, automation engineers and OT owners
  • compliance, risk, legal, DPO, internal audit and quality control teams
  • food companies analyzing whether they fall under national cybersecurity rules and NIS2
  • suppliers to retail chains, wholesalers, gastronomy, e-commerce and production plants
  • SMEs that are not directly covered by NIS2 but receive requirements from larger customers
  • IT, ERP, MES, WMS, refrigeration, automation, SOC, MSSP, EDR, backup and quality system providers

Key takeaways

  1. Food production, processing and distribution are treated as an important sector under Polish national cybersecurity rules.
  2. A cyberattack in the food sector affects not only IT, but also production, warehouses, cold storage, logistics, invoices, quality and deliveries.
  3. The cost of NIS2 and national cybersecurity compliance may be significant, especially where the plant has extensive OT, multiple locations and many suppliers.
  4. Cybersecurity costs may partly affect prices, but the cost of a successful attack can be higher than the cost of properly planned resilience.
  5. The best projects do not only buy tools. They connect risk, production, OT, business continuity, suppliers and governance.

Why was the food industry included in national cybersecurity rules and NIS2?

Food is a basic element of economic and social security. A large producer, processor, wholesale distributor, cold storage operator or supplier to retail chains does not operate only through machines and people. It operates through digital systems.

A modern food plant uses ERP, MES, WMS, production planning systems, automation, quality control systems, refrigeration systems, laboratory systems, electronic data exchange with customers, invoicing, transport, labelling, traceability and supplier communication.

A cyberattack can hit:

  • production planning
  • continuity of production lines
  • warehouse and WMS
  • cold chain
  • traceability and batch identification
  • quality control
  • invoicing systems
  • logistics and deliveries
  • communication with retail and wholesalers
  • customer, supplier and employee data

Can NIS2 increase food prices?

It can, but not in a simple way. Cybersecurity is a cost of operating a modern plant. Companies must pay for people, tools, audits, training, backup, monitoring, segmentation, documentation, suppliers, tests and maintenance of safeguards. In a low-margin sector, part of these costs may be passed on to contracts, price lists, service fees or ultimately consumers.

Costs may come from:

  • national cybersecurity and NIS2 applicability assessment
  • ISMS implementation
  • risk register and security policies
  • MFA, EDR, backup and monitoring
  • IT and OT segmentation
  • supplier assessment
  • penetration tests and audits
  • employee training
  • incident response and BCP procedures
  • reporting to the board and authorities

However, the question should be reversed. What does low cybersecurity cost when the plant cannot produce for several days, cannot invoice, has no access to quality documentation, loses data, suffers cold storage downtime or cannot ship goods to a retail chain?

Cost of compliance versus cost of an incident

The cost of compliance is visible because it appears in the budget. The cost of an incident is often underestimated because the organization sees it only after an attack. This is one of the reasons why boards sometimes see cybersecurity as a cost rather than insurance for business continuity.

Compliance costs

  • audit and gap assessment
  • implementation of safeguards
  • licences and maintenance services
  • training
  • documentation and procedures
  • tests and exercises
  • recurring reviews

Incident costs

  • production downtime
  • lost or delayed deliveries
  • loss of product batches
  • cold chain disruption
  • manual warehouse and document handling
  • forensics and incident response
  • communication with customers and regulators
  • contractual penalties
  • loss of contracts
  • increased insurance premium
  • reputational damage

Which food companies should check applicability?

Every company involved in food production, processing or distribution should analyze its status. This especially applies to medium-sized and large companies, wholesale distributors, industrial producers, large processors, cold storage operators and suppliers to retail chains.

Entities to analyze include:

  • food producers
  • meat, dairy, vegetable, fruit, grain and beverage processors
  • packaging and co-packing plants
  • cold storage operators
  • wholesale food distributors
  • suppliers to retail chains
  • logistics companies supporting the cold chain
  • quality laboratories and production process subcontractors
  • groups with multiple plants

Indirect applicability

Even a smaller company may feel NIS2 impact if it supplies a regulated entity. A large producer, retail chain or distributor may require MFA, backup, incident procedure, training evidence, supplier assessment, audit or cyber insurance from its suppliers.

What must a food producer do under national cybersecurity rules and NIS2?

The key obligations are not limited to one document. The company should build an operating cyber risk management system covering people, processes, technology, production, OT and suppliers.

Key programme elements

  • national cybersecurity and NIS2 applicability assessment
  • registration in the national register where applicable
  • ISMS preparation and implementation
  • cyber risk register
  • critical services, systems and processes register
  • incident procedure
  • readiness to report incidents through S46 and CSIRT where applicable
  • backup and restore testing
  • supplier assessment
  • employee training
  • monitoring and effectiveness assessment of safeguards

Key systems in the food industry

NIS2 preparation should start with a map of systems affecting production and deliveries. Not all of them are typical IT. Some are OT, automation or intermediate systems between production and office.

