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Introducing NIS2 and ISO 27001
NIS2 is a mandatory European Union (EU) directive focused on securing critical infrastructure, while ISO 27001 is a voluntary, internationally recognized standard for establishing and certifying an Information Security Management System (ISMS) within any organization. ISO 27001 offers detailed security controls and risk management frameworks that can be used to meet the broader, more high-level requirements of NIS2 for certain organizations, especially those in critical sectors.
NIS2 is the revised directive on security of network and information systems, adopted by the European Union in 2022 as a replacement for the original NIS directive. NIS2 expands the cybersecurity obligations for both essential and important entities across sectors like energy, transportation, health, and digital infrastructure.
Under NIS2, organizations must implement risk management practices, report incidents promptly, and ensure strong governance structures. The directive also introduces stricter enforcement measures, larger fines, and greater accountability at the management level.
Organizations can also seek certification against ISO 27001, which involves being audited by accredited external auditors. While the standard is globally recognized and widely adopted across industries, it is voluntary; organizations choose to implement ISO 27001 to demonstrate their commitment to information security or meet contractual obligations. ISO 27001 was most recently updated in October 2022, improving its relevance to today’s cloud, supply chain, and resilience requirements.
This is part of a series of articles about NIS2 compliance
In this article:
- NIS2 vs. ISO 27001: Key Differences
- Does ISO 27001 Compliance Make You NIS2 Compliant?
- Should You Comply with ISO 27001, NIS2, or Both?
- How Cloud Best Practices Lead to Effortless Compliance
NIS2 vs. ISO 27001: Key Differences
1. Mandatory vs. Voluntary
NIS2 is a legislative measure enacted by the European Union and is mandatory for organizations that fall within its designated sectors and thresholds. Failure to comply with NIS2 can lead to enforcement actions, significant fines, and reputational damage. The directive enforces a minimum baseline of cybersecurity and reporting obligations that affected entities must follow, regardless of whether they have existing information security certifications or frameworks in place.
In contrast, ISO 27001 is a voluntary framework that organizations can adopt at their discretion to structure and improve their information security management practices. Certification to ISO 27001 can provide external validation of security measures, but it does not satisfy any specific national or regional regulatory requirement by itself. Organizations often pursue ISO 27001 to demonstrate industry best practices or assure customers, but there is no legal mandate for adherence outside contractual requirements.
2. Scope and Applicability
NIS2 has a well-defined applicability, focusing on entities operating in sectors deemed critical for the functioning of society and the economy, such as utilities, health, transportation, and digital infrastructure. The directive stipulates thresholds based on size, industry, and type of service provided. NIS2’s aim is to safeguard services that, if disrupted, could have significant consequences for the wider public or national security, leading to strict oversight of both public and private sector entities.
In contrast, ISO 27001 is sector-agnostic and can be applied to any organization regardless of size, industry, or geographical location. Its broad framework provides flexibility for organizations to define the scope of their ISMS around business needs, risk environment, and organizational structure. This makes ISO 27001 popular not only among critical infrastructure providers but also among businesses seeking to enhance their security posture.
3. Structure and Content
NIS2 prescribes specific obligations, including risk management measures, incident reporting, supply chain security requirements, and clear accountability structures for covered entities in 18 sectors. The directive outlines minimum measures for particular controls and reporting mechanisms, meaning organizations must meet these points exactly as specified or potentially face non-compliance.
ISO 27001 is built around the Plan-Do-Check-Act (PDCA) cycle and emphasizes continual improvement. The standard establishes a framework for an information security management system that identifies risks and then selects controls from ISO 27002 or other sources according to those risks. While certain elements, like management commitment, documented policies, and regular review, are mandatory, how each organization implements security controls is driven by its individual risk assessment and context.
4. Incident Reporting and Notification Obligations
NIS2 imposes strict incident reporting timelines and protocols. Entities must notify the relevant national authorities within 24 hours of becoming aware of a significant cybersecurity incident, followed by more detailed updates as investigations progress. This prompt reporting ensures that threats to wider society or cross-border infrastructure can be contained and managed collectively, improving incident response and coordination at both national and EU levels.
ISO 27001 does not prescribe explicit external incident notification requirements. Instead, it requires organizations to establish processes for managing information security incidents internally, ensuring they are detected, responded to, and learned from. While ISO 27001 organizations should communicate incidents to relevant stakeholders—possibly including regulators—this is subject to internal policy and legal requirements. The absence of fixed external reporting timelines contrasts sharply with the binding obligations set by NIS2.
