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Cybersecure Water Utilities: How to Deliver the Grant Project and Secure IT/OT?

Cybersecure Water Utilities is not only a grant programme for buying IT equipment or services. It is an opportunity to significantly improve the resilience of the water and wastewater sector, which provides one of the most important services to residents: access to water and wastewater management. A good project should connect four areas: organizational, competency, technical IT and technical OT. The greatest value appears when the grant leads to an ISMS, risk management, secure remote access, IT/OT segmentation, backup, monitoring, training, incident procedures and recovery testing. The biggest mistake is treating the grant as a one-time purchase without a process, owner, tests and post-project maintenance.

Prepared by: CCyber Editorial Team

Short answer

Cybersecure Water Utilities is a programme designed to strengthen the digital resilience of entities responsible for water and wastewater services. Funding should be used not only to buy tools, but to build an operating IT and OT security system. The best project covers four layers: organization, skills, technical IT safeguards and technical OT safeguards. In practice, this means an ISMS, risk register, asset register, secure remote access, MFA, IT/OT segmentation, backup, recovery tests, monitoring, incident procedures, training, supplier assessment and delivery evidence. Water utilities should not ask only what can be bought with the grant. They should ask what must continue to operate so residents have continuity of water supply and safe wastewater services despite a cyberattack.

Last updated

July 2026

Who this article is for

  • water and wastewater companies that received a grant or are on the ranking list
  • municipalities, municipal associations, municipal companies and units performing public utility tasks
  • boards, CEOs, technical directors, operations managers and people responsible for continuity of water and wastewater services
  • IT staff, automation engineers, OT administrators, SCADA operators and people responsible for control systems
  • CISOs, vCISOs, DPOs, compliance, internal audit, management control and people responsible for national cybersecurity rules
  • IT, OT, SOC, MSSP, integrator, backup, EDR, SIEM, firewall and telecom service providers
  • local governments preparing cybersecurity projects for critical infrastructure
  • organizations that want to avoid mistakes in delivery, documentation and post-project maintenance

Key takeaways

  1. Cybersecure Water Utilities is a digital resilience programme for the water and wastewater sector, not ordinary IT purchase financing.
  2. The project should cover IT and OT, because a cyberattack can affect both office systems and systems controlling water utilities and wastewater treatment plants.
  3. The four key areas are organization, skills, technical IT and technical OT.
  4. The most important actions are secure remote access, segmentation, MFA, backup, monitoring, incident response, training and supplier assessment.
  5. The biggest mistake is buying tools without procedures, owners, tests, evidence and a maintenance plan after project completion.

What is Cybersecure Water Utilities?

Cybersecure Water Utilities is financed from Poland’s National Recovery and Resilience Plan under investment C3.1.1. The programme is implemented by the Centre for Digital Poland Projects in cooperation with NASK National Research Institute.

The purpose is to increase digital resilience of national cybersecurity system entities responsible for water and wastewater services and units performing public utility tasks. In practice, this means protecting IT systems, OT systems, data, technological processes, remote access, suppliers and employee skills.

The programme covers four areas:

  • organizational - implementation and audit of information security management systems and organizational security aspects of IT and OT systems
  • competency - raising awareness, knowledge and skills of employees at basic, management and specialist levels
  • technical IT - securing and maintaining the IT environment, equipment, software and business data
  • technical OT - securing the operational technology environment used for collective water supply and wastewater collection

What does the ranking list show?

The ranking list shows the scale of needs in the water and wastewater sector. Hundreds of applications were assessed, and projects received funding worth hundreds of millions of PLN. Such high interest means the sector understands the importance of cybersecurity, but it also shows the investment gap in IT, OT, procedures, training and security management.

Key programme numbers

  • 896 applications submitted
  • 759 applications positively assessed
  • 688 projects funded in the first ranking allocation
  • total funding for 688 projects: over PLN 590 million
  • later allocation update to over PLN 627 million
  • applications submitted by limited liability companies, municipalities and their associations, municipal organizational units and joint-stock companies

This is not only statistical information. For water utility boards and local governments, it means that cybersecurity in the water and wastewater sector is becoming a management standard, not an exception.

Why are water utilities especially important?

Access to water and wastewater services are basic services for residents, public health, businesses, schools, hospitals and administration. Disruption of water utilities or wastewater treatment is not an ordinary IT outage. It can lead to water supply interruption, service quality deterioration, sanitary issues, communication chaos and loss of trust in local government.

Water utilities connect three worlds:

  • IT - email, finance systems, billing, ERP, customer systems, public information bulletin, documents, computers and servers
  • OT - SCADA, PLCs, telemetry, pump control, pumping stations, treatment plants, sensors, field devices and technological systems
  • organization - people, procedures, suppliers, on-call duties, board decisions, resident communication and business continuity

Water utility cybersecurity must cover all three areas. Securing email alone is not enough. Securing SCADA alone is also not enough if a supplier has uncontrolled remote access or backup has not been tested.

Key threats to the water and wastewater sector

1. Remote access to control systems

One of the most serious risks is direct or weakly secured remote access to control systems, operator panels, visualization systems, industrial routers, GSM modems, VNC, RDP or technical support tools.

2. OT exposure to the internet

Industrial devices exposed to the internet can be targeted by activists, cybercriminals or random scanners. Even if the system does not seem financially attractive, it may be attacked for publicity or service disruption.

3. Ransomware in IT

Ransomware may start from a workstation, email or file server and then affect billing, documentation, customer service, operational data and technical coordination.

4. Lack of IT and OT separation

If the office network is connected to OT without proper segmentation and control, an IT incident may move into the technological environment.

5. Suppliers with broad access

Integrators, automation service providers, domain system providers and external IT companies often have access to the environment. Lack of MFA, named accounts, logging and just-in-time access procedures increases risk.

6. Untested backup

Backup without restore testing does not prove that the water utility can recover after ransomware, configuration error or hardware failure.

7. No incident procedure

During an incident, there is no time to decide who makes decisions, who reports to CSIRT, who contacts the supplier, who informs the municipality and who communicates with residents.

How to turn the grant into real protection?

A good grant project does not end with signing the agreement and buying solutions. It should change how the organization operates. Every cost should lead to a specific effect: lower exposure, shorter detection time, better backup, stronger access control, ready procedure or higher employee competence.

Best project logic

  1. Identify critical services.
  2. Define key IT and OT risks.
  3. Check which safeguards already operate.
  4. Select actions that reduce the highest incident impact.
  5. Assign owners on the board, IT, automation and operations side.
  6. Plan evidence, tests and acceptance.
  7. Secure maintenance after project completion.

Organizational area: ISMS and governance

The organizational area is often underestimated because it does not look as attractive as a new tool. In practice, this area decides whether the project will work after funding ends. Without policies, roles, risks, procedures and reporting, tools quickly become unused or misconfigured.

What is worth implementing?

  • ISMS adapted to water and wastewater, IT and OT
  • cyber risk register
  • IT and OT asset register
  • critical service map
  • incident management procedure
  • CSIRT incident reporting procedure
  • supplier remote access procedure
  • backup and recovery procedure
  • business continuity plan for water and wastewater services
  • recurring reporting to the board and local government owner

Delivery evidence

  • approved information security policy
  • risk register with owners
  • critical system register
  • management review minutes
  • ISMS audit report
  • remediation action list

Competency area: people and exercises

Water utility cybersecurity depends not only on IT staff. Automation engineers, dispatchers, field technicians, customer service employees, accounting, shift managers, board members and suppliers all matter.

Which trainings make sense?

  • cyber hygiene for all employees
  • phishing and secure email use
  • safe MFA use
  • board training on accountability and cyber risk
  • training for automation and OT teams on secure remote access
  • incident procedure training
  • ransomware tabletop exercises
  • SCADA or pumping station failure exercises
  • communication exercises with municipality and residents

Delivery evidence

  • training plan
  • participant lists
  • knowledge test results
  • phishing simulation report
  • tabletop report
  • post-exercise actions

Technical IT area: foundations that must work

The IT environment is often the attacker’s entry point. The project should cover email, identity, workstations, servers, backup, finance systems, billing, customer systems, documentation and remote access.

Key IT actions

  • MFA for email, administrators, VPN and backup
  • EDR or XDR on workstations and servers
  • email protection against phishing and malware
  • ransomware-resistant backup
  • restore test for critical systems
  • patch management
  • vulnerability scanning
  • logging and monitoring
  • administrator account control
  • privilege separation and access review

Delivery evidence

  • MFA report
  • EDR report
  • backup report
  • restore test report
  • vulnerability report
  • privileged account list
  • access review report

Technical OT area: protection of control systems

OT requires a different approach than classic IT. Technological systems must operate reliably, often for many years, and misconfiguration may have physical consequences. OT safeguards must therefore be designed carefully, with automation and operations teams involved.

Key OT actions

  • OT asset inventory
  • map of connections between IT and OT
  • IT and OT network segmentation
  • removal of direct internet access to VNC, RDP and web panels
  • VPN with MFA for remote access
  • just-in-time remote access
  • logging of supplier and service actions
  • limited exposure of industrial protocols
  • configuration backup for PLCs, HMI and supervisory systems
  • anomaly detection in OT network traffic

Delivery evidence

  • OT asset register
  • segmentation diagram
  • remote access review report
  • supplier account list
  • service action logging report
  • configuration backup test report
  • OT audit report

Remote access to OT: the key control point

Remote access is needed because automation providers, service teams and technical duty staff must respond quickly. But uncontrolled remote access is one of the most serious risks. The grant should help move from informal access to a controlled model.

A good remote access model includes:

  • no direct exposure of OT panels and services to the internet
  • VPN with MFA
  • named accounts
  • access only for authorized suppliers
  • time-limited access
  • approval of service session
  • action logging
  • ability to terminate the session
  • regular access review
  • contractual security requirements for suppliers

Backup in water utilities: what must be recoverable?

Backup in water utilities is not only a copy of office files. The organization must know which data and configurations are needed to restore operations.

Backup analysis should include:

  • finance and accounting system
  • billing and customer service system
  • document workflow system
  • email and user data
  • file servers
  • domain system databases
  • firewall, router and switch configurations
  • HMI, SCADA and PLC configurations where possible
  • technology documentation
  • emergency procedures and crisis contacts

The most important test

The most important evidence is not that backup exists. The most important evidence is a critical system restore test and a protocol showing what was restored, how long it took, who participated and what problems were found.

Monitoring and SOC: when does it make sense?

Monitoring makes sense when it is clear what will be monitored, who responds to the alert, how escalation works and what happens after hours. Many water and wastewater entities do not have their own SOC, so SOC as a Service, MDR or shared monitoring for several units may be a good model.