Systems to include

  • ERP
  • MES
  • WMS
  • SCADA and HMI
  • PLCs and automation systems
  • refrigeration systems and temperature monitoring
  • traceability systems
  • quality and laboratory systems
  • labelling systems
  • EDI with customers and retail chains
  • transport management system
  • invoicing systems
  • email and communication
  • backup and documentation repositories

Cyberattack against food production: what can it look like?

Scenario 1: ransomware in ERP

ERP stops working. The company cannot issue warehouse documents, invoices, production orders and shipping documents. Production may continue for a short time, but data, orders and confirmations quickly become unavailable.

Scenario 2: WMS attack

The warehouse does not know where product batches are, what expiration dates apply, which orders must be shipped and which documents are needed. Manual work slows deliveries, increases errors and can affect retail chains.

Scenario 3: cold chain disruption

A temperature monitoring system or cold storage automation stops working or the data becomes unreliable. The company must assess whether batches still meet quality requirements and whether they can be shipped to customers.

Scenario 4: incident at an IT or automation supplier

A supplier has remote access to the plant systems. Its account is compromised or its service tool becomes the attack vector. The company does not control who connected to the environment and when.

Scenario 5: traceability unavailable

The company loses access to batch traceability data. In case of a quality issue, it cannot quickly determine where the product went and which batches should be blocked or recalled.

OT in the food industry: where is the biggest risk?

Food plants increasingly use automation, robotics, sensors, industrial IoT, dosing systems, refrigeration, packaging machines and digitally managed production lines. This improves efficiency, but creates OT risks.

Common OT problems

  • missing full device inventory
  • old operating systems
  • lack of IT and OT segmentation
  • supplier remote access without MFA
  • no logging of service actions
  • missing backup of controller configurations
  • unpatched HMI and operator panels
  • no anomaly monitoring
  • no emergency procedure for production line failure

Key OT rule

OT is not secured in the same way as office laptops. Production continuity, physical safety, maintenance windows, automation supplier responsibility and product quality impact must be considered.

What should the food company board do?

The board does not need to configure firewalls. It must understand risk, approve priorities and require evidence. National cybersecurity rules and NIS2 move cybersecurity from IT level to organizational accountability.

Board questions

  • do we know whether the company is in scope of national cybersecurity rules and NIS2?
  • which plants, lines and systems are critical?
  • how much does one day of production downtime cost?
  • do we have backup and restore tests for ERP, WMS, MES and quality systems?
  • do administrator and supplier accounts have MFA?
  • do we have IT and OT segmentation?
  • are remote suppliers controlled?
  • can we report an incident on time?
  • do we have manual work procedures for production and warehouse?
  • do we know the cyberattack impact on contracts, penalties and prices?

How to prepare a compliance programme for the food industry?

Step 1: applicability assessment

The company should check sector, size, group structure, activity type and customer relationships. In corporate groups, it must be clear which companies and plants are in scope.

Step 2: critical process map

Do not start with tools. Start with the process: order, production, quality control, cold storage, warehouse, shipping, invoicing, traceability, complaints and batch recall.

Step 3: cyber risk register

Risks must be described in business language. Example: WMS unavailability blocks shipments to a retail chain, which triggers contractual penalties and shelf-space risk.

Step 4: technical minimum

MFA, EDR, backup, restore testing, updates, segmentation, monitoring, email protection and remote access control should be treated as the operational minimum.

Step 5: procedures and evidence

Every obligation should have evidence: MFA report, backup report, restore test, access review, supplier assessment, training report, incident register, tabletop report and board decision.

Key safeguards for a food producer

1. MFA and access

  • MFA for administrators
  • MFA for email
  • MFA for VPN and remote access
  • MFA for backup and cloud
  • supplier account control
  • regular access review

2. Backup and recovery

  • backup of ERP, WMS, MES and quality documentation
  • backup of network and key OT configurations where possible
  • ransomware-resistant backup
  • restore test
  • RTO and RPO for critical processes
  • manual work plan

3. IT/OT segmentation

  • separation of office and production networks
  • controlled transitions between zones
  • limited industrial protocols
  • separate service access
  • monitoring of traffic between IT and OT

4. Monitoring and detection

  • EDR or XDR
  • logs from AD, Entra ID, VPN and firewalls
  • backup monitoring
  • supplier access monitoring
  • OT anomaly monitoring where justified
  • SOC or MSSP for plants without an internal team

5. Suppliers and supply chain

  • critical supplier register
  • risk assessment of IT and OT suppliers
  • security clauses in contracts
  • incident notification obligation
  • remote access control
  • exit plan for critical services

Which compliance evidence should be prepared?

