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What Is NIST CSF?
The NIST Cybersecurity Framework (CSF) is a set of guidelines developed by the U.S. National Institute of Standards and Technology to help organizations manage and reduce cybersecurity risks. Created initially for critical infrastructure sectors, the framework is now widely used across industries in the United States and globally. The CSF is structured around six core functions: identify, protect, detect, respond, recover, and govern.
The Network and Information Security Directive (NIS2) is a legislative act enacted by the European Union (EU) to strengthen cybersecurity requirements across member states. NIS2 replaces the original NIS Directive adopted in 2016, expanding the scope of covered sectors and tightening obligations for incident reporting, risk management, and supply chain security.
NIST vs. NIS2: Core differences
NIST (US) provides a voluntary Cybersecurity Framework for organizations to manage risk, while NIS2 is a binding EU Directive mandating cybersecurity requirements for organizations within its scope. NIST is a flexible, risk management tool, whereas NIS2 is a legal regulation with stricter demands, including expanded sector coverage, mandatory incident reporting, and potential executive liability. Organizations can, and often should, use the NIST CSF to help implement the requirements of the NIS2 Directive.
How they relate
- NIST’s CSF is a valuable tool to help organizations achieve compliance with NIS2.
- The NIST CSF, with its core functions of Identify, Protect, Detect, Respond, Recover, and Govern, provides a structured approach that organizations can use to meet NIS2’s detailed requirements.
- For organizations operating in the EU and potentially the U.S., understanding both is crucial. NIS2 sets the legal bar in the EU, while NIST provides a best-practice framework for managing risks in the U.S. and globally.
This is part of a series of articles about NIS2 compliance
In this article:
- How NIST and NIS2 Relate
- NIST CSF vs. NIS2: The Key Differences
- Should You Comply with NIST CSF, NIS2, or Both?
How NIST and NIS2 Relate
NIST CSF and NIS2 share a common goal: enhancing organizational cybersecurity through structured processes. Both promote risk-based approaches and emphasize the need for ongoing evaluation, incident response, and cyber risk management. While NIST CSF has a modular and primarily voluntary character, it aligns well with global expectations for systematic risk management, a concept that NIS2 mandates through regulatory requirements.
Organizations operating internationally or maintaining a presence in both the U.S. and EU often find value in mapping the NIST CSF to NIS2 requirements. This alignment can simplify compliance efforts and support the adoption of recognized best practices. Although each framework stems from different regulatory backgrounds, their principles can be integrated to build strong cybersecurity programs.
NIST CSF vs. NIS2: The Key Differences
1. Purpose
The purpose of the NIST cybersecurity framework (CSF) is to provide a voluntary, risk-based approach to improving cybersecurity across organizations. It was originally developed for critical infrastructure in the United States but has since become a globally recognized tool for structuring cybersecurity strategies. The framework’s aim is to help organizations prioritize and manage cybersecurity risks while aligning with their specific business goals and risk appetite. It supports communication between technical and business stakeholders.
The NIS2 directive has a regulatory purpose. It is a legislative act of the European Union designed to enforce baseline cybersecurity requirements across member states. NIS2 entered into force in January 2023, and Member States had until 17 October 2024 to transpose it into national law (with NIS1 repealed from 18 October 2024).
NIS2 focuses on ensuring the security and continuity of essential services, including energy, health, digital infrastructure, and public administration. Its primary objective is to create a harmonized level of cybersecurity resilience across the EU, protect the internal market, and reduce fragmentation caused by differing national approaches. While the NIST CSF provides guidance, NIS2 imposes obligations.
2. Scope and Applicability
NIST CSF is designed for universal applicability. Organizations of any size, industry, or geographical location can implement it as a reference model for cybersecurity risk management. Its flexible structure allows companies to adopt it incrementally, customize it to their needs, and integrate it with other frameworks such as ISO/IEC 27001 or COBIT. It’s often used by both government agencies and private companies in the U.S., and increasingly by international entities seeking to establish structured cybersecurity practices without regulatory enforcement.
NIS2 applies specifically to entities designated as essential or important under the directive’s criteria. These include operators in sectors like energy, transportation, health, banking, and digital infrastructure. It also covers digital service providers and certain public sector bodies. Applicability is largely determined by sector and organization size (e.g., medium and large enterprises). The directive mandates that member states maintain up-to-date lists of covered entities and ensure that compliance obligations are enforced uniformly across jurisdictions.
NIS2 scope also explicitly includes many digital/ICT service providers (e.g., cloud computing, data centres, MSPs/MSSPs, DNS/domain services)—not just ‘traditional’ critical infrastructure.
3. Mandatory vs. Voluntary
NIST CSF is entirely voluntary. It was never intended as a compliance checklist but rather as a guiding framework for organizations aiming to enhance their cybersecurity posture. Adoption is often driven by internal initiatives, industry expectations, or contractual requirements rather than legal mandates. This flexibility allows organizations to tailor their cybersecurity efforts to available resources and specific threat environments.
NIS2 introduces a mandatory compliance regime. Organizations falling within its scope must implement specific security measures, conduct regular risk assessments, and report significant incidents within defined timeframes (early warning within 24 hours of becoming aware, then an incident notification within 72 hours, and a final report within one month—plus interim updates on request).
National regulatory authorities are empowered to audit compliance, request documentation, and impose sanctions—including fines and other penalties—for failures or breaches. The mandatory nature of NIS2 reflects the EU’s goal to ensure a consistent, enforceable level of cybersecurity across all member states.