Log sources to consider

  • Microsoft 365 or Google Workspace
  • Active Directory or Microsoft Entra ID
  • firewalls
  • VPN
  • EDR or XDR
  • critical servers
  • backup system
  • OT systems, if integration is safe
  • ticketing system or incident register

What to define in a SOC or MSSP agreement?

  • scope of monitored systems
  • service hours
  • critical alert triage time
  • customer escalation time
  • after-hours contact procedure
  • ransomware and account takeover playbook
  • provider access model
  • monthly report and metrics

How to deliver the project well after the grant is awarded?

Positive assessment and funding award are only the beginning. The greatest risk appears during delivery: procurement, acceptance, integrations, tests, evidence, deadlines, suppliers and outcome maintenance.

First 30 days after the decision

  • read the grant agreement and delivery conditions
  • appoint a project manager
  • create an IT, OT, operations, finance and board project team
  • confirm project scope
  • create decision, risk and change registers
  • create evidence repository
  • plan procurement procedures
  • define outcome acceptance method

First 60 days

  • prepare detailed timeline
  • check IT and OT dependencies
  • agree security requirements with suppliers
  • plan maintenance windows
  • prepare test plan
  • define report and acceptance protocol formats
  • start baseline trainings

First 90 days

  • perform first progress review
  • check completeness of financial documents
  • check completeness of technical evidence
  • close first risks and delays
  • test at least one critical component
  • prepare report for the board and local government owner

Which documents should a grant recipient have?

Project documents

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

Cyber documents

  • ISMS
  • cyber risk register
  • IT and OT asset register
  • incident response plan
  • BCP and DRP
  • backup policy
  • remote access procedure
  • incident reporting procedure

Technical evidence

  • MFA report
  • EDR or XDR report
  • backup report
  • restore test report
  • vulnerability scan report
  • network segmentation or review report
  • OT audit report
  • monitoring or SOC report

Competency evidence

  • training plan
  • attendance lists
  • knowledge test results
  • phishing simulation report
  • tabletop report
  • post-exercise findings and actions

How to measure project impact?

The grant should leave behind measurable improvement in cyber resilience. That is why KPIs should be defined at the beginning, understandable for the board, municipality, auditor and technical team.

IT metrics

  • percentage of critical accounts with MFA
  • percentage of devices covered by EDR
  • number of overdue critical vulnerabilities
  • time from alert detection to escalation
  • number of systems covered by backup

OT metrics

  • number of inventoried OT assets
  • number of remote connections under control
  • number of OT devices exposed to the internet
  • number of suppliers with named access and MFA
  • number of OT systems covered by anomaly monitoring

Business continuity metrics

  • RTO for critical systems
  • RPO for critical systems
  • restore time in test
  • number of tested emergency procedures
  • tabletop exercise result

Management metrics

  • number of risks with owners
  • number of overdue remediation actions
  • number of assessed suppliers
  • number of trained employees
  • readiness status for national cybersecurity rules and NIS2

Common grant recipient mistakes

Mistake 1: purchase without architecture

The organization buys many solutions but does not know how they will connect with existing IT, OT, monitoring, backup and procedures.

Mistake 2: OT omitted

The project strengthens only office computers, while control systems, remote access and field devices remain uncontrolled.

Mistake 3: automation team not involved

OT cybersecurity should not be designed without people responsible for the technological process.

Mistake 4: no testing

Tools are implemented, but nobody tests restore, alert escalation, remote access or incident procedure.

Mistake 5: missing evidence

The project is technically completed, but there are no reports, protocols, attendance lists, baseline configurations or acceptance confirmations.

Mistake 6: no maintenance budget

After the grant ends, there is no money for licences, monitoring, service, training and regular tests.

Mistake 7: suppliers ignored

Automation and IT suppliers still use broad remote access, shared accounts or unlogged connections.

Mistake 8: no board reporting

The board does not see risks, delays, scope changes and project outcomes. Without reporting, accountability and continuity after the project are hard to maintain.

How to connect the project with national cybersecurity rules and S46?

Water and wastewater entities in the national cybersecurity system should treat the grant as part of preparation for wider obligations. The project should support not only technology, but also formal organizational readiness.

The project should include:

  • assessment of the entity’s national cybersecurity status
  • registration or data update where applicable
  • contact persons and deputies
  • incident reporting procedure
  • preparation for S46 use
  • reporting to the board and local government owner
  • evidence for future audit

Example of a well-used grant project

A medium-sized water and wastewater company has SCADA, several pumping stations, a wastewater treatment plant, telemetry network, billing system, Microsoft 365, file server and external automation and IT suppliers. An audit shows that some remote access uses old VPN, service accounts are shared, backup has not been tested and OT devices are not fully inventoried.

The grant project is divided into four packages. In the organizational area, an ISMS, risk register and incident procedure are created. In the competency area, training is delivered for the board, IT, automation staff and dispatchers. In the IT area, MFA, EDR, backup and restore testing are implemented. In the OT area, inventory, segmentation, remote access control and anomaly monitoring are implemented.

After the project, the organization has not only new safeguards, but also evidence: audit report, asset register, MFA report, restore test report, segmentation protocol, incident procedure, tabletop results and board report. This is real cyber resilience, not only a settled purchase.

Related CCyber resources and services

This topic can be connected with further reading and CCyber services to move from ranking list and grant agreement to safe project delivery.

How can ccyber.io help?

ccyber.io helps water and wastewater companies, local governments and municipal companies turn the Cybersecure Water Utilities grant into real IT and OT security improvement. We combine financing, cybersecurity, OT, national cybersecurity rules, NIS2, IT projects, suppliers and delivery evidence.

We can support your organization with:

  • grant project scope review
  • IT and OT cyber resilience diagnosis
  • ISMS design for water and wastewater entities
  • cyber risk register and risk treatment plan
  • IT and OT inventory
  • IT/OT segmentation design
  • secure remote access to OT
  • MFA, IAM, PAM, EDR, SIEM, backup and monitoring
  • incident response plan and incident reporting procedure
  • BCP, DRP, restore test and tabletop
  • assessment of IT, OT, automation and managed service suppliers
  • training for board, IT, automation, dispatch and general staff
  • evidence repository and reporting to the board and local government owner
  • post-project outcome maintenance roadmap

The best first step is a Cybersecure Water Utilities Delivery Workshop. In a short workshop, the organization can review project scope, IT/OT risks, required evidence, timeline, suppliers, outcome maintenance and alignment with national cybersecurity rules and NIS2.

FAQ

Is Cybersecure Water Utilities only a tool purchase programme?

No. The programme covers four areas: organizational, competency, technical IT and technical OT. Tool purchases make sense only when they support a process, procedure, risk and measurable outcome.

Does the project have to include OT?

Not every cost must relate to OT, but OT is a key risk area in the water and wastewater sector. Control systems, telemetry, SCADA, PLCs and supplier remote access should be analyzed.

What matters most after receiving funding?

The most important actions are appointing the project owner, confirming scope, preparing timeline, securing evidence, defining acceptance criteria and connecting purchases with real security outcomes.

Is backup enough?

Backup is very important, but not enough. It must be tested, backup accounts must be protected, RTO and RPO must be defined and backup must be connected with a ransomware recovery procedure.

Does every water utility need SOC or monitoring?

Not always in the same scope. Every entity should have detection and escalation capability. This may be an internal process, MSSP service, SOC as a Service or shared model.

What should be done with supplier remote access?

It should be inventoried, limited, secured with VPN and MFA, moved to named accounts, logged and preferably implemented as just-in-time access where possible.

Which evidence will matter most?

MFA report, backup and restore test report, risk register, IT/OT asset register, incident procedure, training report, OT audit report, supplier access review and board report.

Where should project delivery start?

Start with critical services, risks, owners, remote access, backup, MFA, OT and evidence timeline. Only then finalize purchases and deployments.

Summary

Cybersecure Water Utilities is one of the most important programmes strengthening the cyber resilience of the water and wastewater sector. Its importance goes beyond buying equipment and services. It protects a public service directly connected with health, safety and everyday life of residents.

The best projects will connect organization, skills, IT and OT. They will include ISMS, risks, remote access, segmentation, MFA, backup, monitoring, training, suppliers, incident procedures and tests. This turns the grant into an investment in resilience, not only a settled expense.

The best rule is: do not first ask what to buy. Ask which technological process and which resident service must operate after a cyberattack, then plan safeguards, people, procedures and evidence around that answer.

Sources

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

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

Prepared by: CCyber Editorial Team

Short answer

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

Last updated

July 2026

Who this article is for

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

Key takeaways

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

What is the Security and Defence Fund?

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

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

Key elements of FBiO

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

FBiO is not a classic grant. It is preferential financing

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

For the municipal sector, this means:

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

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

What can a local government obtain financing for?

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

Example categories for the municipal sector

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

What does this mean for cybersecurity?

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

Which cyber projects may make sense in local government?

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

1. Protection of critical local government services

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

2. Backup, recovery and business continuity

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

3. Monitoring, detection and response

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

4. Identity, access and MFA

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

5. Cybersecurity of e-services

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

6. OT and technical infrastructure security

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

7. Training, cyber hygiene and operational readiness

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

How to connect FBiO with national cybersecurity rules and NIS2?

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

FBiO can support elements such as:

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

Practical rule

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

How to build a good cyber project for FBiO?

Step 1: start with critical services

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

Step 2: describe the risk

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

Step 3: define the outcome

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

Step 4: prepare architecture

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

Step 5: plan maintenance

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

What should be included in the project description?

Problem description

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

Project scope

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

Outcomes

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

Sustainability

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

Which costs are worth planning?

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

Preparation costs

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

Technology costs

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

Service costs

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

Documentation and evidence costs

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

What should not be financed without thinking?

Equipment without process

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

Tools without people

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

Solutions without integration

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

Project without maintenance

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

How to prepare the BGK application?

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

Practical preparation list

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

Which documents should a local government have before applying?

Strategic documents

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

Project documents

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

Cyber documents

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

How to assess whether the project is good?

Test 1: does the project protect a public service?

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

Test 2: does the project have a measurable outcome?

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

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

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

Test 4: can the project be maintained?

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

Test 5: does the project have an owner?

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

Project ideas for a small or medium-sized municipality

Baseline package: local government cyber minimum

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

Critical service resilience package

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

SOC package for a group of local governments

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

Crisis communication package

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

FBiO for enterprises: what matters?

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

Key parameters for enterprises

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

For cyber companies, this creates opportunities for:

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

How to combine FBiO with other financing sources?