Formal evidence

  • national cybersecurity and NIS2 applicability assessment
  • registration confirmation where applicable
  • ISMS
  • information security policy
  • risk register
  • board decisions and risk acceptances

Technical evidence

  • MFA report
  • EDR report
  • backup report
  • restore test report
  • vulnerability report
  • IT/OT segmentation diagram
  • IT and OT asset register

Operational evidence

  • incident response plan
  • BCP and DRP
  • ransomware playbook
  • incident reporting procedure
  • incident and near miss register
  • tabletop report
  • remediation action list

Supplier and people evidence

  • critical supplier register
  • supplier assessments
  • supplier access review
  • training report
  • phishing simulation report
  • confirmation of board and administrator training

30, 60 and 90-day action plan

First 30 days

  • assign owner for the national cybersecurity and NIS2 programme
  • perform applicability assessment
  • identify critical plants, processes and systems
  • collect the list of ERP, MES, WMS, OT, quality and refrigeration systems
  • check MFA for email, administrators, VPN and backup
  • check backup status and latest restore test
  • collect critical supplier list
  • present first risk and cost report to the board

Days 31 to 60

  • create cyber risk register
  • prepare ISMS implementation plan
  • perform access review for critical accounts and suppliers
  • perform restore test for a critical system
  • assess key IT, OT and logistics suppliers
  • prepare incident response plan
  • launch phishing, MFA and incident reporting training
  • design IT/OT segmentation or segmentation review

Days 61 to 90

  • run ransomware tabletop for a production plant
  • test ERP, WMS or MES unavailability scenario
  • update BCP and DRP
  • prepare CSIRT and S46 incident reporting procedure where applicable
  • prepare evidence pack for board, audit and customers
  • close key high-risk gaps
  • define plant cyber resilience metrics
  • approve 12-month roadmap

Board metrics for a food company

Risk metrics

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

Protection metrics

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

Production and continuity metrics

  • RTO for ERP, WMS, MES and quality system
  • RPO for production systems
  • time to switch to manual work mode
  • time to restore shipping
  • number of systems without contingency plan

Supplier metrics

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

Common mistakes in food companies

Mistake 1: treating NIS2 as paperwork

Documents are needed, but not enough. If the company has no backup, MFA, supplier control and manual work plan, documentation will not stop downtime.

Mistake 2: ignoring OT

The IT team secures email and laptops, but does not analyze production lines, automation, cold storage, SCADA and service access.

Mistake 3: no downtime cost

The board sees implementation cost, but does not know the cost of one day of production downtime, lost batches or delayed deliveries to retail chains.

Mistake 4: backup without testing

The company says it has backups, but has never restored ERP, WMS, MES or quality documentation in a realistic scenario.

Mistake 5: uncontrolled supplier remote access

Automation and IT suppliers have system access, but there is no MFA, named accounts, logging or periodic access review.

Mistake 6: no procedure for production

Incident response is written for IT, but does not say what production, warehouse, quality, logistics and the board should do.

Mistake 7: no training for operational employees

Training covers office staff, but not production, warehouse, maintenance and automation teams.

Mistake 8: choosing the cheapest implementation

The cheapest compliance often ends with documents without operation. It is better to implement fewer elements that truly reduce risk.

How to reduce the impact of cyber costs on product price?

Not every cyber expense must automatically increase unit product cost. A well-planned programme can reduce cost through prioritization, shared purchasing, standardization, automation and eliminating fake compliance.

Practical methods

  • start with highest-impact risks
  • implement MFA, backup and EDR as the foundation
  • combine NIS2 requirements with ISO 27001, cyber insurance and customer requirements
  • standardize safeguards across multiple plants
  • build a shared supplier and contract model
  • use managed services where an internal team would be too expensive
  • measure outcomes, not only the number of purchased tools
  • avoid solutions nobody will maintain

Practical example

A medium-sized food producer has two plants, ERP, WMS, quality system, laboratory, cold storage, packaging lines, several automation suppliers and an external IT provider. The analysis shows that the company is likely to fall under national cybersecurity rules as an important entity. The board is concerned about costs because margins are low and retail chains negotiate prices strongly.

The first review shows partial MFA, backup without current testing, no IT/OT segmentation, incomplete remote supplier list, no formal incident procedure and no board reporting. At the same time, the cost of one day of production downtime is several times higher than the cost of implementing a baseline cyber programme.

The company implements a 90-day plan: applicability assessment, risk register, MFA for critical accounts, restore test for ERP and WMS, assessment of automation suppliers, ransomware playbook, training for production and warehouse staff, and IT/OT segmentation review. After three months, the board sees not only a list of costs, but also concrete risk reduction: shorter recovery time, supplier control and incident readiness. The cybersecurity discussion moves from “regulatory cost” to “cost of maintaining supply”.

Related CCyber resources and services

This topic can be connected with further reading and CCyber services to move from cost concerns to a practical compliance and resilience plan.

