Cyber Battle Lines Drawn: Inside Italy’s NIS2 Incident Response Shake-Up

On a chilly December morning, as most Italians prepared for the holidays, the nation’s cybersecurity community found something unexpected in its digital stocking: a sweeping set of new guidelines from the National Cybersecurity Agency (ACN). Designed to fortify the country’s cyber defenses under the latest NIS2 directive, these “non-binding indications” are anything but optional for organizations tasked with keeping Italy’s critical infrastructure safe. But as the clock ticks on compliance, are these guidelines a much-needed shield or another bureaucratic hurdle?

The Anatomy of a Cybersecurity Crackdown

The NIS2 directive is Europe’s answer to the escalating threat of cyberattacks targeting essential services and digital infrastructure. Italy, through its Legislative Decree 138/2024, has translated these requirements into national law - making the ACN the country’s digital watchdog. The agency’s recent publication, officially titled “NIS2, Guidelines on the Cybersecurity Incident Management Process,” lays out a battle plan for organizations designated as NIS2 entities.

At its core, the document defines a structured incident management process, mapping out how organizations must detect, respond to, and recover from cyber incidents. The guidelines aren’t just theoretical: they tie each stage of incident response directly to basic security controls that organizations are now expected to implement. This approach is intended to ensure not only compliance, but also real-world resilience - helping organizations bounce back from attacks that could otherwise cripple operations or destroy trust.

What’s Actually Changing?

Under the new regime, organizations will need to document every step of their incident response, from initial detection to final resolution. The guidelines provide a suggested model, but with the ACN’s Determination 379907/2025 looming, compliance isn’t just best practice - it’s mandatory.

Beyond the main text, two appendices serve as both a primer for the uninitiated and a checklist for seasoned IT professionals. The first appendix breaks down the technical basics, while the second lists the security controls considered essential for effective incident management under NIS2. In effect, the guidelines offer both a roadmap and a measuring stick: ignore them at your peril.

A Race Against the Clock

For Italy’s critical infrastructure providers, the message is clear: adapt or risk severe consequences. The ACN’s guidelines are designed to help organizations navigate the labyrinth of NIS2 compliance, but time is running short. As threats evolve and deadlines approach, the real test will be whether these measures can move from paper to practice - before the next major cyber incident strikes.

Conclusion

Italy’s latest push to bolster its cyber defenses marks a turning point in the nation’s digital resilience. The ACN’s guidelines could set the gold standard - or expose just how far organizations still have to go. As the cybersecurity arms race accelerates, one thing is certain: the stakes have never been higher.

WIKICROOK

• NIS2 Directive: The NIS2 Directive is an EU law requiring critical sectors and their suppliers to strengthen cybersecurity and report serious cyber incidents.
• Incident Management: Incident management is the structured approach to detect, respond to, and recover from cybersecurity incidents, aiming to minimize damage and restore operations.
• ACN (Agenzia per la Cybersicurezza Nazionale): ACN is Italy’s National Cybersecurity Agency, overseeing digital protection, managing cyber threats, and enforcing cybersecurity regulations nationwide.
• Security Controls: Security controls are tools, processes, or policies - like firewalls or backups - used to protect computer systems and data from threats and attacks.
• Legislative Decree 138/2024: Legislative Decree 138/2024 enacts NIS2 in Italy, enhancing cybersecurity obligations for key sectors and aligning national law with EU standards.