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

Practical rule

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

Action plan before submitting the application

First 30 days

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

Days 31 to 60

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

Days 61 to 90

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

Action plan after receiving financing

First 30 days

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

Days 31 to 60

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

Days 61 to 90

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

Metrics for local government leadership

Project metrics

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

Cyber resilience metrics

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

Business continuity metrics

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

Supplier metrics

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

Common local government mistakes

Mistake 1: the project starts with purchases

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

Mistake 2: no owner on the local government side

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

Mistake 3: no maintenance costs

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

Mistake 4: no link with national cybersecurity rules and NIS2

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

Mistake 5: dependent units and companies omitted

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

Mistake 6: no testing

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

Mistake 7: unclear cost eligibility

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

Mistake 8: no documentation from day one

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

Practical example

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

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

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

Related CCyber resources and services

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

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

How can ccyber.io help?

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

We can support your organization with:

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

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

FAQ

Is FBiO a cybersecurity grant?

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

Can a local government finance a cybersecurity project?

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

Can SOC or monitoring be financed?

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

Can backup be financed?

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

Can the project include a municipal company?

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

Can FBiO be combined with other programmes?

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

What matters most before applying?

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

Where should a small municipality start?

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

Summary

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

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

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

Sources

Cybersecurity Grants from the Digital Europe Programme: How to Prepare and Deliver a Successful Project?

A cybersecurity grant is not only a way to buy a tool. It is a project that needs a clear objective, business justification, compliance with the call rules, measurable outcomes, realistic budget, timeline, competent team, delivery evidence and a plan to sustain results after funding ends. The Digital Europe Programme and NCC-PL initiatives show that funding can support SMEs, NIS2 and CRA projects, AI-based cybersecurity solutions, preparedness testing, penetration testing, vulnerability assessment, training, platforms, services and tools that increase cyber resilience. The biggest risk for beneficiaries is not only a weak idea, but poor scope, unrealistic budget, missing owners, weak documentation and failure to deliver outcomes.

Prepared by: CCyber Editorial Team

Short answer

Cybersecurity funding from the Digital Europe Programme, NCC-PL, ECCC or similar instruments can accelerate the development of products, services, skills and organizational resilience. However, it should not be treated as “free money for cyber”. A grant is a project that must be planned, justified, delivered, documented and reported. The best projects have a clear problem, well-defined beneficiaries, measurable outcomes, realistic budget, strong team, solid timeline, delivery evidence, risk management plan and a sustainability plan after funding ends. The most common mistakes are overly broad scope, missing owner, unrealistic timeline, weak cost justification, poor alignment with the call objective, underestimating reporting work and missing evidence.

Last updated

July 2026

Who this article is for

  • SMEs planning cybersecurity projects with external funding
  • cybersecurity companies, software houses, SaaS, MSPs, MSSPs and technology startups
  • organizations preparing projects for NIS2, CRA, DORA, AI Act or ISO 27001
  • universities, research organizations and project consortia
  • public entities, CSIRTs, healthcare units and critical service operators
  • boards, CFOs, project managers and budget owners
  • CISOs, vCISOs, CTOs, CIOs, compliance, legal, risk and cyber owners
  • organizations that have received a grant and want to avoid delivery and reporting problems

Key takeaways

  1. A good grant project starts with a problem and outcome, not a shopping list.
  2. Cybersecurity can be funded through tool, service, training, research, deployment and testing projects.
  3. The key elements of an application are alignment with the call objective, beneficiaries, outcomes, budget, timeline, team and sustainability.
  4. After the grant is awarded, the harder part begins: managing scope, partners, milestones, reports and documentation.
  5. The best cyber project connects funding with a real increase in cyber resilience and does not stop at purchasing a tool.

Why does cybersecurity funding matter now?

Cybersecurity is becoming more expensive and more necessary. Companies must invest in MFA, backup, EDR, monitoring, training, supplier assessment, penetration testing, compliance with NIS2, CRA, DORA, AI Act, ISO 27001 and cyber insurance. At the same time, SMEs, startups, healthcare entities, local governments and smaller technology providers often do not have the budget to implement everything quickly and independently.

Grants can reduce the entry barrier. They can help develop Polish cyber products, strengthen SMEs, test organizational resilience, fund training, create compliance tools, develop AI-based solutions, support healthcare, digital infrastructure and supplier resilience.

Funding makes the most sense when the project:

  • solves a specific cybersecurity problem
  • has clearly defined beneficiaries
  • fits regulatory or market needs
  • delivers measurable outcomes
  • can be maintained after funding ends
  • has a team capable of delivery and reporting

Digital Europe Programme and the role of ECCC and NCC-PL

The Digital Europe Programme supports the development and deployment of advanced digital technologies in the economy and public administration. In cybersecurity, an important role is played by the ECCC, the European Cybersecurity Competence Centre, and the network of National Coordination Centres. In Poland, this role is performed by NCC-PL.

From the perspective of companies and institutions, the key point is that such programmes do not fund “cybersecurity in general”. They fund specific objectives: deployment of innovative solutions, tool development, testing, vulnerability assessment, regulatory readiness, critical sector resilience, skills, AI, cloud, infrastructure and response capabilities.

Common types of funded activities

  • cybersecurity tools and platforms
  • solutions supporting SMEs with NIS2 and CRA
  • AI-based cybersecurity
  • preparedness testing, penetration testing and vulnerability assessment
  • training and educational modules
  • hotlines and expert support
  • projects for healthcare, public administration and critical sectors
  • solutions increasing digital infrastructure resilience
  • research, development and deployment of new products

Examples of calls: what do they teach companies?

Digital Europe Programme and related calls show which directions matter for the EU and the Polish cyber ecosystem. Some of the calls mentioned had deadlines in the first half of 2026, so they should be treated as examples and a preparation pattern for future competitions.

Support for innovative cyber solutions for SMEs

Calls focused on uptake of innovative cyber tools for SMEs show that regulations such as NIS2 and CRA create a real need for practical solutions. It is not enough to say that SMEs must be secure. They need tools, platforms, services, training, hotlines and processes that can be implemented in small organizations.

AI-based cybersecurity

AI-based cyber solutions can support threat detection, alert analysis, incident response, automation and data analysis. Such projects must also address the security of AI itself, data quality, AI Act compliance, GDPR and risk of wrong decisions.

Preparedness and resilience testing

Preparedness tests, exercises, penetration tests and risk assessments matter because they show whether organizations are ready for real incidents. A well-designed testing project does not end with a report. It should lead to remediation and retesting.

Penetration testing and vulnerability assessment

Grants for organizations specializing in cybersecurity show that the market needs practical services: penetration testing, vulnerability assessment, technical recommendations and support for entities in scope of NIS2.

Regional Cable Hubs and critical infrastructure

Calls related to submarine cables show that cybersecurity is connected with physical infrastructure, international communications and strategic resilience. This is a good example of a project where cyber, infrastructure, AI, data analysis and operational security must work together.

Who can use such funding?

Eligible entities depend on the specific call. In practice, cybersecurity projects include various groups of beneficiaries and partners.

Most commonly these may include:

  • SMEs
  • cybersecurity startups
  • mid-sized companies
  • software houses and product companies
  • MSPs, MSSPs, SOCs and cyber service providers
  • universities
  • research organizations
  • public entities
  • CSIRTs and competent cybersecurity authorities
  • organizations implementing NIS2 or CRA
  • entities supporting critical sectors
  • consortia combining business, science and the public sector

When does a consortium make sense?

A consortium makes sense when the project requires combining skills: technology, research, deployment, access to end users, regulation, testing, training and commercialization. A consortium should not be created only to look better in the application. Every partner must have a real role, budget, tasks and accountability.

Which projects have the best chance?

The best chance belongs to projects that fit the call objective and can show why their outcome is needed, feasible and sustainable.

Good projects usually have:

  • a specific cyber problem to solve
  • clearly identified beneficiaries
  • real market or regulatory need
  • measurable outcomes
  • well-described team and skills
  • realistic timeline
  • budget linked to tasks
  • deployment and sustainability plan
  • risk management plan
  • clear delivery evidence

Weak projects usually have:

  • too generic problem description
  • no specific end user
  • AI or NIS2 used as slogans without substance
  • budget disconnected from tasks
  • no commercialization or sustainability plan
  • unrealistic timeline
  • unclear division of roles in the consortium
  • no evidence that the team can deliver

How to prepare a project for an application?

Step 1: read the call objective, not only the amount

The biggest mistake is starting with “how much can we get?”. The more important question is: which problem does the programme want to solve and does our project really address it?

Step 2: define the beneficiary

A project for SMEs affected by CRA and NIS2 will be different from a project for hospitals, CSIRTs, digital infrastructure entities or cyber providers. The more precisely the beneficiary is defined, the easier it is to justify scope.

Step 3: describe the outcome

The outcome should be specific: tool, platform, service, testing methodology, training, module, report, pilot, deployment, recommendations, ready product or tested procedure.

Step 4: check eligibility

Check whether the organization can apply, whether a consortium is required, whether an EU or EEA establishment is needed, what the funding rate is, what co-financing is required and which costs are eligible.

Step 5: build a logical budget

The budget should follow tasks. Each cost should have a justification, owner and link to the project outcome.

Step 6: prepare the timeline

The timeline must include time for procurement, contracts, testing, acceptance, corrections, reporting, partners, risks and delays. A cyber project often needs more time for integration and testing than the first plan assumes.

Step 7: plan evidence

Already at the application stage, you should know which evidence will prove project delivery: acceptance protocols, test reports, logs, technical documentation, participant lists, training reports, scan results, materials, repositories and financial reports.

What can be funded in cyber projects?

Every call has its own rules, but cybersecurity projects may cover many types of activities. The list below helps prepare scope, but it must always be compared with the documentation of the specific competition.

Technologies and tools

  • cybersecurity platforms
  • vulnerability management tools
  • asset inventory tools
  • monitoring and detection systems
  • AI-based cyber solutions
  • NIS2 and CRA compliance tools
  • training and educational modules
  • data protection solutions

Services and tests

  • penetration testing
  • vulnerability assessment
  • security audit
  • preparedness testing
  • tabletop exercises
  • risk assessment
  • supplier resilience testing
  • technical recommendations

Skills and training

  • digital hygiene training
  • board training
  • IT and SOC training
  • NIS2, CRA, DORA and AI Act training
  • educational materials for SMEs
  • mentoring programmes
  • hotlines and expert support

Governance and compliance

  • risk management methodologies
  • incident procedures
  • NIS2 and CRA compliance models
  • supplier assessment
  • regulatory requirements mapping
  • evidence repositories
  • board reporting models

How to build the project budget?

The budget should be understandable for evaluators and defensible during reporting. It should not look like a wish list. It should follow work packages and outcomes.