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

How can ccyber.io help?

ccyber.io helps food companies translate national cybersecurity rules and NIS2 into a practical cyber resilience programme that covers production, OT, logistics, quality, suppliers and costs. This is not only about documentation. It is about maintaining production, deliveries and customer trust despite growing threats.

We can support your organization with:

  • national cybersecurity and NIS2 applicability assessment
  • NIS2 gap assessment for the food sector
  • ISMS and cyber risk register
  • critical process map: production, warehouse, cold storage, quality and logistics
  • IT and OT review
  • IT/OT segmentation design
  • backup, restore testing, BCP and DRP
  • MFA, IAM, PAM, EDR, SIEM and monitoring
  • assessment of IT, OT, automation, logistics and digital service suppliers
  • incident response plan and ransomware playbook for a production plant
  • training for board, IT, production, warehouse, quality and maintenance teams
  • tabletop for production downtime, WMS unavailability, OT incident or data leakage
  • evidence pack for audit, customer, insurer or regulator
  • 30, 60, 90-day and 12-month roadmap

The best first step is a Food Sector NIS2 Readiness Workshop. In a short workshop, the company can determine whether it is in scope of national cybersecurity rules and NIS2, which processes are critical, where the biggest gaps are, how much downtime can cost and which actions reduce risk most without overloading the budget.

FAQ

Is every food company covered by NIS2 and national cybersecurity rules?

Not automatically. Sector, company size, role in the supply chain, group structure and national law must be checked. Even a company not directly in scope may receive requirements from customers.

Is food production an important sector?

Yes. Under Polish national cybersecurity rules, food production, processing and distribution are listed among important sectors.

Can cybersecurity costs affect product prices?

They may partly affect prices, especially where margins are low and implementation costs are high. However, this is not only regulatory cost. It is an investment in production and supply continuity.

What matters most at the beginning?

Applicability assessment, critical system map, risk register, MFA, backup, restore test, supplier assessment, incident response and basic training.

Is NIS2 documentation enough?

No. Documentation must be supported by operating evidence: MFA reports, restore tests, access reviews, supplier assessments, training, incident procedures and board reporting.

Does OT need separate protection?

Yes. OT in a food plant requires separate analysis because it includes production lines, automation, cold storage, SCADA, PLCs and supplier service access.

Should smaller suppliers also prepare?

Yes, especially if they supply large producers, retail chains, wholesalers or entities covered by NIS2. Requirements may appear in contracts and security questionnaires.

How can implementation costs be reduced?

Start with the highest-impact risks, use existing tools, combine NIS2 with ISO 27001 and customer requirements, standardize across plants and measure outcomes.

Summary

NIS2 and national cybersecurity rules in the food industry are not a legislative curiosity. Food production, processing and distribution now depend on digital systems, suppliers, automation, data and supply chains. A cyberattack can quickly affect production, logistics, store shelves and consumer costs.

Implementation costs may be significant, but the cost of low resilience can be higher: downtime, lost batches, supply chaos, contractual penalties, lost customers and economic security risk. This is why implementation should be proportionate, practical and measurable.

The best rule is: do not ask only how much NIS2 costs. Ask how much one day without production, warehouse, cold storage, ERP, WMS, traceability and customer deliveries costs. Only then does cybersecurity become part of the resilience calculation, not only a regulatory cost.

Sources

Cybersecurity of Hospitals and Healthcare Providers: EU Action Plan, NIS2 and Practical Steps

The European action plan on the cybersecurity of hospitals and healthcare providers shows that healthcare is one of the most sensitive digital sectors. A cyberattack on a hospital is not only an IT problem. It can mean delayed procedures, unavailable medical records, emergency room disruption, patient data loss, diagnostic delays or operational chaos for medical staff. The EU plan focuses on four pillars: prevention, detection, response and recovery, and deterrence. For healthcare providers, this means implementing an ISMS, risk assessment, MFA, backup, segmentation, medical device security, monitoring, incident procedures, supplier assessment, training and readiness to report incidents under NIS2 and national cybersecurity rules.

Prepared by: CCyber Editorial Team

Short answer

Cybersecurity of hospitals and healthcare providers is directly connected with patient safety. Ransomware, data leakage, unavailable electronic medical records, administrator account takeover, an attack on a diagnostic supplier or loss of access to medical records can affect treatment, diagnostics, emergency departments, planned procedures and patient trust. The European action plan for cybersecurity of hospitals and healthcare providers defines four pillars: prevention, detection, response and recovery, and deterrence. For healthcare providers in Poland, this means connecting the EU plan with NIS2, national cybersecurity rules, GDPR, EHDS, AI Act, cyber insurance and daily risk management. The key actions are: risk register, ISMS, backup and restore testing, MFA, EDR, segmentation, medical device control, monitoring, incident procedures, supplier assessment, staff training and board reporting.

