The CRA's 24-hour reporting duty has applied since 11 September 2026. Check whether it reaches you

NIS2: all pages and articles

Implementing Regulation (EU) 2024/2690 · Annex

NIS2, mapped to ISO 27001

Most of what NIS2 asks for technically is the same in every member state, because that part is a Regulation rather than a Directive, and it was written from ISO 27001. If you run a conforming ISMS you have already built most of this. Here is the whole Annex, section by section, and the two places it asks for more.

Who this is for
An essential or important entity under NIS2, or a supplier one of them is asking, that already runs or is building an ISO/IEC 27001 management system and wants to know how much of Article 21 it already answers.
What maps
All 10 measures of Article 21(2), each to the ISO/IEC 27001 clauses and Annex A controls whose records evidence it: 73 controls and 14 clauses in total, StandardOS's reading, downloadable as a CSV below.
What does not
6 places where the Implementing Regulation asks for something no ISO 27001 record produces, listed further down; and the Directive's own duties, the registration, the management body's training and the incident clocks, which sit beside the ISMS, not inside it.

The ten measures of Article 21(2), mapped

One row per point of the Directive: the measure in plain words, the Directive's own text, and the ISO/IEC 27001 clauses and Annex A controls whose records evidence it. Essential and important entities alike.

Article 21(2) points (a) to (j) mapped to ISO/IEC 27001 clauses and Annex A controls
PointMeasureClausesAnnex A controls
21(2)(a)Have a risk analysis and security policypolicies on risk analysis and information system securityClause 5.1Clause 5.2Clause 5.3Clause 6.1.2Clause 6.1.3Clause 8.2Clause 8.3A.5.1A.5.2A.5.3A.5.4A.5.7A.5.36A.5.35
21(2)(b)Handle incidents by a written procedureincident handlingA.5.24A.5.5A.8.15A.8.16A.8.17A.6.8A.5.25A.5.26A.5.28A.5.27
21(2)(c)Keep backups, a recovery plan and crisis managementbusiness continuity, such as backup management and disaster recovery, and crisis managementA.5.29A.5.30A.8.13A.8.14A.5.5A.5.7A.7.11A.7.12
21(2)(d)Secure your supply chain and direct supplierssupply chain security, including security-related aspects concerning the relationships between each entity and its direct suppliers or service providersA.5.19A.5.20A.5.21A.5.22A.5.23
21(2)(e)Build, buy and maintain systems securely, vulnerabilities handledsecurity in network and information systems acquisition, development and maintenance, including vulnerability handling and disclosureA.8.26A.5.21A.8.25A.8.27A.8.28A.8.29A.8.30A.8.31A.8.33A.8.9A.8.32A.8.8A.8.19A.8.20A.8.21A.8.22A.8.7A.5.7A.7.5A.7.8
21(2)(f)Assess whether your security measures workpolicies and procedures to assess the effectiveness of cybersecurity risk-management measuresClause 9.1Clause 9.2Clause 9.3Clause 10.1Clause 10.2
21(2)(g)Practise basic cyber hygiene and train everyonebasic cyber hygiene practices and cybersecurity trainingClause 7.3Clause 7.2A.6.3
21(2)(h)Have a policy on cryptography and encryptionpolicies and procedures regarding the use of cryptography and, where appropriate, encryptionA.8.24
21(2)(i)Manage people security, access control and assetshuman resources security, access control policies and asset managementA.6.2A.5.4A.6.1A.6.5A.6.6A.6.4A.5.15A.5.18A.5.3A.8.3A.8.2A.8.5A.8.18A.5.16A.5.17A.5.12A.5.10A.5.14A.7.14A.8.10A.7.10A.8.7A.5.9A.5.11A.7.1A.7.2A.7.3A.7.4
21(2)(j)Use multi-factor authentication and secured communicationsthe use of multi-factor authentication or continuous authentication solutions, secured voice, video and text communications and secured emergency communication systems within the entity, where appropriateA.5.17A.8.5

The mapping is StandardOS's reading of which records evidence which measure; NIS2 names no standard and grants no presumption of conformity, and the Implementing Regulation's sections below add the detail the Directive leaves open.

Two different instruments, and only one of them is portable

The controls are a Regulation. Implementing Regulation (EU) 2024/2690 applies directly in all 27 member states: the same text, no national version. Everything around them is a Directive. Registration, which authority supervises you, the filing portal and the penalties all come from 27 separate national laws that differ in substance. This page covers the first and deliberately says nothing about the second.

The national laws themselves, as each state communicated them to the Commission, are on their own page: NIS2 transposition by member state.