Main cost categories

  • project team work
  • subcontracting
  • technology purchase or development
  • testing and validation
  • training and educational materials
  • project management
  • communication and dissemination
  • audit, reporting and financial settlement

Budget control questions

  • does each cost relate to the call objective?
  • is the cost assigned to a task?
  • is it clear who is responsible for delivery?
  • is the cost realistic for the market?
  • is own contribution included?
  • does the budget include reporting and management?
  • will the project survive if cost increases by 10-15%?

How to plan outcomes and KPIs?

A grant project must have measurable outcomes. In cybersecurity, it is easy to fall into generic language such as “improving security”. That is not enough. The project must show exactly what will change.

Example KPIs for a cyber project

  • number of organizations supported
  • number of penetration tests performed
  • number of vulnerabilities detected and remediated
  • number of people trained
  • number of pilot deployments
  • number of SMEs using the tool
  • detection or response time before and after implementation
  • number of compliance reports prepared
  • number of educational modules developed
  • readiness level for NIS2, CRA or another requirement

A good KPI should be:

  • measurable
  • linked to the call objective
  • possible to prove
  • realistic
  • useful for the project beneficiary

What to do after the grant is awarded?

Awarding the grant is not the end. It is the moment when the project moves from promise to execution. This is where the most common problems appear: delays, missing documentation, partner disputes, unclear roles, missing evidence, procurement errors and reporting left until the last moment.

First 30 days after the decision

  • read the agreement and funding conditions
  • confirm project scope
  • appoint project manager
  • confirm partner roles
  • create milestone calendar
  • launch document repository
  • define cost description rules
  • prepare reporting plan

First 60 days after the decision

  • launch work packages
  • prepare detailed schedule
  • set project meeting cycle
  • define evidence and acceptance protocol formats
  • prepare project risk register
  • verify procurement and subcontracting rules
  • define progress reporting method

First 90 days after the decision

  • check delivery of first outcomes
  • compare costs with budget
  • close first risks and delays
  • prepare a trial technical report
  • prepare a trial financial report
  • check evidence completeness
  • run a review with partners

How to manage a grant project?

1. Build a simple governance model

The project should have a sponsor, project manager, work package owners, finance owner, compliance owner, technical owner and evidence owner.

2. Set the rhythm of work

A steady rhythm works best: weekly operational meeting, monthly management review, quarterly risk review and evidence review before every report.

3. Keep a decision register

In a publicly funded project, decisions should be recorded. This applies to scope changes, supplier selection, timeline shifts, risks, acceptance and approvals.

4. Manage changes

A cyber project almost always changes. New vulnerabilities, technology changes, supplier delays, regulatory changes and new user needs appear. What matters is that changes are controlled and documented.

5. Document continuously

The most expensive mistake is trying to recreate documentation at the end of the project. Evidence should be created when the task is completed.

Which documents should a beneficiary have?

Project documents

  • grant agreement
  • application and budget
  • timeline
  • work package description
  • project risk register
  • decision register
  • change register
  • partner and role list

Financial documents

  • cost register
  • invoices and contracts
  • cost descriptions
  • payment confirmations
  • procurement documentation
  • time records, if required
  • cost justifications

Technical documents

  • architecture documentation
  • test reports
  • vulnerability reports
  • penetration test reports
  • code repository or version documentation
  • acceptance protocols
  • user manuals
  • pilot deployment reports

Reporting documents

  • technical reports
  • financial reports
  • milestone reports
  • communication and dissemination reports
  • final report
  • outcome sustainability report

Common mistakes in applications

Mistake 1: project does not match the call objective

The project is interesting, but it does not solve the problem described in the competition. Evaluators see weak alignment and scoring drops.

Mistake 2: too many slogans, too few specifics

AI, NIS2, CRA, resilience and innovation matter, but slogans are not enough. The application must show what exactly will be done.

Mistake 3: no end user

The project talks about the market, but does not show who will actually use the solution, how it will be deployed and how it will be maintained.

Mistake 4: unrealistic budget

The budget is too low to perform the tasks or too high without justification. Both situations weaken credibility.

Mistake 5: lack of team competence

The team declares advanced cyber activities, but does not show experience, roles, certifications, projects or partners.

Mistake 6: no post-project plan

Evaluators want to know what happens after funding ends. Will the product be maintained? Will the service be available? Will the results be used?

Common mistakes after the grant is awarded

Mistake 1: no project manager

Everyone runs part of the project, so nobody controls timeline, budget, partners, reports and evidence.

Mistake 2: reporting at the end

Documentation created at the last minute is incomplete, inconsistent and hard to defend.

Mistake 3: uncontrolled scope changes

The team adds features, changes technology or moves tasks without a formal decision and without assessing budget impact.

Mistake 4: weak consortium communication

Partners work separately, do not understand dependencies and do not provide evidence on time.

Mistake 5: underestimating management costs

A cyber project is not only technical work. Reporting, meetings, acceptance, coordination, documentation and settlement require real time.

Mistake 6: no audit plan

The beneficiary does not prepare documents for control and later has to search for evidence in emails, chats and folders.

How to avoid reporting problems?

1. Read the agreement and call documentation

Do not rely only on the competition summary. Eligibility, reporting, changes, subcontracting and evidence rules come from the call documents and agreement.

2. Build an evidence repository from day one

Every task should have a folder or record: description, owner, outcome, evidence, date, status and link to costs.

3. Connect technical evidence with costs

If a cost relates to penetration testing, there should be a test report, scope, acceptance protocol and budget link.

4. Document partner work

In a consortium, every partner must provide evidence of its tasks, while the coordinator should control completeness.

5. React to risks early

Supplier delay, technical problem, lack of resources or scope change should go into the risk register, not remain an informal conversation.

Grant and cyber resilience: how to connect funding with real impact?

The best grant project increases the cyber resilience of beneficiaries. This means that after the project ends, the organization should be better prepared for threats, not only richer by one document or one-time report.

Cyber resilience impact may mean:

  • shorter incident detection time
  • better vulnerability management
  • more organizations after security testing
  • more SMEs prepared for NIS2 or CRA
  • better data protection
  • tested response procedures
  • trained employees
  • working support model after the project
  • product ready for commercialization

Action plan before submitting an application

First 30 days

  • select the right call and check its objective
  • determine whether the organization is eligible
  • describe cyber problem and target group
  • define project outcome
  • decide whether a consortium is needed
  • check own contribution and funding rate
  • prepare initial budget
  • obtain board decision to start work

Days 31 to 60

  • build detailed scope and work packages
  • assign task owners
  • prepare timeline and milestones
  • collect CVs, experience and team competences
  • describe project risks
  • build KPI model
  • prepare outcome sustainability plan
  • verify compliance with call documentation

Days 61 to 90

  • finalize application and attachments
  • check budget with finance owner
  • check legal and partnership issues
  • perform technical review
  • perform call objective alignment review
  • prepare document repository
  • approve the final version internally
  • submit before the last day

Action plan after the grant is awarded

First 30 days

  • read the grant agreement carefully
  • organize project kick-off
  • confirm roles and responsibilities
  • create operational timeline
  • create decision, risk and change registers
  • create evidence repository
  • define cost description rules
  • prepare first internal report

Days 31 to 60

  • launch work package delivery
  • prepare procurement and subcontracting plan
  • define acceptance protocol format
  • launch partner meeting cycle
  • confirm first outcomes and evidence
  • check expenditure against budget
  • prepare communication and dissemination plan

Days 61 to 90

  • review project risks
  • check milestone delivery
  • prepare trial technical and financial reports
  • close first delays and unclear items
  • check cost documentation completeness
  • prepare report for board or consortium
  • update timeline

Metrics for the board and project team

Delivery metrics

  • percentage of work packages completed
  • number of milestones delivered on time
  • number of formally accepted outcomes
  • number of delays and their impact
  • project risk status

Financial metrics

  • budget utilization
  • costs disputed or requiring clarification
  • costs assigned to work packages
  • own contribution used
  • forecast cost to completion

Cyber metrics

  • number of organizations supported
  • number of tests or assessments performed
  • number of vulnerabilities detected and closed
  • number of people trained
  • number of pilot deployments
  • change in cyber maturity level

Sustainability metrics

  • number of customers or users after project end
  • product or service maintenance plan
  • revenue or financing model after the project
  • number of partners continuing cooperation
  • number of outcomes used after funding ends

Common board questions before the project

  • does the project fit company strategy?
  • what own contribution do we need to provide?
  • do we have people to deliver?
  • will the grant create costs we cannot maintain later?
  • will the project increase revenue, resilience or regulatory readiness?
  • do we have competence to settle the project?
  • what happens if one milestone is not delivered?
  • are legal, tax and financial risks known?

Business example

A Polish cybersecurity company develops a tool helping SMEs prepare for NIS2 and CRA. The tool supports asset inventory, supplier assessment, risk register, training and compliance evidence. The company sees a Digital Europe call and wants to apply.

The first version of the application is too generic. It describes a “cyber platform for SMEs”, but does not identify a specific beneficiary group, KPIs, pilot, sustainability model and evidence. After a workshop, the scope is narrowed: the project includes a platform, training module, expert hotline, pilot in 50 SMEs and impact report. The budget is assigned to work packages, while a research partner owns the maturity assessment methodology.

After receiving the grant, the company launches an evidence repository, meeting cycle, risk register, progress reporting and acceptance protocols. It does not wait with documentation until the end of the project. After several months, it can show which SMEs used the tool, which gaps were identified, which training was completed and which outcomes were deployed.

Related CCyber resources and services

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

  • CCyber Blog - related articles on grants, NIS2, CRA, DORA, cyber resilience, MFA, backup, AI, suppliers and audits.
  • Cyber consulting - audit, strategy, implementation and cybersecurity maturity development.
  • EU regulatory compliance - preparation for NIS2, DORA, CRA, ISO 27001 and customer requirements.
  • NIS2 compliance programme - applicability assessment, gap assessment, documentation, evidence, roadmap and audit readiness.
  • Secure IT deployments - support for IT, AI and cloud 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, IT, boards and teams delivering cyber projects.

How can ccyber.io help?

ccyber.io helps organizations prepare cybersecurity project scope, plan budgets, define outcomes, collect evidence, implement solutions and translate funding into a real increase in cyber resilience. We can support both organizations applying for grants and beneficiaries that already received funding and must deliver the project properly.

We can support your organization with:

  • cyber project idea assessment
  • 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
  • technical documentation support
  • cyber audit and security testing as project components
  • MFA, backup, EDR, IAM, asset inventory and procedure implementation
  • training, tabletop and educational materials
  • 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 determine whether the idea fits the funding programme, which outcomes should be planned, which costs are logical and which evidence should be collected from the first day of the project.

