Implementing NIS2 requirements step by step:

Risk management, incident response, and reporting requirements

The NIS2 Directive is more than just a list of technical requirements—it demands consistent, verifiable processes. Many companies are faced with the question: How do we implement the extensive requirements in concrete terms? Where do we start? Which processes need to be established?

The good news is that with a structured, step-by-step approach, NIS2 compliance becomes manageable. This article shows you how to systematically address the requirements—from impact assessment and the establishment of risk management and incident response processes to the implementation of reliable reporting channels.

You will receive a practical guide that translates abstract regulatory texts into concrete steps. Learn how to establish risk management in accordance with NIS2, set up a professional incident response process, and reliably fulfill strict reporting requirements. Axsos accompanies you on this journey—for an IT infrastructure that is secure, stable, and future-proof.

From regulatory text to practical application: Why processes are crucial

The NIS2 Directive significantly tightens cybersecurity requirements for thousands of companies in Germany. Essentially, it requires not only selective technical measures, but also holistic cyber resilience management with clear processes, defined responsibilities, and continuous improvement.

The difference to previous approaches: NIS2 requires verifiability. It is not enough to have implemented security measures. Companies must be able to document that their processes work, are regularly reviewed, and are adjusted as necessary. Regulatory authorities will check precisely this—and if deficiencies are found, severe penalties may be imposed.

The focus is on three core areas:

Risk management: Systematic identification, assessment, and treatment of cyber risks
Incident Response: Professional processes for detecting, handling, and managing security incidents
Reporting requirements: Reliable reporting channels and compliance with strict deadlines (24 hours, 72 hours)

These three areas are closely interlinked: effective risk management helps prevent incidents. An established incident response process enables a rapid response. Clear reporting processes ensure that you comply with regulatory obligations.

The following guide shows you step by step how to establish these processes in your organization.

Overview: What exactly does NIS2 require?

Before we dive into the details of implementation, here is an overview of the key NIS2 requirements:

Organizational measures

Risk management processes: Systematic recording and handling of cyber risks
Security policy and concepts: Documented guidelines and strategies
Incident Management: Processes for incident handling and documentation
Business continuity: Contingency plans and recovery concepts
Supply chain security: Assessment and management of risks by service providers
Training and awareness: Regular awareness-raising for all employees
Governance: Responsibility of management, monitoring of implementation of measures

Technical measures

Network and system security: firewalls, segmentation, hardening
Access and access control: multi-factor authentication, authorization management
Encryption: Protection of data during transmission and storage
Patch and vulnerability management: Systematic elimination of security gaps
Backup and recovery: Regular data backup, tested recovery
Security monitoring: Continuous monitoring for anomalies and threats

reporting requirements

Early warning: Initial reporting of significant incidents within 24 hours
Interim report: More detailed report within 72 hours
Final report: Comprehensive documentation within approximately one month

Together, these requirements form a comprehensive cyber resilience framework. The challenge lies not in individual measures, but in their systematic integration into the organization.

Step 1: Assess impact and define scope

The first step in any NIS2 implementation is to be clear about how it affects you. Not every company falls under the directive, and even companies that are affected must define the exact scope of application.

Perform impact assessment

Check systematically:

Industry affiliation: Does your company belong to one of the critical sectors defined in NIS2?
Company size: Do you meet the thresholds (at least 50 employees and €10 million in annual revenue)?
Criticality of services: Do you provide particularly critical services that could fall under NIS2 regardless of size?
Categorization: Are you an "essential" or "important" institution?

Practical tip: Hold a scoping workshop attended by representatives from IT, compliance, legal, and management. Different perspectives help to correctly assess the impact.

Define scope and limits

If you are affected, define precisely:

Which business areas fall under NIS2?
Which systems and assets are critical for the services covered?
Which locations should be included?
Which service providers and partners have access to critical systems?

This scoping phase is fundamental. A scope that is too narrow overlooks risks, while a scope that is too broad wastes resources. Document your decisions—regulatory authorities will want to understand your reasoning.

Identify stakeholders and involve management

NIS2 is not purely an IT task. Identify all relevant stakeholders:

Management: Bears overall responsibility
CISO/IT security officer: Coordinates implementation
IT department: Implements technical measures
Specialist departments: Identify critical processes and risks
Compliance/Legal: Monitoring regulatory requirements
Communication: Responsible for internal and external communication in the event of incidents

Establish an NIS2 project team with clear roles and responsibilities. Management must be involved from the outset—NIS2 explicitly requires the responsibility of senior management.