Last updated

July 2026

Who this article is for

  • hospital directors, board members, owners and managers of healthcare providers
  • public and private hospitals, outpatient clinics, laboratories, diagnostic centres and telemedicine providers
  • CIOs, CISOs, vCISOs, IT managers, system administrators and cybersecurity owners
  • DPOs, compliance, risk, internal audit, quality, management control and legal teams
  • medical equipment, clinical engineering, infrastructure maintenance and procurement teams
  • HIS, EHR, PACS, RIS, LIS, telemedicine, cloud, backup, SOC, MSSP and medical device providers
  • entities preparing for NIS2, national cybersecurity rules, EHDS, ISO 27001, cyber insurance or ownership audit
  • people responsible for business continuity, crisis management and patient safety

Key takeaways

  1. In healthcare, cybersecurity is part of patient safety, not only an IT responsibility.
  2. The biggest risks are ransomware, unavailable records, data leakage, diagnostic downtime, supplier attacks and uncontrolled access to medical devices.
  3. The EU plan is based on four pillars: prevention, detection, response and recovery, and deterrence.
  4. A healthcare provider should have an operating ISMS, risk register, incident procedure, backup, MFA, monitoring, segmentation, supplier assessment and staff training.
  5. The best maturity question is: can the provider continue care and communicate with patients when email, EHR, PACS or diagnostic systems are down?

Why did the EU prepare a plan for hospitals?

Digitalisation of healthcare has accelerated. Electronic health records, e-prescriptions, telemedicine, AI-supported diagnostics, connected devices, imaging systems, laboratories, patient portals and cloud improve care efficiency, but also expand the attack surface.

A hospital is now a digital organization. Doctors, nurses, reception, laboratories, imaging, hospital pharmacy, administration and external providers rely on IT systems. When these systems stop working, the problem is not only technical. It can delay treatment, force staff to work on paper, limit access to results and disrupt patient flow.

The EU plan responds to three facts:

  • healthcare is a socially critical sector
  • cyberattacks against healthcare affect patients, not only organizations
  • healthcare providers have very different maturity levels, budgets, staff and supplier dependencies

Four pillars of the European action plan

1. Prevention

Prevention means building cybersecurity foundations before an incident happens. In practice, this includes critical security practices, risk management, guidance, training, procurement with cyber requirements, digital hygiene and financial support for smaller providers.

Example actions

  • MFA for critical accounts
  • regular updates
  • backup and recovery testing
  • secure procurement of medical systems
  • supplier assessment
  • training for clinical and administrative staff
  • inventory of systems and medical devices

2. Detection

Detection means the ability to notice an attack early, before full disruption occurs. The EU plan foresees an EU-wide early warning service for the health sector and better sharing of threat information.

Example actions

  • log monitoring
  • EDR or XDR
  • administrator account monitoring
  • email and identity monitoring
  • alerts about vulnerabilities in medical devices
  • participation in sectoral information sharing

3. Response and recovery

Response and recovery mean preparing for the worst scenario: ransomware, data leakage, unavailable EHR system, supplier failure or attack on medical devices. The EU plan refers to rapid response, the EU Cybersecurity Reserve, exercises and playbooks for the health sector.

Example actions

  • incident response plan
  • ransomware playbook
  • emergency procedure without electronic records
  • crisis communication procedure
  • restore test for critical systems
  • tabletop exercises with board and clinical staff

4. Deterrence

Deterrence concerns actions at state and EU level. The goal is to show attackers that attacks against healthcare systems are met with coordinated diplomatic, legal and operational response.

What does the European Cybersecurity Support Centre mean for hospitals?

The EU plan proposes a European Cybersecurity Support Centre for hospitals and healthcare providers. It is intended to operate with ENISA and provide practical support to the sector: guidance, tools, services, training, playbooks and early warning.

What may be especially useful for providers?

  • guidance on critical cybersecurity practices
  • regulatory mapping tool
  • cyber maturity assessment framework for healthcare
  • procurement guidance for hospitals
  • training materials for healthcare professionals
  • early warning about threats
  • ransomware and incident response playbooks
  • support in using European response services

For a healthcare provider, the key is readiness to use such support. The existence of a support centre will not replace a local incident plan, backup, MFA and system owners.

Why is healthcare harder than ordinary IT?

The patient is at the centre of risk

In a company, system downtime often means lost sales or delayed work. In a hospital, downtime can delay diagnostics, a procedure, discharge, admission or access to test results. This changes the weight of decisions.

Many systems operate in parallel

HIS, EHR, PACS, RIS, LIS, pharmacy, operating theatre system, emergency department, medical devices, finance system, HR, email, registration, patient portal and supplier systems create a complex ecosystem.