Recital 3 of the Regulation is explicit about where its requirements come from. They are “based on European and international standards, such as ISO/IEC 27001, ISO/IEC 27002 and ETSI EN 319401”. That is what makes a crosswalk possible rather than approximate.

The Annex, section by section

1. Policy on the security of network and information systems

Art. 21(2)(a) NIS2

Satisfied by

  • 1.1Policy on the security of network and information systems Clause 5.1Clause 5.2A.5.1
  • 1.2Roles, responsibilities and authorities Clause 5.3A.5.2A.5.3A.5.4

Not covered by ISO 27001: The floors. 1.1.2 has the management bodies review the policy at least annually, and 1.2.3 requires at least one person who reports directly to the management bodies on network and information security. ISO 27001 has top management review at planned intervals and names no such reporting line.

2. Risk management policy

Art. 21(2)(a) NIS2

Satisfied by

  • 2.1Risk management framework Clause 6.1.2Clause 6.1.3Clause 8.2Clause 8.3A.5.7
  • 2.2Compliance monitoring A.5.36
  • 2.3Independent review of information and network security A.5.35

Not covered by ISO 27001: The annual floor. 2.1.4 requires the risk assessment results and the risk treatment plan to be reviewed at planned intervals and at least annually. ISO 27001 sets the intervals and no floor under them.

3. Incident handling

Art. 21(2)(b) NIS2

Satisfied by

Not covered by ISO 27001: The statutory clock. ISO 27001 requires an incident process; it does not require a 24-hour early warning, a 72-hour notification, dual filing to a CSIRT and a competent authority, or a significance test. IR Arts. 3–14 make those mechanical and EU-uniform. Art. 3(1)(a) is €500,000 or 5% of turnover, whichever is lower, and none of it falls out of an ISMS by itself. And the logs: 3.2.5 keeps logs and backs them up for a predefined period, protected from unauthorised access or change. A.8.15 asks for logging; it does not require the logs themselves to be backed up for a set period.

4. Business continuity and crisis management

Art. 21(2)(c) NIS2

Satisfied by

5. Supply chain security

Art. 21(2)(d) NIS2

Satisfied by

6. Security in network and information systems acquisition, development and maintenance

Art. 21(2)(e) NIS2

Satisfied by

7. Policies and procedures to assess the effectiveness of cybersecurity risk-management measures

Art. 21(2)(f) NIS2

Satisfied by

  • 7.1(untitled point: the section's requirement itself) Clause 9.1Clause 9.2Clause 9.3
  • 7.2(untitled point: the section's requirement itself) Clause 9.1
  • 7.3(untitled point: the section's requirement itself) Clause 10.1Clause 10.2

8. Basic cyber hygiene practices and security training

Art. 21(2)(g) NIS2

Satisfied by

  • 8.1Awareness raising and basic cyber hygiene practices Clause 7.3A.6.3
  • 8.2Security training Clause 7.2A.6.3

Not covered by ISO 27001: Training the management body. Art. 20(2) NIS2 requires members of the management body themselves to follow training, and Art. 20(1) makes them personally liable for approving and overseeing the measures. ISO 27001 asks for leadership commitment and competence; it does not put the board in the training register or attach liability to the signature.

9. Cryptography

Art. 21(2)(h) NIS2

Satisfied by

  • 9.1(untitled point: the section's requirement itself) A.8.24
  • 9.2(untitled point: the section's requirement itself) A.8.24
  • 9.3(untitled point: the section's requirement itself) A.8.24

10. Human resources security

Art. 21(2)(i) NIS2

Satisfied by

Not covered by ISO 27001: The annual floor. 10.1.3 has the entity review its human resources security, including the resources it commits to it, at planned intervals and at least annually. ISO 27001 sets the intervals and no floor under them.

11. Access control

Art. 21(2)(i, j) NIS2

Satisfied by

Not covered by ISO 27001: Multiple factors. 11.3.2 requires strong identification and authentication such as multi-factor authentication for privileged and system administration accounts, 11.7 requires users to be authenticated by multiple factors or continuous authentication, and 11.6.2(e) terminates inactive sessions after a predefined period. A.8.5 asks for secure authentication and names none of the three.

12. Asset management

Art. 21(2)(i) NIS2

Satisfied by

13. Environmental and physical security

Art. 21(2)(c, e, i) NIS2

Satisfied by

Where an ISMS stops, in 6 places

Everything else in that Annex falls out of a conforming ISO 27001 management system. These do not, and no amount of ISO conformity produces them:

  • 1. Policy on the security of network and information systems

    The floors. 1.1.2 has the management bodies review the policy at least annually, and 1.2.3 requires at least one person who reports directly to the management bodies on network and information security. ISO 27001 has top management review at planned intervals and names no such reporting line.