Step 2: Conduct an inventory and gap analysis

With a clear scope, the current assessment follows: Where are you today? What is already in place? Where are the gaps?

asset inventory

Record systematically:

IT assets: servers, network components, end devices, applications
Data: What data do you process? Where is it stored?
Critical processes: Which business processes depend on which IT systems?
Dependencies: Which systems depend on each other? Which service providers are involved?

Tools such as configuration management databases (CMDB) or asset management systems help with inventory management. If such tools do not exist, now is the time to introduce them.

Assessment of existing security measures

Analyze your current security measures:

Technical controls: Which firewalls, antivirus solutions, and monitoring systems are in use?
Processes: Are there documented processes for patch management, backup, and access management?
Policies: Are security policies defined and communicated?
Incident management: Are there established procedures for handling incidents?

Gap analysis: target vs. actual

Compare your status quo with the NIS2 requirements. Create a structured gap analysis:

Fulfilled: Which requirements have already been implemented?
Partially fulfilled: Where are there approaches that still need to be developed further?
Not fulfilled: Which requirements are completely missing?

Assess each gap in terms of risk and urgency. Prioritize areas for action: What needs to be addressed immediately? What can be done at a later stage?

Practical tip: Use established frameworks such as ISO 27001 or BSI IT-Grundschutz as a reference. Many of their requirements overlap with NIS2, and existing certification makes compliance much easier.

Step 3: Establish risk management in accordance with NIS2

Systematic risk management is the foundation of NIS2 compliance. It involves understanding, assessing, and systematically addressing cyber risks.

Establish a risk management process

A complete risk management cycle comprises four phases:

1. Risk identification

Systematically identify threats and vulnerabilities:

External threats: cyberattacks, malware, DDoS, ransomware
Internal risks: misconfigurations, insufficient access controls, outdated systems
Human factors: social engineering, phishing, unintentional errors
Supply chain risks: Vulnerabilities among service providers or suppliers
Physical risks: fire, natural disasters, physical access

Methods: Workshops with experts, threat modeling, analysis of past incidents, threat intelligence feeds.

2. Risk assessment

Assess identified risks according to two dimensions:

Probability of occurrence: How likely is it that the risk will occur? (low, medium, high)
Impact: What damage would the risk cause? (financial, operational, reputational, legal)

Create a risk matrix that visually represents and prioritizes risks. Focus on high-impact/high-probability risks.

3. Risk treatment

Define a treatment strategy for each significant risk:

Avoid: Discontinue activities that cause the risk
Reduce: Implement measures that lower the probability of occurrence or impact
Transfer: Shift risk to third parties (insurance, outsourcing)
Accept: Conscious decision to bear the residual risk

Document every decision with justification. NIS2 requires verifiability.

4. Risk monitoring and review

Risk management is not a one-time project, but rather a continuous process:

Regular reviews: At least annually, preferably semi-annually
Ad hoc reviews: In the event of significant changes (new systems, new threats, incidents)
Monitoring risk indicators: Key figures that signal changes in the risk situation

Specific risk management measures

Based on your risk analysis, you implement security measures:

Network security:

Segmentation of critical network areas
Next-generation firewalls with intrusion prevention
Network monitoring and anomaly detection

Access controls:

Multi-factor authentication for all critical systems
Least privilege principle: Minimum required permissions
Regular review and cleanup of permissions
Privileged access management for administrative access

Patch and vulnerability management:

Systematic scanning for vulnerabilities
Prioritization according to criticality and exploitability
Defined patch cycles for different system categories
Emergency patching processes for critical vulnerabilities

Backup and recovery:

3-2-1 rule: 3 copies, 2 different media, 1 offline/offsite
Regular backup tests: Can you really restore?
Immutable backups against ransomware
Documented recovery procedures with defined RTOs and RPOs

Documentation and verifiability

Document your risk management comprehensively:

Risk register: Central documentation of all identified risks
Risk assessments: Methodology and results
Treatment plans: Which measures against which risks
Review logs: When was what reviewed, with what result?
Management reports: Regular reporting to management

This documentation serves as proof to regulatory authorities that you are operating in compliance with NIS2.