Medical devices have a long lifecycle

Some medical devices operate for many years, have limited update options, require certification, depend on specialist service and cannot easily be shut down for patching.

Staff work under pressure

A hospital operates 24/7. Doctors and nurses cannot stop working only because a security measure is inconvenient. Safeguards must be designed to protect without blocking care.

Suppliers are critical

Providers of medical, diagnostic, laboratory, cloud and service systems often have remote access, and their incident can affect the healthcare provider.

How to connect the EU plan with NIS2 and national cybersecurity rules?

The EU plan sets the direction. NIS2 and national rules create obligations. A healthcare provider should connect both levels into one cyber resilience programme.

In practice, the provider must determine:

  • whether it is an essential or important entity
  • whether it must register or update data in the national register
  • whether it must use the S46 system
  • who is the contact person and deputy
  • what the ISMS looks like
  • how incidents are reported to CSIRT
  • how a cyber incident connects with GDPR and patient safety
  • which evidence will be needed for audit

Priority 1: critical services and dependency map

Not everything can be secured at once. Start with critical services and dependencies. In healthcare, criticality is not only technical. It depends on patient impact.

Key questions

  • which systems are necessary to admit a patient?
  • which systems are necessary for diagnostics?
  • which systems are necessary for surgery, ICU, emergency department and urgent care?
  • which systems support medicines, pharmacy and medical orders?
  • which systems store medical records?
  • which supplier is necessary to maintain operations?
  • how long can the provider operate without a given system?

Evidence

  • critical service register
  • system and dependency map
  • critical supplier list
  • RTO and RPO for clinical systems
  • emergency work plan

Priority 2: backup, recovery and emergency work

Ransomware is one of the key threats for healthcare. Backup must therefore be designed not as an archive, but as part of maintaining continuity of care.

What should be backed up?

  • EHR and HIS
  • PACS and RIS
  • LIS and laboratory systems
  • pharmacy systems
  • finance and billing systems
  • email and user data
  • server, network and firewall configurations
  • crisis documentation and emergency contacts

Key actions

  • ransomware-resistant backup
  • separation of backup accounts from ordinary administrators
  • MFA for backup accounts
  • regular restore tests
  • paper-based emergency procedure when clinical systems are down
  • recovery exercises with IT and clinical staff

Priority 3: identity, MFA and access

Account takeover is one of the easiest ways into a healthcare provider. In healthcare, the challenge is harder because staff rotate, work shifts, use shared workstations and often need fast access to systems.

What to implement?

  • MFA for email
  • MFA for administrators
  • MFA for VPN and remote access
  • MFA for backup and cloud
  • control of shared accounts
  • access review
  • onboarding and offboarding process
  • supplier account control
  • privileged activity logging

What to watch out for in a hospital?

MFA must not block care in emergencies. This is why exceptions, emergency accounts, break glass procedures, logging of their use and review after each use are needed.

Priority 4: medical devices, IoMT and OT

Medical devices and Internet of Medical Things are among the hardest areas of hospital cybersecurity. Some devices communicate with the network, some send data to clinical systems, some require supplier service and some operate on older operating systems.

Key actions

  • inventory of network-connected medical devices
  • classification of devices by clinical criticality
  • segmentation of medical network
  • remote service access control
  • monitoring of device network traffic
  • patching and exception procedure
  • cyber requirements in procurement of new equipment
  • emergency plan for critical devices

Evidence

  • networked medical device register
  • segmentation diagram
  • supplier remote access list
  • vulnerability review report
  • service and remote support procedure

Priority 5: suppliers and procurement

A hospital does not operate alone. Many key processes depend on suppliers: HIS, EHR, PACS, RIS, LIS, diagnostics, outsourced IT, cloud, medical device service, laboratories, external companies and healthcare service providers.

What should supplier assessment include?

  • system or service description
  • clinical criticality
  • type of data processed by the supplier
  • remote access and authentication model
  • MFA for supplier accounts
  • logging of service actions
  • incident response time
  • incident notification obligation
  • supplier continuity plan
  • exit plan

Procurement requirements

  • security by design
  • patching and vulnerability management requirements
  • logging and monitoring support
  • architecture and data flow description
  • SBOM where relevant
  • compliance with GDPR, NIS2, national cybersecurity rules, CRA or MDR where applicable

Priority 6: monitoring, SOC and early warning

A healthcare provider does not need to operate its own SOC, but it must have detection and escalation capability. In practice, this can be an internal team, MSSP, MDR, SOC as a Service or a mixed model.

Key monitoring sources

  • email and Microsoft 365 or Google Workspace
  • Active Directory or Microsoft Entra ID
  • VPN and remote access
  • firewalls
  • EDR or XDR
  • clinical servers
  • backup
  • cloud
  • supplier systems where possible
  • selected medical devices and clinical network segments

What to define in SOC or MSSP model?