5. Mapping / Overlap and Gaps
There is a significant overlap in objectives between NIS2 and ISO 27001, with both frameworks promoting risk management, continuous improvement, and a documented approach to information security. Many controls required by NIS2 can be found within ISO 27001 and its related guidance, enabling organizations certified to the standard to align some existing processes with NIS2 requirements.
However, there are notable gaps. NIS2 mandates specific reporting deadlines and legal compliance measures not covered within ISO 27001, which remains a voluntary standard. Furthermore, NIS2’s focus on sector-specific critical infrastructure brings obligations tailored to service continuity and national oversight that ISO 27001 does not address directly. As a result, achieving compliance with one framework does not assure full alignment with the other.
6. Governance and Accountability
NIS2 introduces direct accountability for senior executives and management boards. Leadership must approve security policies, allocate resources, and ensure compliance, with potential for personal liability in the event of negligence. This legal accountability is designed to embed cybersecurity into organizational culture and decision-making at the highest levels.
ISO 27001 also emphasizes leadership commitment, but its requirements stop at ensuring top management demonstrates leadership and support for the ISMS. The standard requires management to set policy, allocate resources, and review performance, but it does not create a legal framework for personal accountability. The obligations and penalties under NIS2 are far stronger, serving as a catalyst for executive involvement beyond what ISO 27001 requires.
In short, under NIS2, C-level leadership may be held personally liable in the event of breach due to negligence.
Does ISO 27001 Compliance Make You NIS2 Compliant?
ISO 27001 certification indicates a mature information security management system and demonstrates that the organization is committed to risk-based security. However, meeting ISO 27001 requirements does not guarantee full compliance with NIS2. While there is considerable synergy, especially around risk management, policies, and technical controls, NIS2 includes specific legal, reporting, and governance obligations that ISO 27001 does not address.
Organizations with ISO 27001 certification are better positioned to meet many NIS2 requirements but will still need to close gaps. This means reviewing and updating processes for incident notification, supply chain risk management, governance structures, and sector-specific requirements set by NIS2. Additional actions include assigning legal responsibility to management, conducting regulatory-relevant risk assessments, and establishing documentation to demonstrate compliance to regulators.
TL;DR: ISO 27001 supports NIS2 goals—but it doesn’t fulfill NIS2 legal obligations. You still need sector-specific risk assessments, executive accountability, and fast incident reporting to be compliant.
Examples of what ISO 27001 doesn’t cover:
- 24-hour incident notification requirement
- Mandatory reporting to national authorities
- Sector-based oversight by EU regulators
- Legal obligations for management
- Specific supply chain clauses tied to critical infrastructure
- Create a dual compliance roadmap with delta mapping: Build a shared controls inventory and highlight where ISO 27001 meets NIS2 obligations and where it doesn’t. A delta map helps avoid duplicating effort, clearly defines what’s "already covered," and accelerates timelines.
- Use NIS2 enforcement pressure to justify ISO 27001 adoption: For orgs newly in-scope under NIS2, ISO 27001 can be positioned as the operational foundation for sustainable compliance. Framing ISO certification as a "compliance enabler" gives CISOs leverage to secure executive buy-in.
- Establish a regulatory impact heatmap: Develop a sector-specific regulatory heatmap that scores NIS2 obligations by business impact, compliance cost, and overlap with ISO 27001 controls. This visual approach helps prioritize implementation steps and communicate urgency and scope.
- Layer “governance for enforcement” over your ISMS: ISO 27001 focuses on policy and process, but not on legal enforcement. Use NIS2’s governance obligations (like executive accountability and breach liability) to augment your ISMS with a top-down compliance lens.
- Implement incident notification triggers tied to SIEM thresholds: ISO 27001 doesn’t specify when to notify regulators, but NIS2 does. Set automatic alerting workflows that link SIEM anomalies with predefined NIS2 notification thresholds. This ensures you’re not relying on ad-hoc decisions.
Should You Comply with ISO 27001, NIS2, or Both?
When deciding between ISO 27001 and NIS2, organizations should evaluate their regulatory obligations, operational priorities, and security maturity. The choice is not always binary; many organizations will find value in implementing both frameworks in a complementary way.
Regulatory and Industry Alignment
Organizations in regulated sectors—such as energy, transport, finance, and healthcare—are likely to fall within the scope of NIS2 and must comply with its mandatory requirements. For these entities, NIS2 is not optional. Its focus on sector-specific risks, legal obligations, and national oversight makes it better suited for organizations where public safety, economic stability, or national security are at stake.