Step 4: Set up professional incident response

Even with the best risk management, security incidents can occur. The decisive factor then is how quickly and professionally you respond. NIS2 requires established incident response processes.

What does NIS2 mean by incident response?

Incident response encompasses all measures for detecting, assessing, containing, eliminating, and following up on security incidents. A "significant incident" within the meaning of NIS2 is an event that:

Significantly impairs or could impair the provision of services
Leads to significant financial losses
Has a significant impact on other companies or public safety

Such incidents must be reported and dealt with systematically.

Building blocks of an incident response plan

A professional incident response process is divided into several phases:

1. Preparation

Before incidents occur, foundations must be laid:

Incident Response Team (IRT): Defined roles and responsibilities
Incident response plan: Documented procedures for different types of incidents
Tools and technology: SIEM systems, forensic tools, secure communication channels
Training: Regular training of the IRT
Contact lists: All relevant persons available 24/7

2. Detection and analysis

Incidents must be quickly identified and assessed:

Monitoring: SIEM systems, IDS/IPS, log analysis, anomaly detection
Alerting: Automatic notifications in case of suspicious events
Triage: Initial assessment: false positive or genuine incident?
Classification: Severity, type, affected systems
Documentation: Document everything from the very beginning

Define clear criteria: When does an event qualify as an incident? At what severity level is it escalated?

3. Containment

Prevent the incident from spreading:

Short-term containment: Isolate compromised systems, disconnect network segments
Long-term containment: Temporary fixes, activate backup systems
Preservation of evidence: Collecting forensic data for later analysis

4. Eradication

Remove the cause of the incident:

Completely remove malware
Lock compromised accounts, reset passwords
Close vulnerabilities that have been exploited
Eliminate backdoors and persistence mechanisms

5. Recovery

Restore systems to normal operation safely:

Restore systems from clean backups
Gradual restart with intensive monitoring
Validation: Has the incident really been resolved?
Communication: Inform stakeholders about restoration

6. Follow-up (lessons learned)

Every significant incident is followed by a structured review:

Post-incident review: What happened? Why? How was it handled?
What went well? What needs to be improved?
Catalog of measures: Define specific improvement measures
Update documentation: Adjust incident response plan
Final report: Documentation for management and authorities

Incident response team and roles

Define clear roles within the incident response team:

Incident Manager: Coordinates the response, main contact person
Technical Lead: Technical analysis and implementation of measures
Forensics Specialist: Evidence preservation and root cause analysis
Communications Lead: Internal and external communications
Legal/Compliance: Legal assessment, reporting requirements
Management Representative: Interface to management

Not every organization needs all of these roles filled by dedicated individuals—in smaller companies, employees take on multiple roles. It is important that responsibilities are clear.

Simulation games and tests

An incident response plan on paper is worthless if it doesn't work. Test it regularly:

Tabletop exercises: Playing through scenarios at the table
Simulations: Technical tests with simulated attacks
Red team exercises: External experts test your defenses

After each exercise: Document lessons learned and adjust the plan. A plan that has never been tested is an illusion.

Step 5: Define reporting requirements and reporting processes

The NIS2 reporting requirements are among the strictest requirements of the directive. Violations can be severely penalized. Companies must establish processes to ensure that reports are submitted on time and in full.

The reporting deadlines in detail

Early warning: 24 hours

Within 24 hours of becoming aware of a significant security incident, an initial report must be made to the competent authority (in Germany, this is the BSI). This initial report can be brief, but should contain:

Type of incident (e.g., ransomware attack, DDoS, data leak)
Time of discovery
Initial assessment of scope and impact
Affected systems or services
Initial measures

Important: The 24-hour period begins at the time of knowledge, not at the time of the incident itself. "Knowledge" means that you should reasonably have known that a significant incident had occurred.