  • which systems are monitored
  • service hours
  • critical alert triage time
  • who answers the phone after hours
  • who can isolate a device
  • who contacts the supplier
  • what the monthly report looks like
  • how playbooks are tested

Priority 7: incident procedure and notifications

A healthcare provider must have an incident procedure connecting IT, clinical staff, board, DPO, communications, legal, suppliers and public or private owners. The procedure should answer: what do we do in the first 15 minutes, first hour and first day?

The procedure should include:

  • definitions of event, incident and significant incident
  • incident classification matrix
  • incident team roles
  • CSIRT and S46 contact path, where applicable
  • GDPR and DPO path
  • patient and ownership body communication path
  • communication procedure when email is down
  • ransomware playbook
  • final report and lessons learned

Most important exercises

  • ransomware affecting EHR
  • PACS or RIS unavailability
  • patient data leakage
  • attack on a laboratory supplier
  • administrator account takeover
  • cloud or telemedicine provider outage

Priority 8: health data, EHDS and privacy

Health data is one of the most sensitive categories of personal data. The European Health Data Space will increase the importance of secure access, exchange and reuse of medical data. Cybersecurity and data protection therefore cannot be managed separately.

The provider should have:

  • health data map
  • data classification
  • access control for electronic medical records
  • logging of access to records
  • personal data breach procedure
  • DPIA for selected processes where required
  • assessment of suppliers processing medical data
  • rules for using data in AI and research

Priority 9: AI in healthcare

AI can support diagnostics, triage, image analysis, documentation, administrative automation and research. It can also create risks: data leakage into public tools, wrong recommendations, shadow AI, lack of validation, attacks on models and supplier dependency.

Minimum AI rules for a healthcare provider

  • do not enter patient data into unapproved AI tools
  • AI does not replace clinical decision-making without appropriate legal and medical framework
  • AI outputs are verified by humans
  • AI tools are registered and assessed
  • AI suppliers are assessed for security and data handling
  • staff know AI use rules
  • AI-related incidents are reported

Priority 10: training for healthcare staff

Clinical staff have little time and work under pressure. Training must be short, practical and role-based. The board, doctor, nurse, reception team, IT team and clinical engineer need different training.

Training scope

  • phishing and suspicious attachments
  • MFA and secure login
  • incident reporting
  • what to do during EHR outage
  • patient data protection
  • safe use of mobile devices
  • safe AI use
  • ransomware procedures

30, 60 and 90-day action plan

First 30 days

  • assign owner for the healthcare cybersecurity programme
  • determine whether the provider is subject to NIS2 and national cybersecurity rules
  • identify clinical services and critical systems
  • collect key systems list: HIS, EHR, PACS, RIS, LIS, email, backup, cloud
  • check MFA for email, administrators, VPN and backup
  • check latest restore test
  • collect critical supplier list
  • present first risk map to leadership

Days 31 to 60

  • create cyber risk register
  • prepare or update ISMS
  • prepare incident response plan
  • perform access review for critical accounts
  • test recovery of one critical system
  • assess three most important suppliers
  • launch phishing and incident reporting training
  • plan segmentation of clinical network and medical devices

Days 61 to 90

  • run ransomware tabletop for EHR or PACS
  • test emergency communication without email
  • update BCP and DRP
  • prepare CSIRT and S46 incident reporting procedure where applicable
  • prepare AI use policy
  • define board metrics
  • close key high-risk gaps
  • approve 12-month roadmap

Metrics for the healthcare provider board

Risk metrics

  • number of high and critical risks
  • number of critical systems without owner
  • number of critical suppliers without assessment
  • number of exceptions accepted by the board
  • number of overdue remediation actions

Protection metrics

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

Clinical and operational metrics

  • EHR downtime
  • PACS, RIS or LIS downtime
  • number of procedures moved or delayed during exercise
  • time to switch to paper procedure
  • time to return to normal operation

Competency metrics

  • percentage of staff trained
  • phishing simulation result
  • number of suspicious messages reported
  • number of people trained on ransomware procedure
  • number of people trained on safe AI use

Common healthcare provider mistakes

Mistake 1: treating cyber as an IT issue

A cyberattack can affect treatment. Cybersecurity must therefore be managed together with patient safety, business continuity and clinical risk.

Mistake 2: no emergency work test

The provider has a paper procedure, but never checked whether staff can operate without EHR, email and online results.

Mistake 3: underestimating medical devices

The hospital secures office computers, but does not know which medical devices are connected to the network, who manages them and how they are updated.

Mistake 4: backup without restore

A copy exists, but nobody knows whether HIS, EHR, PACS or LIS can be restored within acceptable time.

Mistake 5: no supplier control

Medical system suppliers have remote access without MFA, named accounts, logging and clear incident responsibilities.