4. Alignment, Overlap and Gaps
While NIST CSF and NIS2 share foundational concepts, like risk-based management, incident response, and continuous improvement, their structure and intent differ.
NIST CSF is a high-level framework with six core functions (identify, protect, detect, respond, recover, and govern), which can be mapped to various regulatory standards, including NIS2. Many organizations use the CSF as a strategic foundation and then layer on NIS2-specific controls to meet legal requirements.
However, gaps exist between the two frameworks. NIST CSF lacks prescriptive requirements for executive accountability, formal governance structures, and mandatory incident reporting timelines, elements that are central to NIS2. For example, NIS2 requires the designation of a responsible management body, formal documentation of cybersecurity policies, and reporting obligations for incidents that significantly impact services.
A practical overlap is resilience: NIS2 explicitly calls out business continuity—‘backup management and disaster recovery’—as a required risk-management measure. That makes the CSF Recover function (and testing it) an easy place to operationalize NIS2 expectations with real evidence.
✅ TIP: One way to close the ‘proof’ gap is to use tooling, like N2W, that produces audit-friendly recovery evidence (e.g., scheduled DR tests, restore logs, retention reporting)—not just a framework narrative.
5. Supply Chain and Third-Party Risk
NIS2 places a strong emphasis on managing supply chain and third-party risks. It requires organizations to assess and mitigate risks associated with service providers, vendors, and other external entities that support critical functions. This includes ensuring that contractual arrangements address cybersecurity responsibilities and that the security posture of suppliers is continuously evaluated. Organizations must demonstrate due diligence in their supply chain risk management practices as part of their compliance efforts.
NIST CSF also acknowledges the importance of supply chain risks, particularly under the “identify” and “protect” functions. It encourages organizations to map dependencies, assess risks, and implement controls related to third-party services. However, its treatment is more conceptual and less enforceable. The framework provides guidance but not specific requirements.
NIS2 goes further than NIST CSF by making these practices legally binding and subject to regulatory oversight. This distinction is critical for organizations operating in both U.S. and EU markets, as supply chain requirements under NIS2 are more stringent and formally monitored.
6. Scope of Covered Entities
The NIST CSF does not define a set of covered entities. Any organization—public or private—can choose to adopt it. There are no formal criteria for inclusion or exclusion, making it a tool for voluntary adoption based on organizational goals and risk maturity. It’s particularly useful for organizations seeking to build a cybersecurity program from scratch or improve an existing one without navigating legal constraints.
NIS2, as an EU Directive, clearly defines who is covered. Entities are categorized as “essential” or “important,” depending on their role in delivering critical services, size, and impact on the economy or society. This includes sectors such as water, energy, finance, healthcare, and digital infrastructure. The directive also covers managed service providers and ICT suppliers that may not operate critical services directly but support those that do.
- Establish a dual-track governance model: Implement two governance layers: one for voluntary frameworks like NIST CSF and one for legal mandates like NIS2. This avoids confusing accountability.
- Use crosswalk tools to automate alignment: Leverage existing mapping tools or build internal crosswalks that align NIST CSF categories directly to NIS2 articles and requirements. This accelerates gap remediation.
- Implement “compliance-aware” threat modeling: Go beyond technical threat modeling by integrating legal and regulatory exposure, such as breach notification thresholds under NIS2, into risk assessments.
- Leverage NIST CSF for NIS2 pre-audit simulations: Use the CSF to simulate NIS2 audit scenarios. For example, use the "Respond" and "Recover" functions to simulate incident workflows required under NIS2.
- Use automation to schedule DR drills and send reports: Use a tool like N2W to schedule automated DR drills and keep the results as evidence (RTO/RPO, restore order, network config recovery) for internal audits.
Should You Comply with NIST CSF, NIS2, or Both?
The choice between adopting NIST CSF or complying with NIS2 depends largely on organizational context and regulatory exposure. For entities operating within the European Union, or providing services into it, NIS2 compliance is not optional. However, organizations expanding overseas need to consider the operational implications of operating in the EU, if they fall under the purview of NIS2.
For organizations outside the EU or those not directly subject to NIS2, the NIST CSF often serves as a practical starting point. Its flexibility allows incremental adoption, making it useful for organizations with limited resources or those developing their cybersecurity maturity. It also provides a recognized framework that can align with regulatory or contractual obligations in different jurisdictions.
In practice, many global organizations use both. They implement the NIST CSF to establish a risk-based foundation and then layer on NIS2-specific obligations where required. This approach reduces duplication of effort and ensures consistency across international operations. Organizations that expect future regulatory changes often find the CSF a strategic tool for preparing in advance, while NIS2 compliance ensures alignment with current EU legal obligations.
Supporting NIST CSF and NIS2 Compliance with N2W Disaster Recovery
- NIS2 Article 21 business continuity calls out backup management and disaster recovery—N2W helps operationalize that with automated, policy-driven backups, fast restores, and repeatable DR testing.
- For ransomware resilience, N2W supports immutable backups and a true air-gapped approach (e.g., clean DR accounts / isolated repositories) so recovery isn’t dependent on a compromised production environment.
- Need flexibility for regulatory or operational separation? N2W supports cross-region/cross-account recovery and even cross-cloud restore options (AWS/Azure/Wasabi), which can help meet isolation and recoverability expectations.
- And because compliance shouldn’t equal runaway spend: N2W includes archiving + lifecycle cleanup controls to reduce long-term backup storage costs while keeping required retention.
For a deeper, actionable view, grab our NIS2 Guide for a practical breakdown of requirements, timelines, and implementation steps.