Interim report: 72 hours

No later than 72 hours after becoming aware of the incident, a more detailed report is required, including:

Updated assessment of the incident
Severity and effects
Indicators of Compromise (IoCs)
Measures taken and planned
Cross-border effects
Initial assessment of the cause

Final report: Approximately 1 month

Once the incident has been resolved, a comprehensive final report must be submitted no later than one month after the initial report:

Complete description of the incident
Detailed root cause analysis
Chronology of events
All measures taken
Assessment of the effectiveness of the response
Lessons learned and planned improvements
Economic and other impacts

Establish internal reporting processes

To ensure that external reporting deadlines can be met, you need functioning internal processes:

1. Define clear escalation paths

Who reports to whom when an incident is suspected?
How does escalation take place (email, ticket system, telephone)?
Who decides whether an incident must be reported?
How can you reach decision-makers outside of business hours?

2. Define roles and responsibilities

Reporting officer: Submits the report to the authorities
Technical evaluators: IT security experts who classify the incident
Compliance Officer: Checks regulatory requirements
Communications officer: Formulates messages in a way that is easy to understand
Management: Approves messages, provides information

3. Use standardized templates and checklists

Create templates for messages that request all necessary information:

Reporting form for 24-hour reporting (brief, essential)
Reporting form for 72-hour reporting (detailed)
Structure for final report
Checklist: Is the incident reportable?

Templates speed up the process and ensure that nothing is forgotten.

Define thresholds for reporting requirements

Not every incident needs to be reported. Define criteria:

An incident is typically significant if:

Critical services have been down for more than X hours
More than Y customers are affected
Sensitive data has been compromised
The financial damage exceeds Z euros.
Public safety is compromised

Adapt these thresholds to your organization. Document the criteria and train all parties involved.

Documentation of all incidents

Incidents that are not subject to reporting requirements should also be documented:

Incident log: Chronological record of all events
Documentation of measures: What was done, when, and by whom?
Communication protocols: Who was informed and when?
Verifiable decisions: Why was a measure taken or not taken?

This documentation serves as proof for regulatory authorities and, in case of doubt, in court.

Step 6: Governance, training, and safety culture

Technical measures and processes are essential—but without the right people and a culture of security, they remain ineffective. NIS2 explicitly requires governance at the highest level and continuous training.

Responsibility of management

Management bears overall responsibility for cybersecurity. Specifically, this means:

Active monitoring: Regular reporting on the security situation and implementation of measures
Approval of budgets and resources: Approve investments in security
Policy approval: Approve security policies and strategies
Crisis management: Be involved in significant incidents
Own continuing education: Management must build up cybersecurity expertise themselves

Practical implementation:

Establish regular management meetings on cybersecurity (quarterly).
Create KPI dashboards for the security situation
Define approval processes for security-related decisions
Document management decisions in a comprehensible manner

Training and awareness programs

People are often the weakest link in the security chain—but also the strongest, if they are properly trained.

Training program for all employees:

Onboarding training: Every new employee receives security basics training.
Annual mandatory training: Refresher courses and updates on new threats
Phishing simulations: Regular tests to raise awareness
Awareness campaigns: posters, newsletters, intranet posts

Special training courses for key personnel:

IT staff: In-depth technical training on security tools and processes
Executives: Security awareness for management level
Incident response team: Specialized training, certifications
Developer: Secure Coding, Security-by-Design

Measuring effectiveness:

Training participation rates
Success rates in phishing tests (should decrease over time)
Number of suspicious emails reported (should increase – indicates awareness)
Feedback and suggestions for improvement from training courses

Establishing a safety culture

Security must become part of the corporate DNA:

Tone from the Top: Management leads by example in safety
Error culture: Employees can report incidents without fear of sanctions
Recognition: Safety-conscious behavior is positively emphasized
Integration: Security is integrated into all processes, not an add-on
Continuity: Security is not a project with an end date, but an ongoing issue.

A strong safety culture reduces risks more effectively than any technology.

Step 7: Continuous improvement and audits

NIS2 compliance is not a one-off project with a defined end point, but rather an ongoing process. The threat landscape is evolving, your organization is changing, and technologies are advancing. Your security measures must keep pace.