FAQ

Can a cybersecurity grant fund tool purchases?

Sometimes yes, but it depends on the rules of the specific call. The purchase must be part of a project with a clear objective, outcome, beneficiary and justification, not only a shopping list.

Can SMEs apply independently?

In some calls yes. In others, a consortium is recommended or practically useful. The call documentation and eligibility requirements must always be checked.

Does the project have to relate to NIS2 or CRA?

Not always, but many current cyber calls support solutions helping organizations meet regulatory requirements, including NIS2 and CRA. Alignment with regulations often strengthens project justification.

What matters more: good idea or good delivery?

Both matter. A good idea can fail because of weak scope, budget and missing evidence. A good grant project must be needed, feasible and reportable.

What most often causes problems after receiving a grant?

No project manager, weak documentation, unclear partner roles, underestimating reporting, delays, missing evidence and uncontrolled scope changes.

Does AI in a cyber project improve chances?

It can improve project attractiveness if AI is justified and securely designed. Simply adding AI to an application without clear function, data, controls and AI Act compliance may weaken the project.

How can cyber project impact be proven?

Through measurable outcomes: number of tests, deployments, trained people, closed vulnerabilities, reduced response time, improved maturity, technical reports, acceptance protocols and pilot results.

Where should we start?

Start with alignment between the idea and the call objective. Then define beneficiary, outcome, budget, partners, KPIs, risks and evidence that will prove the project was delivered.

Summary

Cybersecurity grants from the Digital Europe Programme and NCC-PL initiatives can be an important accelerator for Polish companies, SMEs, cyber providers, the public sector, healthcare and organizations preparing for NIS2, CRA, DORA and AI Act. They can support tools, services, training, tests, platforms and new skills.

However, the grant should not be treated as one-time funding for a purchase. It should be a project with a real outcome, beneficiary, metrics, timeline, evidence and sustainability plan. A well-delivered project does not only end with successful reporting. It leaves behind stronger cyber resilience.

The best rule is: do not write a project for the money. Write it for a problem that truly needs to be solved, and treat funding as a tool to reach the outcome faster and with better documentation.

Sources

National Cybersecurity Rules in Local Government: What Are Mayors and Local Leaders Responsible For?

The amended Polish national cybersecurity framework turns local government cybersecurity from a purely technical issue into a leadership accountability issue. A mayor, city president, county leader or head of an entity should no longer ask only whether IT “secured something”. They should know whether the entity is in scope, registered, connected to the S46 system, has an ISMS, risk register, incident procedure, backup, MFA, supplier assessment, training, AI rules and evidence of execution. The biggest risk is not the lack of a document, but the lack of an operating process, owners and management decisions before an incident.

Prepared by: CCyber Editorial Team

Short answer

The amended Polish national cybersecurity framework means that cybersecurity in local government can no longer be treated as a task for one IT person or IT provider. A mayor, city president, county leader, regional leader or head of an entity must understand whether the entity is in scope, what obligations apply, who owns the risk, how incidents are reported, whether backup works, who has administrative access, which suppliers are critical and whether employees know how to use AI safely. The most important elements are an information security management system, incident procedures, compliance evidence and recurring management reporting. Leadership accountability means decisions, oversight and evidence, not manual technical execution.

Last updated

July 2026

Who this article is for

  • mayors, city presidents, county leaders and regional government leaders
  • secretaries, treasurers, office directors and heads of organizational units
  • IT staff, system administrators and people responsible for local government IT
  • DPOs, compliance, internal audit, management control and legal teams
  • local government units preparing for national cybersecurity rules and NIS2
  • local government organizational units, cultural institutions, schools, municipal companies and shared service centres
  • IT, cloud, backup, domain system, e-service and cybersecurity providers serving local governments
  • people preparing incident procedures, ISMS, training, audits and evidence documentation

Key takeaways

  1. Cybersecurity in local government is not only a technical duty. It is a management and organizational duty.
  2. Leadership must know whether the entity is essential or important, whether it must be registered and which deadlines apply.
  3. The key pillars are ISMS, risk register, incident procedure, S46 system, backup, MFA, suppliers, training and evidence.
  4. Shadow AI is becoming a real local government risk because employees may unknowingly enter resident data into public AI tools.
  5. A good mayor or local leader does not need to be a technical expert, but must ask the right questions, make decisions and require reports.

What is changing?

The amended Polish national cybersecurity framework, implementing NIS2, changes how local government should think about cybersecurity. Cybersecurity is no longer a server room topic. It is part of continuity of public services, protection of resident data, trust in the office, security of e-services and management accountability.

Local government now operates digitally: ePUAP, e-delivery, tax systems, resident registers, financial systems, public information bulletin, email, document workflow, education systems, municipal services, monitoring, healthcare systems and platforms for communication with residents. An attack on these systems is not only an IT issue. It may mean interruption of services, data leakage, communication chaos and leadership accountability.

Why can a mayor not delegate all accountability to IT?

IT can implement safeguards, administer systems and respond technically. But IT should not independently decide on risk acceptance, budget, public service priorities, resident communication, regulatory notifications, supplier relationships or accountability for data.

Management decisions include:

  • whether the entity is in scope
  • who owns the cybersecurity programme
  • what budget is allocated to safeguards
  • which systems are critical for the office
  • which risk can be accepted
  • when to activate the crisis procedure
  • when to inform residents
  • which requirements to impose on suppliers
  • how remediation actions are tracked

This is why national cybersecurity rules move cybersecurity to leadership level. Not so that the mayor configures a firewall, but so that the office has real oversight of risk.

Who in local government may be affected?

In practice, the analysis should cover not only the municipal, county or city office. Local government is an ecosystem of many units, suppliers and services. Some entities may be registered by the authorities, some may require individual analysis and some may be indirectly affected through contracts or sector rules.

Entities to check include:

  • municipal, city, county or regional office
  • local government organizational units
  • shared service centres
  • local government cultural institutions
  • schools and education institutions
  • municipal service entities
  • water and wastewater providers
  • public transport
  • municipal companies
  • healthcare entities run by local government
  • IT providers and domain system operators

Key dates for leadership

Deadlines matter because they show that preparation cannot be postponed until the end of the year. A local government entity should maintain an obligations calendar and report its status to leadership.

Key dates

  • 3 April 2026 - entry into force of the amended national cybersecurity law.
  • 13 April 2026 - launch of the national register of essential and important entities.
  • 13 April - 6 May 2026 - registrations carried out by the Minister of Digital Affairs for selected categories of entities.
  • 7 May - 3 October 2026 - self-registration for entities not registered by the authorities.
  • 12 June 2026 - start of access to the S46 system for new entities.
  • 3 April 2027 - deadline for implementing obligations and starting S46 use by entities that met the criteria on the date of entry into force.
  • 3 April 2028 - deadline for the first mandatory audit for selected essential entities and start of financial penalty provisions.

What must a local government do step by step?

1. Determine entity status

The first task is to assess whether the office or unit is an essential entity, important entity, entity registered by the authorities, entity requiring self-registration or entity indirectly affected through relationships with other units or suppliers.

What to prepare?

  • applicability assessment for national cybersecurity rules and NIS2
  • list of local government units and companies
  • list of public and digital services
  • list of sectors where the entity operates
  • decision on who owns registration or data completion

2. Register or complete register data

Registration is the first formal step for many entities. Some entities may be registered by the authorities, but this does not remove the obligation to complete data and implement further duties.

What should leadership do?

  • determine whether the entity waits for authority registration or submits an application
  • appoint the person responsible for the registration process
  • check electronic signature and authorizations
  • secure access to correspondence and systems
  • monitor deadlines and confirmations

3. Connect to the S46 system

The S46 system is intended, among other things, for incident reporting, receiving warnings and communicating with competent authorities in the national cybersecurity system. A local government should treat S46 as an operational channel, not only a formal platform.

What to prepare?

  • primary and deputy S46 operators
  • procedure for using the system
  • connection between S46 and incident procedure
  • list of people approving notifications
  • after-hours instruction
  • secure storage of access data

4. Implement an ISMS

An information security management system should be a working system, not a folder of documents. It should include risks, policies, procedures, roles, evidence, reviews and remediation actions.

ISMS elements in local government

  • system scope
  • information security policy
  • asset register
  • risk register
  • risk treatment plan
  • incident procedure
  • access and permission procedures
  • backup and recovery procedure
  • supplier assessment
  • training and cyber hygiene
  • reviews and audits

5. Build a cyber risk register

Local government leadership should see risks in the language of impact on public services, residents and business continuity, not only in technical language.

Example risks

  • ransomware blocking the office and document workflow
  • email account takeover of the mayor, secretary or treasurer
  • leakage of resident data
  • missing backup restore test
  • excessive access of an IT provider
  • no MFA for email and administrators
  • shadow AI and entering sensitive data into chatbots
  • old domain system without support
  • no incident notification procedure within 24 hours

6. Prepare incident and reporting procedure

The incident procedure should answer: who detects, who classifies, who escalates, who reports, who communicates and who makes business decisions. Under national cybersecurity rules, incident reporting to CSIRTs and use of proper channels, including S46, is important.

The procedure should include:

  • definitions of event, incident and significant incident
  • incident classification matrix
  • incident team roles
  • CSIRT reporting path
  • DPO and GDPR path
  • insurer path if a policy exists
  • notification templates
  • incident timeline
  • final report and lessons learned

7. Prepare backup and restore testing

Local governments often use many domain systems and documents whose loss may paralyze work. Backup without restore testing is not sufficient resilience evidence.

What should be checked?

  • which systems are backed up
  • whether backup includes critical systems
  • whether backup is protected from ransomware
  • whether backup accounts have MFA
  • whether a restore test has been performed
  • how long system recovery takes
  • whether backup includes supplier-held data

8. Organize access and MFA

Compromise of email, administrator or IT provider account is one of the easiest ways into an organization. MFA should be treated as a baseline requirement, especially for email, administrators, VPN, finance systems, backup and remote access.

Access minimum

  • administrator list
  • MFA for critical accounts
  • no shared accounts where possible
  • periodic access review
  • offboarding procedure
  • supplier account control
  • administrator action logging

9. Assess IT and domain system suppliers

Many local governments use external providers for tax systems, finance, document workflow, public information bulletin, email, backup, hosting, e-services, IT support and cybersecurity. Their risk is the entity’s risk.

What should supplier assessment include?