  • 2. Risk management policy

    The annual floor. 2.1.4 requires the risk assessment results and the risk treatment plan to be reviewed at planned intervals and at least annually. ISO 27001 sets the intervals and no floor under them.

  • 3. Incident handling

    The statutory clock. ISO 27001 requires an incident process; it does not require a 24-hour early warning, a 72-hour notification, dual filing to a CSIRT and a competent authority, or a significance test. IR Arts. 3–14 make those mechanical and EU-uniform. Art. 3(1)(a) is €500,000 or 5% of turnover, whichever is lower, and none of it falls out of an ISMS by itself. And the logs: 3.2.5 keeps logs and backs them up for a predefined period, protected from unauthorised access or change. A.8.15 asks for logging; it does not require the logs themselves to be backed up for a set period.

  • 8. Basic cyber hygiene practices and security training

    Training the management body. Art. 20(2) NIS2 requires members of the management body themselves to follow training, and Art. 20(1) makes them personally liable for approving and overseeing the measures. ISO 27001 asks for leadership commitment and competence; it does not put the board in the training register or attach liability to the signature.

  • 10. Human resources security

    The annual floor. 10.1.3 has the entity review its human resources security, including the resources it commits to it, at planned intervals and at least annually. ISO 27001 sets the intervals and no floor under them.

  • 11. Access control

    Multiple factors. 11.3.2 requires strong identification and authentication such as multi-factor authentication for privileged and system administration accounts, 11.7 requires users to be authenticated by multiple factors or continuous authentication, and 11.6.2(e) terminates inactive sessions after a predefined period. A.8.5 asks for secure authentication and names none of the three.

What this page is not

It is not a coverage score. A single percentage for how much of NIS2 ISO 27001 covers gets quoted in a lot of places. Every version of it is a structural judgement rather than a measurement, and we are not going to repeat a number we cannot show the working for. ENISA published a machine-readable crosswalk in its Technical Implementation Guidance (v1.0, June 2025); the mapping above is ours, from the two documents, and you should check it against theirs rather than trust either of us.

It is not a NIS2 product. StandardOS does not register you with a national authority, does not file your incident reports, and does not track 27 national transpositions. If you need those, you need something else, and the honest version of our position is that the control set is the part worth building once, because it is the only part that is the same everywhere.

It is not a scope determination. NIS2 binds essential and important entities above the size thresholds in Article 2. Below roughly 50 people and €10m you are very likely outside it entirely, with sector exceptions. That determination is yours to make and record, and we will not make it for you on a marketing page.

The questions people ask

Is ISO 27001 enough for NIS2?
For the technical measures, most of the way: the ten measures of Article 21(2) map to 73 Annex A controls and 14 clauses of a conforming ISO/IEC 27001 system, and the Implementing Regulation was written from the same vocabulary. Not all the way: 6 places in the Implementing Regulation ask for records no ISMS produces, and the registration, the management body's approval and training, and the 24-hour and 72-hour incident clocks are duties of the Directive outside the standard.
NIS2 vs ISO 27001: what is the difference?
NIS2 is law: a Directive transposed by each member state, with a supervisor, registration, incident reporting clocks and fines, binding on the entity types it lists. ISO/IEC 27001 is a standard a company chooses and a certification body audits. The one reads like the other because the Implementing Regulation borrowed the standard's structure, so the ISMS is the shortest route to the technical half of NIS2, and the Directive's duties are the other half.
Does NIS2 require ISO 27001 certification?
No. The Directive names no standard and no member state's transposition makes certification a condition; Article 25 says member states shall encourage the use of European and international standards. A certificate is evidence a supervisor and a customer accept quickly, not a requirement.
Which ISO 27001 controls cover NIS2 incident handling?
Article 21(2)(b), incident handling, maps to the Annex A controls on incident management planning, event assessment, response, learning and evidence, with the clauses on operational planning and monitoring; the reporting clocks of Article 23 are the Directive's own and run beside the standard, which is why the incident clock page exists.

Further reading

The overlap is the point

If a customer's questionnaire is really asking whether you manage security the way the Regulation describes, an ISO 27001 ISMS is the answer to eleven of these thirteen sections. StandardOS builds that ISMS: the Statement of Applicability, the risk register and the evidence trail. The export is organised by Annex A reference, which is the same vocabulary the table above uses.

Section titles are quoted from the Annex to Implementing Regulation (EU) 2024/2690 as published on EUR-Lex, read on 10 August 2026. The mapping to ISO/IEC 27001 is our own and is not ENISA's. This is not legal advice, and the Regulation is short enough to read yourself: Implementing Regulation (EU) 2024/2690.

This page in:DeutschFrançaisNederlandsEspañolDansk