Regular risk analyses and reviews

Annual comprehensive risk analysis: Systematic reassessment of all risks
Quarterly risk reviews: Review of significant changes
Ad hoc reviews: After major incidents, when new threats arise, after system changes
Lessons learned sessions: After incidents and exercises

Internal and external audits

Internal audits:

Regular review of the effectiveness of controls
Random checks to verify compliance with policies
Review of documentation and evidence
Self-assessments based on checklists

External audits:

Independent testing by external security experts
Penetration tests and vulnerability assessments
ISO 27001 audits (if certified)
Preparation for regulatory inspections

Key figures and KPIs for cybersecurity

What is not measured cannot be controlled. Establish relevant key performance indicators:

Technical KPIs:

Mean Time to Detect (MTTD): How quickly are incidents detected?
Mean Time to Respond (MTTR): How quickly is a response provided?
Patch compliance rate: How up to date are your systems?
Number of critical open vulnerabilities
backup success rate

Process KPIs:

Number and severity of security incidents
Compliance with reporting deadlines
Training completion rate
Completion rate of audit measures

Management KPIs:

Investments in cybersecurity (absolute and as % of IT budget)
Availability of critical services
Compliance status (percentage of NIS2 requirements met)
cyber risk score

Report these KPIs regularly to management and use them to steer your security measures.

Maturity models for cybersecurity

Systematically assess your cyber resilience with maturity models:

Level 1 – Ad hoc: Reactive, unstructured measures
Level 2 – Defined: Basic processes documented
Level 3 – Standardized: Consistent application of defined processes
Level 4 – Controlled: Quantitative control, metrics established
Level 5 – Optimized: Continuous improvement, proactive adaptation

Frameworks such as CMMI Cybersecurity or NIST Cybersecurity Framework offer structured maturity models. Use these to measure progress and identify potential for improvement.

Practical examples and typical stumbling blocks

Example 1: Medium-sized manufacturing company without clear processes

A company with 180 employees in mechanical engineering falls under NIS2. The IT department consists of three people, and there is no dedicated CISO. When a ransomware attack paralyzes critical production systems, the weaknesses become apparent:

No one knows who should report the incident to the BSI.
The 24-hour deadline expires because responsibilities are unclear.
Documentation is missing—what exactly happened? Which systems are affected?
Management only learns of the incident 48 hours later.
Backups exist but have never been tested – recovery fails

Consequences: Five days of lost production, fines for late reporting, massive damage to reputation.

What could have helped: Clear incident response processes, defined roles, regular testing, training for management.

Example 2: NIS2 as an opportunity for systematic improvement

An IT service provider with 120 employees is using NIS2 as a catalyst for long-overdue improvements:

Systematic development of an ISMS in accordance with ISO 27001
Implementation of a SIEM system for centralized monitoring
Establishment of an incident response team with clearly defined roles
Quarterly tabletop exercises for incident management
Regular training for all employees

Result: After 18 months, the company is not only NIS2-compliant, but also objectively more secure. The number of successful phishing attacks has fallen by 70%. A minor security incident is detected and contained within two hours. The timely report to the BSI is completed without any problems. The company can use the improved security situation as a competitive advantage.

Typical stumbling blocks in NIS2 implementation

Stumbling block 1: Focusing solely on technology

Many companies invest in expensive security tools but neglect processes, training, and governance. Technology without processes is ineffective.

Stumbling block 2: Insufficient involvement of management

NIS2 explicitly requires management to take responsibility. If management delegates the issue and does not actively engage, there will be a lack of resources and enforcement.

Stumbling block 3: Underestimating documentation

Regulatory authorities require proof. "We'll take care of it" is not enough. Without documentation, you cannot prove that you are compliant.

Stumbling block 4: Not testing processes

Plans on paper are worthless if they don't work. Regular testing is essential.

Stumbling block 5: Viewing compliance as a one-time project

NIS2 compliance is not a project with an end date, but rather a continuous process. Those who stop after the initial implementation will fall behind.

How Axsos supports you in implementing NIS2

The requirements of NIS2 are complex and extensive. As an experienced partner, Axsos supports you through all phases of implementation—from initial analysis to continuous optimization.

Impact analysis and scoping

We will clarify with you whether and to what extent you are affected by NIS2, define the scope, and identify all relevant stakeholders.

Establishment of risk management structures

Axsos supports you in systematically establishing a risk management process: from risk identification and assessment to the implementation of measures and continuous review.

Establishment of professional incident response processes

We help you build a functioning incident response team, define processes, create playbooks, and test them through exercises.

Definition and implementation of reporting processes

Axsos supports you in establishing reliable reporting processes that ensure you meet strict deadlines—including templates, checklists, and training.

Technical implementation

From SIEM systems to firewalls to backup solutions: we implement the technical measures required for your NIS2 compliance.

