Paper Shields: Why Last-Minute Incident Plans Spell Disaster Under NIS 2

The clock is ticking for organizations across Europe as the NIS 2 Directive’s incident notification mandate looms ever closer. In boardrooms and IT departments alike, a frantic rush is underway: dust off the templates, tweak the procedures, and hope that a well-padded document will keep the regulators at bay. But behind this paper chase lies a perilous myth - one that could leave companies utterly unprepared when a real cyber crisis hits.

The Dangerous Comfort of Compliance on Paper

Many organizations, from public agencies to private firms, have only just realized that the NIS 2 Directive’s incident notification requirements are not a distant concern - they’re imminent. The instinctive response? Assemble incident management procedures at breakneck speed, often by recycling generic templates or repurposing ISO documentation. These documents may look polished and reference all the right regulations, but they’re little more than a façade if they don’t reflect true operational readiness.

The core problem: NIS 2 is not about having a “nice” procedure on file. It’s about having the processes, people, and systems in place to recognize, assess, and respond to a cyber incident in real time. The difference is stark - one is a box-ticking exercise, the other is a matter of survival when an attack unfolds.

ISO 27001 vs. NIS 2: Parallel Tracks, Not Interchangeable

Confusion often arises from treating ISO/IEC 27001 certification as a panacea. While ISO 27001 sets out strong information security management principles, it’s not designed to ensure the rapid, coordinated response demanded by NIS 2. The ACN’s 2025 guidelines, inspired by the NIST Cybersecurity Framework 2.0, go further - demanding clear roles, evidence preservation, traceability, and real-world decision-making under pressure.

Crucially, not every incident needs to be reported to the ACN, but all must be systematically managed and documented. This requires much more than a borrowed policy - it demands tested, integrated processes and a culture of readiness.

The Audit Reality: Action Over Appearance

When the ACN comes knocking, it won’t be to admire your paperwork. Inspectors want proof: operational coherence, demonstrable decision-making, and a clear audit trail of who did what, when, and why. Organizations relying on last-minute, off-the-shelf solutions may clear a regulatory deadline, but they risk spectacular failure when a real incident strikes - and that’s when the true test of compliance, and resilience, arrives.

Conclusion

As the NIS 2 deadline approaches, the temptation to “get compliant” with paperwork alone is strong - but dangerously misguided. True readiness is measured not by the quality of your templates, but by your ability to act swiftly, decisively, and transparently when the worst happens. In the new era of cyber regulation, only genuine organizational maturity - not last-minute paperwork - will stand the test of crisis.

WIKICROOK

• NIS 2 Directive: The NIS 2 Directive is an EU law requiring stronger cybersecurity and incident reporting from critical infrastructure and digital service providers.
• Incident Management: Incident management is the structured approach to detect, respond to, and recover from cybersecurity incidents, aiming to minimize damage and restore operations.
• ISO/IEC 27001: ISO/IEC 27001 is a global standard for managing information security, guiding organizations to protect data and manage risks through an ISMS framework.
• NIST Cybersecurity Framework: A set of guidelines by NIST to help organizations identify, manage, and reduce cybersecurity risks across industries and sectors.
• ACN (National Cybersecurity Agency): ACN is Italy’s authority for national cybersecurity, overseeing cyber defense, incident response, and regulatory compliance for public and private sectors.