Mistake 6: overly technical board reports

The board does not need only alert numbers. It needs to know which clinical services are at risk, which decisions are needed and what the cost of inaction is.

Mistake 7: no AI policy

Staff use AI tools to summarize documents or draft content, but the provider has no rules for patient data and accountability.

Mistake 8: training once a year

One e-learning course does not change behavior. Short modules, simulations, reminders and scenario exercises are needed.

Practical example

A county hospital uses HIS, EHR, PACS, RIS, LIS, Microsoft 365, finance system, patient portal and several remote suppliers. The board knows that healthcare is under increasing requirements, but cybersecurity has so far been treated as an IT task.

The first review shows several gaps: incomplete MFA for administrators, backup without current restore test, no register of medical devices on the network, incomplete list of suppliers with remote access, no exercise of working without EHR and no CSIRT incident reporting procedure. At the same time, clinical staff say they are afraid to report mistakes because they do not know what counts as an incident.

The hospital implements a 90-day plan. It creates a critical system register, enables MFA, performs a restore test, prepares a ransomware playbook, assesses suppliers, performs basic inventory of medical devices and runs a tabletop involving board, IT, DPO, emergency department, diagnostics and communications. After the exercise, the board sees not only technical gaps, but also patient, communication and operational impact. This is a real start of cyber resilience.

Related CCyber resources and services

This topic can be connected with further reading and CCyber services to move from the EU plan to concrete action in a healthcare provider.

How can ccyber.io help?

ccyber.io helps healthcare providers translate the European action plan, NIS2, national cybersecurity rules, GDPR, EHDS and AI Act into a practical cyber resilience programme. We combine patient safety, IT, medical devices, suppliers, compliance, training and risk management.

We can support your organization with:

  • NIS2 and national cybersecurity applicability assessment
  • healthcare cybersecurity gap assessment
  • ISMS for hospitals, clinics or laboratories
  • cyber risk register and clinical service map
  • backup, restore testing, BCP and DRP
  • incident response plan and ransomware playbook
  • incident reporting procedures for CSIRT, S46, data protection authority and owner
  • assessment of HIS, EHR, PACS, RIS, LIS, cloud and medical device suppliers
  • MFA, IAM, PAM, EDR, SIEM, monitoring and SOC as a Service
  • inventory of systems and networked medical devices
  • AI use policy and shadow AI control
  • training for clinical staff, administration, IT and board
  • tabletop for ransomware, EHR outage, data leakage or supplier incident
  • board report and audit evidence pack

The best first step is a Healthcare Cyber Resilience Workshop. In a short workshop, the provider can identify critical clinical systems, key gaps, ransomware readiness and actions needed in the first 90 days.

FAQ

Does the EU plan create new direct obligations for hospitals?

The action plan itself is strategic and coordination-oriented. Direct obligations mainly come from NIS2, national cybersecurity rules, GDPR, EHDS, AI Act, medical regulations, contracts and ownership requirements.

Is every hospital covered by NIS2 and national cybersecurity rules?

It depends on status, activity type, size, sector and national law. A healthcare provider should perform an applicability assessment and not assume automatically that obligations do not apply.

What should a hospital prioritize first?

First critical services, backup, MFA, incident response, emergency work, suppliers, monitoring and training. Then more advanced elements such as SOC, automation and mature GRC.

Is backup enough against ransomware?

No. Backup is necessary, but it must be protected, tested and connected with recovery procedure, communication, emergency work, system isolation and board decisions.

Should medical devices be treated like IT?

Not exactly. Medical devices require cooperation between IT, clinical engineering, supplier and clinical staff. Certification, availability, updates, patient impact and emergency operation must be considered.

Should a small clinic also prepare?

Yes. A smaller provider may not have a full security team, but it still processes medical data, uses digital systems and can be targeted by phishing, ransomware or data leakage.

Which training works best for medical staff?

Short, practical and repeatable training works best. It should be scenario-based: phishing, suspicious attachment, EHR outage, data leak, ransomware, paper procedures and safe AI use.

Where should we start?

Start with the map of clinical services, critical systems, backup, MFA, suppliers, ransomware procedure and a simple board report. Then plan a 90-day action programme and the first tabletop exercise.

Summary

The European action plan for cybersecurity of hospitals and healthcare providers shows that healthcare requires a dedicated approach. A cyberattack on a healthcare provider can affect patients, procedures, diagnostics, data access and public trust.

The most important actions are not only tool purchases. A provider needs a security management system, risk register, critical service map, MFA, backup, restore tests, medical device protection, supplier assessment, monitoring, incident procedures, training and board reporting.

The best rule is: do not ask only whether the hospital has safeguards. Ask whether the hospital can continue patient care when digital systems fail, whether it knows whom to notify, how to restore data and how to maintain clinical work despite an incident.

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.