Conversely, ISO 27001 is appropriate for organizations seeking a globally recognized framework that can be tailored to their business context. It is particularly relevant for companies operating internationally, those with contractual security obligations, or those aiming to improve internal risk management. Its flexibility makes it suitable for organizations in any sector, including those not covered by NIS2.
Operational and Resource Considerations
Implementing either standard requires investment, but the nature of that investment differs. ISO 27001 involves building a risk-based ISMS, which demands cross-functional coordination, documentation, internal training, and periodic audits. While it may disrupt existing workflows during implementation, it offers long-term operational efficiencies through structured controls and continuous improvement.
NIS2 compliance may impose stricter, externally driven requirements. These include 24-hour incident reporting, board-level accountability, and sector-specific risk assessments. Organizations may need to adjust governance structures, allocate more resources to compliance functions, and prepare for regulatory inspections. In many cases, this can be more intrusive and time-sensitive than ISO 27001.
Strategic Benefits and Long-Term Planning
ISO 27001 provides credibility and assurance across international markets. NIS2, while legally binding only in the EU, signals a commitment to sector-specific cybersecurity and regulatory responsibility. For multinational organizations, ISO 27001 can serve as a baseline, with NIS2 layered on top where applicable.
In the future, both standards are expected to evolve to address emerging technologies and threats. ISO 27001 will likely integrate guidance on areas like artificial intelligence, IoT, and cloud computing, while NIS2 may expand to cover new critical sectors and technologies. Organizations adopting either framework should prepare for ongoing changes and maintain agility in their compliance strategies.“`
How Cloud Best Practices Lead to Effortless Compliance
Cloud best practices can significantly reduce the operational burden of achieving and maintaining compliance with frameworks like NIS2 and ISO 27001. By embedding automation, resilience, and security-by-design principles into cloud operations, organizations can align their infrastructure with regulatory and governance requirements without constant manual oversight.
Automated Disaster Recovery (DR) Drills
Automated DR testing ensures that recovery procedures are validated regularly and consistently. This supports NIS2’s requirement for incident preparedness and ISO 27001’s emphasis on business continuity and operational resilience. Automating these drills not only verifies recovery readiness but also generates audit trails that demonstrate compliance to regulators and auditors.
Immutable Backups and Data Integrity
Immutable backup policies protect against accidental deletion, ransomware, or insider threats by ensuring that backup data cannot be modified or erased. This aligns with NIS2’s focus on maintaining data integrity and availability, while satisfying ISO 27001 controls related to protection from data corruption and unauthorized changes. Immutable storage also supports verifiable evidence of data integrity—a key compliance assurance factor.
Cross-Cloud Recovery and Supply Chain Resilience
Implementing recovery strategies that span multiple cloud providers helps organizations meet NIS2’s supply chain and third-party resilience expectations. Cross-cloud recovery minimizes dependency on a single vendor, ensures operational continuity in case of provider outages, and supports ISO 27001’s requirement to identify and mitigate risks from external suppliers and service providers.
Cost-Optimized Archiving and Governance
Cost-optimized data archiving frameworks use tiered storage, lifecycle policies, and automation to maintain compliance records and backups efficiently. This approach aligns with ISO 27001’s principle of continuous improvement and efficient resource use while addressing NIS2’s long-term data retention and auditability requirements. Properly designed archiving policies reduce both storage costs and compliance complexity.
Incorporating these cloud-native capabilities allows organizations to demonstrate compliance as a byproduct of sound operational practice. Rather than treating NIS2 or ISO 27001 as separate, manual processes, organizations can integrate them into the cloud management lifecycle—making compliance measurable, auditable, and largely effortless.
Empowering Cloud Native Compliance with N2W Cloud Backup
NIS2 and ISO 27001 both call for proactive security, fast recovery, and ironclad governance. N2W helps you bake these principles into your cloud operations—with automated backups, disaster recovery, and compliance visibility across AWS, Azure, and Wasabi.
| Compliance Requirement | N2W Capability |
| Incident Recovery & RTO Tracking | Restore full environments in minutes with orchestrated DR flows |
| Immutable, Tamper-Proof Backups | Enforced retention & cross-cloud isolation for backup integrity |
| Audit Trails & Reporting | Detailed logs, alerts, and compliance-ready reports from one UI |
| Supply Chain Risk Mitigation | Backups stay in your cloud account—no third-party dependency |
| Executive Oversight | Real-time dashboards and automated reporting for CISO and IT leadership visibility |
| Automated DR Testing | Schedule DR drills and reports for audit readiness |
✅ Ready to Align ISO 27001 and NIS2—Without the Paperwork Pileup?
Our free NIS2 checklist helps you map controls, track requirements, and prep for compliance without starting from scratch.