  • which systems the supplier maintains
  • whether the supplier has remote access
  • whether access is protected by MFA
  • whether supplier actions are logged
  • how the supplier reports incidents
  • whether the supplier has a continuity plan
  • where data is located
  • whether subcontractors are used
  • what the exit plan looks like

10. Set rules for AI use

Shadow AI in local government means employees using AI tools without organizational knowledge and rules. The most risky scenario is entering resident data, administrative decision data, medical information, children’s data, social assistance records or internal documents into public chatbots.

Minimum AI rules in the office

  • do not enter personal or sensitive data into public AI tools without approval and legal basis
  • do not treat AI output as an administrative decision
  • verify AI-generated content
  • mark tools approved for work
  • train employees on AI risks
  • report suspicious AI use or AI-related incidents
  • connect AI policy with GDPR, national cybersecurity rules and the AI Act

Which questions should a mayor or city president ask?

The head of an entity does not need to know system administration commands, but must ask the right questions. This is the simplest way to translate accountability into oversight.

Monthly questions

  • do we have new high or critical risks?
  • were there incidents or near misses?
  • does backup for critical systems work?
  • has a restore test been performed?
  • are there administrator accounts without MFA?
  • are there overdue critical vulnerabilities?
  • have suppliers completed remediation actions?

Quarterly questions

  • are we on track with national cybersecurity deadlines?
  • is the risk register current?
  • has the incident procedure been tested?
  • have employees been trained?
  • do we have audit evidence?
  • does the AI policy work in practice?
  • is the cybersecurity budget adequate to the risk?

Which evidence should a local government have?

Formal evidence

  • applicability assessment
  • confirmation of registration or data completion
  • appointment of contact persons
  • ISMS documentation
  • information security policy
  • management order or decision
  • leadership report

Technical evidence

  • MFA report
  • backup report
  • restore test report
  • critical system list
  • asset register
  • vulnerability report
  • administrator logs
  • EDR or antivirus report

Operational evidence

  • risk register
  • incident register
  • incident response plan
  • tabletop report
  • supplier register
  • supplier assessments
  • access review
  • training report
  • remediation action list

Shadow AI in the office: why is this a national cybersecurity, GDPR and AI Act topic?

Shadow AI is especially dangerous in administration because public offices process resident data and handle matters that may involve taxes, social assistance, education, healthcare, real estate, complaints, permits and administrative proceedings. Using a private chatbot to draft a letter may seem harmless, but it can cause confidentiality breach, incorrect content, unauthorized data processing or lack of control over where information goes.

What should the office do?

  • prepare an AI use policy
  • define which tools are approved
  • prohibit entering personal data into unapproved tools
  • train employees and department managers
  • define AI incident reporting procedure
  • connect AI with risk assessment and GDPR
  • check whether system providers use AI

How to prepare the office for an incident?

Scenario 1: ransomware in the office

The document workflow system, network share and some computers are encrypted. Email is unstable. Residents cannot handle some matters. The office must decide whether to activate emergency work, report the incident, inform leadership and recover data.

Scenario 2: treasurer account takeover

An attacker gains access to email and tries to change a bank account number in correspondence with a contractor. Fast account blocking, email analysis, payment verification and finance communication are needed.

Scenario 3: resident data leak

A file containing resident personal data was sent to the wrong recipient or entered into an external AI tool. The office must assess GDPR, national cybersecurity rules, duties toward people, evidence and remediation actions.

Scenario 4: domain system supplier outage

A tax or e-service system provider has an incident and the system is unavailable. The office must know whether it has a workaround, emergency contact, SLA, data backup and resident communication plan.

Minimum cybersecurity programme for local government

Governance

  • cybersecurity programme owner
  • reporting to the mayor, city president or leadership
  • leadership decisions and minutes
  • risk review cycle

Risk and assets

  • cyber risk register
  • critical systems and services register
  • data register
  • supplier register
  • privileged account list

Technical minimum

  • MFA for critical accounts
  • backup and restore test
  • EDR or endpoint protection
  • updates
  • log monitoring
  • email protection

Procedures

  • incident response plan
  • incident reporting procedure
  • BCP and DRP
  • supplier access procedure
  • AI policy
  • training and cyber hygiene procedure

Metrics for local government leadership

Compliance metrics

  • registration or data completion status
  • S46 connection status
  • ISMS implementation status
  • number of requirements without evidence
  • audit readiness status

Security metrics

  • percentage of critical accounts with MFA
  • date of latest restore test
  • number of overdue critical vulnerabilities
  • number of critical systems without owner
  • number of suppliers with privileged access

Incident metrics

  • number of incidents and near misses
  • time from detection to escalation
  • time to prepare 24h notification
  • number of reported suspicious messages
  • number of actions after lessons learned

People and AI metrics

  • percentage of employees trained in cyber hygiene
  • phishing simulation result
  • number of employees trained in safe AI use
  • number of AI policy breach reports
  • number of organizational units without data owner

30, 60 and 90-day action plan

First 30 days

  • assign a cybersecurity programme owner in the entity
  • determine whether the office or unit is subject to registration
  • check registration by authority or need for self-registration
  • prepare a list of critical systems, data, services and suppliers
  • check MFA for email, administrators, VPN and finance systems
  • check backup and latest restore test
  • identify employee AI use
  • present the first gap report to leadership

Days 31 to 60

  • prepare or update ISMS
  • create cyber risk register
  • prepare incident and reporting procedure
  • appoint contact persons and deputies
  • prepare AI use policy
  • perform access review for critical accounts
  • assess key IT suppliers
  • launch cyber hygiene training for employees

Days 61 to 90

  • run ransomware or data leak tabletop
  • test CSIRT and S46 reporting path
  • perform or repeat restore test for a critical system
  • update BCP and DRP
  • prepare audit evidence pack
  • close key technical and organizational gaps
  • prepare report for the mayor, city president or county leadership
  • approve 12-month cybersecurity roadmap

Common local government mistakes

Mistake 1: treating cybersecurity as an IT-only matter

IT is important, but national cybersecurity rules concern leadership accountability, data, public services, suppliers, incidents, audits and communication.

Mistake 2: no status assessment

The entity assumes it is not in scope or waits for an official notification. Meanwhile, the obligation to assess and act may sit with the entity.

Mistake 3: documents without operation

A security policy without restore testing, access review, training, risk register and remediation actions does not create real resilience.

Mistake 4: no deputies

One person has access to the system, procedures and contacts. When they are on leave, the office cannot report an incident.

Mistake 5: untested backup

Backup exists, but nobody knows whether the finance system, document workflow or domain system data can be restored.

Mistake 6: no supplier control

The IT provider has remote access, but nobody knows whether it has MFA, whether actions are logged and how it reports incidents.

Mistake 7: ignoring shadow AI

Employees use private chatbots to draft letters and summarize documents, while the office has no rules, training or risk assessment.

Mistake 8: no leadership report

Leadership does not receive information about risks, gaps and actions. Without reporting, it is difficult to demonstrate oversight and due diligence.

Practical example

A medium-sized city office uses a document workflow system, tax system, finance and accounting system, e-delivery, public information bulletin, email, education systems and several external providers. Leadership knows that the amended law applies, but assumes the topic is under control because the office has IT staff and an external IT provider.

The first review shows that there is no current risk register, backup has not been tested for a year, some administrator accounts do not have MFA, the IT provider uses a shared account and employees use public AI tools to draft letters. There is also no incident notification template and no deputy for the main IT person.

The office implements a 90-day plan: applicability assessment, critical service register, MFA, restore test, incident procedure, AI policy, supplier assessment, training and tabletop. After three months, leadership receives a report with risks, remediation actions and evidence. This does not finish the work, but it turns cybersecurity from informal trust in IT into a managed oversight system.

Related CCyber resources and services

This topic can be connected with further reading and CCyber services to move from awareness of accountability to concrete action in local government.

How can ccyber.io help?

ccyber.io helps local governments and public entities translate national cybersecurity rules into a practical programme of actions, evidence and oversight. We combine legal, technical, organizational and management perspectives so leadership knows what has been implemented, what requires a decision and what risk remains.

We can support your organization with:

  • applicability assessment for national cybersecurity rules and NIS2
  • preparation for registration and S46 system use
  • ISMS design and implementation
  • cyber risk register and risk treatment plan
  • incident response plan and incident reporting procedure
  • BCP, DRP, backup and restore testing
  • assessment of IT, cloud, SaaS and domain system suppliers
  • AI use policy and shadow AI control
  • MFA, access review, asset inventory and IAM
  • cyber hygiene training for employees and leadership
  • ransomware, data leak or supplier incident tabletop
  • audit evidence pack and leadership report
  • 30, 60, 90-day and 12-month roadmap

The best first step is a KSC Readiness Workshop for local government. In a short workshop, the entity can define its status, key obligations, security gaps, shadow AI risks, required evidence and action priorities before the next statutory deadlines.

FAQ

Does a mayor need to be a cybersecurity expert?

No. They must ensure oversight, owners, budget, decisions, reporting and evidence. Leadership accountability means risk management, not technical system configuration.

Is it enough for the office to have IT staff or an external IT provider?

No. IT staff or a provider can perform technical tasks, but the office still needs an ISMS, procedures, risk register, leadership oversight, supplier control, training and evidence.

Does every local government entity need to register itself?

Not always. Some entities are registered by the authorities, while others may require self-registration. Every entity should assess its status and not assume automatically that the obligation does not apply.

What is most urgent for local government?

Status assessment, registration, contact persons, S46, ISMS, critical system register, MFA, backup, restore testing, incident procedure, supplier assessment and employee training.

What is S46 in practice?

S46 Cyber Hub is a platform used, among other things, for incident reporting, receiving warnings and exchanging cyber threat information with competent authorities in the national cybersecurity system.

Why is shadow AI a risk for local government?

Employees may enter resident data, sensitive data or official documents into public AI tools without control. This may violate information security, GDPR, national cybersecurity rules and responsible AI use principles.

Which evidence should the head of the entity see?

MFA report, backup and restore test report, risk register, critical system register, supplier register, incident procedure, training report, access review and remediation action status.

Where should a small municipality start?

Start with a simple review: status under national cybersecurity rules, critical systems, resident data, IT suppliers, administrator accounts, MFA, backup, incident procedure and employee training. Then build an ISMS and action roadmap.

Summary

National cybersecurity rules in local government change the level of accountability. Cybersecurity is no longer only a technical issue. It is part of public service management, resident data protection, business continuity and leadership accountability.

A mayor, city president, county leader or head of an entity does not need to do an administrator’s job, but must know whether the entity has a functioning information security management system, incident procedures, backup, MFA, assessed suppliers, AI rules, training and evidence. Without this, demonstrating due diligence will be difficult.

The best rule is: do not ask only whether the office has IT staff. Ask whether the office has a system that can detect an incident, report it on time, recover services, protect resident data and show leadership a real picture of risk.