Training and awareness

We train your employees, management, and IT teams—tailored to their respective roles and responsibilities.

Continuous support and managed services

NIS2 compliance does not end with implementation. Axsos offers long-term support: monitoring, audits, updates, continuous improvement.

Freedom through technology

At Axsos, we see NIS2 not as a burden, but as an opportunity. A secure, stable, well-organized IT infrastructure creates freedom: your IT teams can concentrate on strategic tasks instead of firefighting. Your management can focus on the core business, knowing that cyber risks are being managed professionally. Your organization becomes more resilient, future-proof, and innovative.

Frequently asked questions about NIS2 implementation

Which NIS2 requirements specifically apply to risk management?

NIS2 requires a systematic risk management process involving risk identification, assessment, treatment, and regular reviews. Companies must document and prioritize cyber risks and address them with appropriate technical and organizational measures. Management must approve and monitor the risk assessment. Risk analyses should be carried out at least once a year.

What does an NIS2-compliant incident response process look like?

An NIS2-compliant incident response process includes: (1) preparation with a defined team and processes, (2) detection and analysis of incidents through monitoring, (3) containment to prevent spread, (4) elimination of the cause, (5) restoration of affected systems, (6) follow-up with lessons learned. Clear roles, documented procedures, regular testing, and the ability to meet reporting requirements on time are crucial.

What reporting obligations and deadlines does NIS2 stipulate?

Strict reporting deadlines apply in the event of significant security incidents: (1) early warning within 24 hours of becoming aware of the incident, with initial information; (2) detailed interim report within 72 hours, with assessment and measures; (3) comprehensive final report within approximately one month, with complete documentation and root cause analysis. Violations of reporting deadlines may be subject to sanctions.

How can companies implement NIS2 step by step?

A structured NIS2 implementation follows seven steps: (1) Assess impact and define scope, (2) Conduct inventory and gap analysis, (3) Establish risk management, (4) Set up incident response processes, (5) Define reporting obligations and reporting channels, (6) Establish governance, training, and security culture, (7) Implement continuous improvement and audits. This step-by-step approach makes the extensive requirements manageable.

What role does management play in NIS2?

NIS2 makes cybersecurity a top priority. Management must actively monitor the implementation of security measures, approve security policies, release budgets, and receive regular reports on the security situation. In the event of serious violations, management can be held personally liable. Management must develop cybersecurity expertise and be involved in significant incidents.

How long does it typically take to implement NIS2?

The duration depends on the starting level. Companies with an existing ISMS (e.g., ISO 27001) can often achieve NIS2 compliance in 6-12 months. Companies starting from scratch should plan for 12-24 months. Not only technical implementations are critical, but also the development of processes, training of personnel, and establishment of a security culture. A step-by-step approach with prioritized quick wins is recommended.

Conclusion: NIS2 compliance through structured implementation

The NIS2 requirements are extensive—but they can be managed with a structured, step-by-step approach. The key lies not in technological complexity, but in methodological consistency: clear processes, defined responsibilities, systematic documentation, and continuous improvement.

Three core areas form the foundation of your NIS2 compliance:

Risk management: Understand and manage your cyber risks systematically
Incident Response: Respond professionally and quickly to security incidents
Reporting requirements: Reliably meet regulatory requirements

Companies that view NIS2 as a mere compliance exercise are wasting potential. The directive offers the opportunity to strengthen your cyber resilience in the long term, professionalize processes, and make your organization fit for the future. Investing in NIS2 compliance pays off in many ways: through reduced risks, greater stability, increased efficiency, and a stronger competitive position.

Now is the right time to act. The sooner you start, the more structured and stress-free the implementation will be. The longer you wait, the greater the time pressure will be.

Start your NIS2 implementation now

Take advantage of the expertise of an experienced partner. Axsos supports you every step of the way, from impact analysis and the establishment of risk management and incident response structures to the long-term optimization of your cybersecurity.

Contact us for an NIS2 readiness check. Together, we will assess your current status, identify areas where action is needed, and develop a prioritized roadmap to compliance. We will show you clearly which steps are necessary and how you can implement them systematically.

Create security, stability, and future viability—with processes and an IT infrastructure that meet NIS2 requirements while strengthening your business.

Axsos – Freedom through technology.

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