Sources

What Must a Company Do Under NIS2? 10 Obligations, Evidence and Priorities Based on ENISA NIS360

NIS2 is not about one document or a one-time audit. A company in scope must build an operating cyber risk management system: risk register, security policies, incident procedure, business continuity, backup, supplier assessment, vulnerability management, training, cryptography, access control, asset management, MFA and board reporting. ENISA NIS360 shows that cybersecurity maturity in EU critical sectors is improving, but unevenly. The key is a proportionate approach: start with critical services, risks, evidence and actions that truly reduce incident impact.

Prepared by: CCyber Editorial Team

Short answer

A company in scope of NIS2 must do more than prepare a security policy. It must implement and maintain proportionate technical, operational and organizational measures to manage cyber risk and reduce incident impact on customers, users, other services and the supply chain. In practice, this means 10 areas: risk analysis and information security policies, incident handling, business continuity, supplier security, acquisition and maintenance security, effectiveness assessment, cyber hygiene and training, cryptography, HR security, access control and asset management, plus MFA and secure communications. In addition, board oversight, significant incident reporting, compliance evidence and regular reviews are required. The key is not having documents, but being able to show that the process works.

Last updated

July 2026

Who this article is for

  • boards and business owners checking NIS2 obligations
  • essential and important entities preparing for national cybersecurity rules
  • CISOs, vCISOs, CIOs, CTOs and people responsible for IT and security
  • compliance, risk, legal, DPO, internal audit and internal control teams
  • SMEs operating in NIS2 sectors or supplying entities in scope
  • IT providers, MSPs, MSSPs, SaaS, cloud, hosting, backup and integration providers
  • companies in healthcare, transport, public administration, ICT, water, energy, finance and manufacturing
  • organizations preparing for customer audits, cyber insurance, ISO 27001, DORA or CRA

Key takeaways

  1. NIS2 requires an operating cyber risk management system, not a one-time document.
  2. The foundation is 10 Article 21 areas: risk, incidents, continuity, suppliers, system security, effectiveness, training, cryptography, access and MFA.
  3. The board must oversee cybersecurity measures and receive understandable risk reports.
  4. Every obligation should have an owner, evidence, review frequency and remediation action.
  5. ENISA NIS360 shows that critical sectors have different maturity levels, so companies should prioritize actions according to service criticality and real incident impact.

First: is your company in NIS2 scope?

Before building a NIS2 programme, the company must check whether it is directly, indirectly or contractually affected. This matters because an essential or important entity has different duties from a smaller supplier receiving requirements from a NIS2 customer.

Check four elements

  • Sector: whether you operate in a NIS2 annex sector, such as energy, transport, healthcare, digital infrastructure, ICT services, public administration, space, manufacturing, food, chemicals, waste, postal services or digital services.
  • Size: whether the company meets medium-sized or large enterprise thresholds or falls under a size-independent exception.
  • Role: whether you are a service operator, ICT provider, subcontractor, cloud provider, MSP, MSSP, SaaS or supplier to a regulated entity.
  • Country: NIS2 is a directive, so obligation details must be checked in national law.

Indirect applicability also matters

Even if a company is not directly in scope of NIS2, it may receive requirements from a customer. This especially concerns IT providers, software houses, SaaS, cloud, hosting, maintenance, backup, SOC, MDR, OT integrators, logistics companies, laboratories, healthcare subcontractors and providers serving public administration.

What does ENISA NIS360 show?

ENISA NIS360 is not a checklist for an individual company. It is a sectoral report that helps understand where high criticality sectors stand in terms of cybersecurity maturity and criticality for society and the economy.

ENISA assesses two dimensions

  • Maturity: how effectively and consistently the sector manages cyber risks and develops security capabilities.
  • Criticality: how important the sector is for society and the economy and how serious the consequences of disruption would be.

Four ENISA maturity dimensions

  • policy frameworks and guidance
  • risk management and good practices
  • collaboration and information sharing
  • operational preparedness, including tests, incident response and BCP

Why this matters for companies

The report shows that cybersecurity maturity in critical sectors is improving, but unevenly. ENISA identifies a risk zone, meaning sectors where criticality exceeds maturity. These include health, railway, maritime, ICT service management, space, public administrations, and drinking water and wastewater.

For a company, the conclusion is simple: if you operate in a high criticality sector or provide services to such entities, you must organize governance, risk, incidents, suppliers and business continuity faster.

Why is ENISA NIS360 practical for the board?

Boards often ask: where should we start if NIS2 is so broad? ENISA NIS360 suggests a way of thinking. Do not start with documents. Start with how critical your service is, how mature your current cybersecurity model is and how large the gap is between service importance and organizational readiness.

Practical board questions

  • are our services more critical than our safeguards are mature?
  • do we have known risks without owners?
  • could our incident affect customers, citizens or other sectors?
  • is our IT, cloud or MSSP provider a single point of failure?
  • can we report an incident on time?
  • has backup really been tested?
  • does the board receive a risk report, not only a technical IT report?

10 NIS2 obligations in practice

Article 21 is the operational core of NIS2. Below is a practical translation of the 10 areas into actions and evidence a company should prepare.

1. Risk analysis and system security policies

The company must know which cyber risks matter most, how they affect services and which mitigation actions are planned. The risk register cannot be a file created once before an audit. It must be updated after changes, incidents, audits and new requirements.

What to implement?

  • risk assessment methodology
  • cyber risk register
  • risk owners
  • risk treatment plan
  • information security policy
  • map of critical systems and services
  • recurring risk review

Evidence

  • risk register with review date
  • risk acceptance decisions
  • board report
  • remediation action list
  • approved security policies

2. Incident handling

NIS2 requires preparation for detecting, analyzing, containing, reporting, handling and recovering from incidents. The incident procedure should operate before an attack, not be written during ransomware.

What to implement?

  • incident response plan
  • incident team roles and responsibilities
  • ransomware playbook
  • email takeover playbook
  • supplier incident playbook
  • incident and near miss register
  • lessons learned procedure

Evidence

  • incident response plan
  • tabletop report
  • incident register
  • incident timeline
  • post-incident report
  • corrective actions

3. Business continuity, backup, disaster recovery and crisis management

Backup without restore testing is only a declaration. NIS2 requires operational resilience, meaning the ability to maintain or recover services after an incident.

What to implement?

  • BCP for critical services
  • DRP for critical systems
  • backup policy
  • RTO and RPO
  • restore tests
  • crisis communication plan
  • emergency work procedure

Evidence

  • backup report
  • restore test report
  • BCP and DRP
  • priority service list
  • business continuity exercise report
  • board decisions on RTO and RPO

4. Supply chain security

An IT, cloud, SaaS, backup, SOC, finance system or OT integrator can be either the source of an incident or a condition for recovery. NIS2 requires security aspects of relationships with direct suppliers and service providers to be considered.

What to implement?

  • supplier register
  • supplier criticality classification
  • supplier risk assessment
  • security requirements in contracts
  • supplier access control
  • supplier incident notification process
  • exit plans for critical suppliers

Evidence

  • critical supplier register
  • supplier risk assessment
  • security questionnaire
  • contract with security clauses
  • supplier access review
  • exit plan

5. Security in acquisition, development and maintenance of systems

Security must be considered when buying, implementing, developing and maintaining systems. This applies both to internally developed applications and purchased SaaS or systems delivered by external providers.

What to implement?

  • secure IT procurement process
  • security-by-design requirements
  • secure SDLC
  • vulnerability management
  • vulnerability handling and disclosure process
  • application security testing
  • change control

Evidence

  • change management procedure
  • vulnerability scan report
  • penetration test report
  • vulnerability and remediation register
  • retest after remediation
  • security requirements in a project

6. Assessing the effectiveness of cybersecurity measures

NIS2 cannot be satisfied on paper. The company must have policies and procedures to assess whether safeguards work. This means measuring, testing and improving.

What to implement?

  • effectiveness testing plan
  • cybersecurity KPIs and KRIs
  • regular control reviews
  • internal audit
  • tabletop exercises
  • vulnerability scans
  • remediation review

Evidence

  • control effectiveness report
  • internal audit report
  • test results
  • MFA, backup, EDR, vulnerability and incident metrics
  • nonconformity and corrective action list

7. Cyber hygiene and training

Cyber hygiene is not an add-on. It is an obligation. Employees must recognize phishing, know how to report incidents, use MFA, protect data and understand basic rules of working with technology.

What to implement?

  • training programme for all employees
  • board training
  • training for IT and administrators
  • phishing simulations
  • BEC training for finance
  • safe AI use training
  • channel for reporting suspicious messages

Evidence

  • training plan
  • participant list
  • knowledge test results
  • phishing simulation report
  • training materials
  • phishing reporting metrics

8. Cryptography and encryption

The company should know where encryption is used, how it protects data at rest and in transit, who manages keys and which data requires special protection.

What to implement?

  • cryptography policy
  • disk encryption for portable devices
  • transmission encryption
  • backup encryption
  • key management
  • data classification
  • exception procedure

Evidence

  • device encryption report
  • TLS configuration report
  • cryptography policy
  • key register or key management model description
  • data classification report

9. HR security, access control and asset management

The company must know who has access, to what, why and when access was reviewed. It must also know which assets it has: systems, applications, devices, data, accounts, suppliers and public-facing assets.

What to implement?

  • onboarding and offboarding procedure
  • asset register
  • privileged account register
  • access review
  • least privilege principle
  • supplier account control
  • asset retirement process

Evidence

  • asset register
  • access review report
  • administrator account list
  • list of removed permissions
  • offboarding evidence
  • accounts without owner report

10. MFA, secure communication and emergency communication

MFA is one of the key safeguards against account takeover. NIS2 refers to MFA or continuous authentication, secure voice, video and text communications, and secure emergency communication systems where appropriate.

What to implement?

  • MFA for email
  • MFA for administrators
  • MFA for VPN and remote access
  • MFA for cloud and backup
  • secure crisis communication channels
  • emergency contact list
  • communication procedure for email outage

Evidence

  • MFA report
  • MFA exception list
  • emergency communication procedure
  • emergency channel test
  • crisis contact list

Board oversight: the obligation often underestimated

NIS2 brings cybersecurity into the boardroom. Management cannot treat cyber as a technical IT problem. It must approve risk management measures, oversee their implementation and understand the consequences of non-compliance.

The board should receive reports on:

  • top cyber risks
  • NIS2 and national cybersecurity compliance status
  • incidents and near misses
  • backup and restore test status
  • overdue critical vulnerabilities
  • supplier risk
  • remediation progress
  • exceptions and risk acceptances
  • audit readiness

Good evidence of board oversight

A presentation alone is not good evidence. Good evidence is minutes, a decision, risk approval, allocated budget, action owner and deadline.

Incident reporting: 24 hours, 72 hours, final report

NIS2 requires reporting significant incidents according to a defined cycle. The company should have the procedure ready beforehand, because during ransomware or account takeover there is no time to search for the reporting channel.

Minimum reporting cycle

  • early warning within 24 hours of becoming aware of a significant incident
  • incident notification within 72 hours with an update and initial impact assessment
  • intermediate report upon request from the CSIRT or competent authority
  • final report no later than one month after the incident notification

What to prepare before an incident?

  • incident classification matrix
  • competent CSIRT or authority
  • access to reporting channel
  • contact person and deputy
  • 24h and 72h notification templates
  • final report template
  • procedure for communication with DPO, customers and insurer

Polish context: national cybersecurity rules, register and S46 system

In Poland, NIS2 obligations must be read through national cybersecurity legislation. Entities covered by the amended law should analyze their activities according to sectors, enterprise size criteria and statutory provisions. In practice, this means preparing not only for “NIS2 compliance”, but for concrete national obligations, deadlines, registration, reporting channels and audits.

What should companies in Poland check?

  • whether they are essential or important entities
  • whether they must register in the national cybersecurity register
  • whether they must connect to the S46 system
  • when they must implement an information security management system
  • how they must report incidents to CSIRTs
  • who is responsible for contacts with national cybersecurity entities
  • whether and when they must perform a mandatory cybersecurity audit

What does ENISA NIS360 mean for specific sectors?

Healthcare

The health sector remains in the risk zone. For hospitals, clinics, laboratories and medical suppliers, this means priority for backup, business continuity, patient data protection, legacy system protection, monitoring and ransomware procedures.

Public administration

Public administration is highly targeted and often has uneven maturity. Local governments and smaller units should start with basics: MFA, backup, incident procedure, system register, supplier assessment and training.

ICT service management

MSPs and MSSPs are critical for other sectors. Their weaknesses can transfer risk to customers. Managed service providers should therefore focus especially on patch management, segmentation, data security, operational preparedness and their own supplier security.

Railway and maritime transport

Transport operates in complex environments with many stakeholders, OT, IT and supplier dependencies. Priorities should include segmentation, remote access, continuity plans, OT security and supplier incident scenarios.

Drinking water and wastewater

Service availability is directly connected with public safety. OT protection, remote access, configuration backup, emergency plans and exercises involving management and technical suppliers are important.

Finance

Finance is one of the most mature sectors, but this does not mean risk is low. DORA, NIS2, fraud, deepfakes, mobile malware, business continuity, ICT suppliers and operational resilience require continuous improvement and testing.

Most important NIS2 compliance evidence

An auditor, customer, authority or board will not only want to hear that “NIS2 is implemented”. They will want evidence. The best compliance programme generates evidence during normal work.

Minimum evidence pack

  • NIS2 and national cybersecurity applicability assessment
  • cyber risk register
  • asset and critical service register
  • information security policy
  • incident response plan
  • incident reporting procedure
  • backup and restore test report
  • BCP and DRP
  • supplier register and risk assessments
  • MFA report
  • access review
  • training report
  • vulnerability report
  • control effectiveness metrics
  • board report
  • remediation action register

How to prioritize actions?

NIS2 covers many areas. A company, especially an SME, should not try to do everything at once without priority. First, it should protect what has the highest impact on critical services and reporting duties.

Priority 1: critical services

  • which services must operate?
  • which systems support them?
  • where is the data?
  • which suppliers are essential?
  • how long can we operate without this service?

Priority 2: accounts and access

  • MFA for critical accounts
  • administrator list
  • access review
  • supplier account control
  • removal of former employee accounts

Priority 3: backup and recovery

  • backup of critical systems
  • backup account protection
  • restore test
  • RTO and RPO
  • ransomware recovery plan

Priority 4: incidents and reporting

  • incident response plan
  • escalation channels
  • competent CSIRT
  • reporting templates
  • tabletop

Priority 5: suppliers

  • critical supplier register
  • risk assessment
  • security clauses
  • supplier access
  • exit plan

30, 60 and 90-day action plan

First 30 days

  • assign NIS2 programme owner
  • perform NIS2 and national cybersecurity applicability assessment
  • identify critical services and systems
  • create initial risk register
  • check MFA for email, administrators, VPN and cloud
  • check backup for critical systems
  • collect critical supplier list
  • present first gap report to the board

Days 31 to 60

  • prepare or update information security policy
  • prepare incident response plan
  • define incident reporting procedure
  • perform data restore test
  • perform access review for critical accounts
  • assess key suppliers
  • launch cyber hygiene training
  • create remediation action register

Days 61 to 90

  • run ransomware or supplier incident tabletop
  • test CSIRT reporting path
  • update BCP and DRP
  • define control effectiveness metrics
  • prepare compliance evidence pack
  • close key gaps
  • prepare board report
  • approve 12-month roadmap

Board metrics

Risk metrics

  • number of high and critical risks
  • number of risks without owner
  • number of accepted exceptions
  • number of overdue remediation actions
  • quarterly risk trend

Protection metrics

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

Incident metrics

  • number of incidents and near misses
  • time from detection to escalation
  • time to classify an incident as significant
  • time to prepare 24h notification
  • number of actions after lessons learned

Compliance metrics

  • percentage of NIS2 requirements with assigned owner
  • percentage of requirements with current evidence
  • number of outdated evidence items
  • audit readiness status
  • national cybersecurity obligation status, where applicable

Common company mistakes

Mistake 1: treating NIS2 as a document checklist

Documents are necessary, but NIS2 requires operation. A policy without execution evidence will not defend the organization in an audit or after an incident.

Mistake 2: no applicability assessment

The company assumes it is not in scope because it is too small or not a critical infrastructure operator. This may be wrong, especially for ICT providers, digital services and customer requirements.

Mistake 3: board does not see risk

If the board receives only technical IT reports, it does not truly perform oversight. It needs reports on risk, impact, costs, decisions and actions.

Mistake 4: no owners

A risk without an owner, a system without an owner and a remediation action without an owner mean that the process does not work.

Mistake 5: backup without testing

The company says it has backup, but has never restored a critical system. Under NIS2, resilience matters, not declarations.

Mistake 6: suppliers ignored

An IT, cloud, MSSP, SaaS or backup provider may be critical to company operations. Their risk becomes the organization’s risk.

Mistake 7: no incident reporting procedure

The 24-hour deadline is difficult to meet without a prior classification matrix, template and contact person.

Mistake 8: no effectiveness measurement

The company implements safeguards, but does not measure whether they work. NIS2 requires assessment of the effectiveness of cyber risk management measures.

Business example

A mid-sized logistics company has 180 employees and serves manufacturing and e-commerce customers. It has WMS, ERP, Microsoft 365, VPN, customer integration system, an external IT provider and several SaaS suppliers. The board hears from a large customer that the company must demonstrate NIS2 readiness as a supply chain provider.

The first review shows partial MFA, backup without restore testing, no formal risk register, incomplete supplier list, outdated incident procedure and no board reporting. IT performs many technical actions, but there is no governance evidence.

The company implements a 90-day plan. It creates an applicability assessment, critical service register, risk register, enables MFA for critical accounts, performs a restore test, prepares an incident response plan, assesses key suppliers, trains employees and runs a ransomware tabletop. After three months, the board has a risk report, remediation actions and an evidence pack for the customer. The company is not fully mature yet, but it has moved from declarations to an operating programme.

Related CCyber resources and services

This topic can be connected with further reading and CCyber services to move from NIS2 analysis to concrete organizational action.

How can ccyber.io help?

ccyber.io helps companies translate NIS2 into a practical programme of actions, evidence and board oversight. It is not only about documentation. We help build a system that works in audits, customer discussions and real incidents.

We can support your organization with:

  • NIS2 and national cybersecurity applicability assessment
  • NIS2 gap assessment across the 10 Article 21 areas
  • cyber risk register and risk treatment plan
  • governance programme and board reporting
  • incident response plan and incident reporting procedures
  • BCP, DRP, backup and restore testing
  • supplier and supply chain risk assessment
  • asset inventory, access review, MFA and IAM
  • cyber hygiene programme and board training
  • effectiveness audit of safeguards
  • evidence pack for audit, customer, regulator or insurer
  • 30, 60, 90-day and 12-month roadmap

The best first step is a NIS2 Readiness Workshop. In a short workshop, the company can determine whether it is in scope of NIS2, what gaps exist, which actions are critical and which evidence should be prepared first.

FAQ

Does NIS2 require a specific tool?

No. NIS2 requires appropriate and proportionate technical, operational and organizational measures. A tool can help, but it does not replace owners, processes, decisions, evidence and board oversight.

Is documentation enough?

No. Documentation is necessary, but it must be supported by operating evidence: reports, tests, access reviews, backup restore, training, supplier assessments and board decisions.

Where should NIS2 preparation start?

Start with applicability assessment, critical services, risk register, MFA, backup, incident procedure, suppliers and board reporting.

Is the board responsible for NIS2?

Yes. The board should approve and oversee cyber risk management measures and receive regular reports. Cybersecurity cannot be only an IT issue.

Which NIS2 evidence matters most?

Risk register, asset register, security policies, incident response plan, BCP, DRP, backup report, restore test, supplier assessment, MFA report, access review, training and board report.

What does ENISA NIS360 practically tell companies?

It shows that maturity differs across critical sectors and that some sectors are more critical than they are cyber-ready. Companies should prioritize actions according to impact on services, customers and supply chains.

Do SMEs also need to prepare?

Yes, if they meet NIS2 criteria or act as a supplier to a regulated entity. Even a smaller company can receive NIS2 requirements in contracts and customer questionnaires.

Can an MSSP or IT provider solve NIS2 for the company?

They can help with monitoring, incidents, technologies and evidence. They cannot take over board accountability, risk acceptance, business decisions or compliance oversight.

Summary

NIS2 requires companies to manage cyber risk in practice. The key areas are risk, incidents, business continuity, suppliers, system security, effectiveness of safeguards, training, cryptography, access, asset management, MFA and board reporting.

ENISA NIS360 shows that cybersecurity maturity in EU critical sectors is improving, but remains uneven. Some sectors, such as health, public administration, ICT service management, rail, maritime transport, water and wastewater, require particular focus on operational preparedness, suppliers and business continuity.

The best rule is: do not ask only whether we have a NIS2 document. Ask whether we can prove that we manage risk, detect and report incidents, recover operations, oversee suppliers and show the board a real picture of cyber resilience.

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.