NIS 2 Guide: Zero-trust Framework as the Key to Compliance

Why NIS-2 and Zero Trust Are Crucial for Your Cybersecurity

The NIS-2 Directive mandates thousands of companies in Europe to adhere to higher cybersecurity standards. Meanwhile, the national implementation is delayed in many member states. This makes a strategic security approach that is effective today, regardless of the legal status, even more important. The Zero Trust Framework provides the ideal structure for this.

Digitalization not only opens up new business opportunities but also significantly intensifies the threat landscape. NIS-2 requires companies to make both technological and organizational adjustments—particularly flexible security strategies that can continuously adapt to new threats.

Zero Trust and NIS-2: Is It the Solution?

Zero Trust and the NIS-2 Directive are gaining increasing importance in the field of cybersecurity. Zero Trust is based on distrusting every network process and participant, while NIS-2 standardizes security measures across Europe. Both concepts complement each other to protect organizations against growing threats and promote a robust security architecture.

Preparing for Zero Trust and NIS-2 Compliance

Preparing for Zero Trust and NIS2 compliance is crucial to meet the IT security requirements of today’s digital landscape. Take proactive measures to protect your systems and data, including implementing strict authentication processes and continuous monitoring to detect potential threats early.

Zero Trust as a NIS-2 Requirement

The NIS-2 Directive highlights the importance of Zero Trust and calls on all affected companies to rethink their security architecture. Zero Trust minimizes risks through continuous verification and validation of access. This ensures that only authorized users have access to sensitive data, significantly enhancing cybersecurity.

NIS-2 Compliance: Overview of Extended Requirements

The NIS-2 Directive marks an important milestone in harmonizing European cybersecurity standards. Unlike its predecessor NIS-1, NIS-2 encompasses a significantly expanded scope with stricter requirements.

It targets not only large infrastructures but also includes SMEs and organizations that are essential for critical societal and economic functions (e.g., the energy sector or healthcare).

Zero Trust Framework: Paradigm Shift for Effective NIS-2 Compliance

The Zero Trust Framework revolutionizes traditional security models with its consistent approach of fundamentally not trusting any user or system. This philosophy is based on the recognition that threats can come from both outside and inside.

The resulting paradigm shift in security architecture relies on three core elements:

• Strict access control
• Comprehensive monitoring
• Effective micro-segmentation

Zero Trust Core Principles for Successful NIS-2 Compliance

“Never Trust, Always Verify”: The Zero Trust Principle

Zero Trust eliminates the concept of trusted zones within a network. The security model treats every user and system as potentially compromised until proven otherwise. Every access attempt undergoes strict scrutiny under the principle of “Never trust, always verify.”

The three pillars of Zero Trust include:

1. Strict Access Control: Only authorized users gain access to specific resources. Continuous authentication significantly minimizes insider threats.
2. Network Micro-segmentation: The network is divided into isolated, better-protected units. This architecture drastically limits attackers’ lateral movement within the network.
3. Comprehensive Data Encryption: Sensitive data is protected both at rest and during transmission, elevating data security to a new level.

Zero Trust Framework as a Data Security Model for Maximum Protection

The Zero Trust Framework forms the foundation for an advanced data security model in modern IT environments. It does not automatically trust any user or device, regardless of their position inside or outside the network.

This model requires continuous verification and encryption to effectively protect data.

NIS-2 Directive: Concrete Compliance Requirements for Companies

NIS-2 Risk Management According to Article 21: Obligations and Solutions

Article 21 of the NIS-2 Directive requires systematic risk management. Companies must:

• Conduct comprehensive risk analyses
• Identify and assess vulnerabilities
• Implement tailored security measures
• Establish regular reviews
• Introduce continuous evaluation mechanisms

Zero Trust optimally supports these requirements through its adaptability to constantly changing threat scenarios.

NIS-2: Implementing Technical and Organizational Measures (TOMs)

The NIS-2 Directive also requires effective technical and organizational measures for the highest security standards:

• Multi-layered access controls
• Advanced encryption protocols
• Resilient network infrastructure
• Systematic security audits

Affected companies must be able to document and demonstrate the effectiveness of these measures. The monitoring and logging system embedded in the Zero Trust Framework significantly simplifies this obligation.

NIS-2 Reporting Obligations According to Article 23: Timelines and Compliance

Article 23 defines mandatory reporting timelines for security incidents to limit potentially larger impacts and proactively prevent incidents across Europe:

• Initial report: within 24 hours of discovery
• Detailed report: within 72 hours
• Final analysis: after 30 days

Zero Trust enables compliance with these deadlines through continuous monitoring and comprehensive logging of all network activities. With flexible reporting options, it is possible to quickly evaluate all file and user activities and securely send a comprehensive report to the responsible reporting authority, encrypted.

Implementing Zero Trust Framework for NIS-2 Compliance in Practice

Zero Trust Framework in Practice: Implementation Without Operational Disruption

Zero Trust can be seamlessly integrated into existing IT infrastructures—providing a crucial advantage for NIS-2 compliance.

Instead of a complete system overhaul, targeted additions allow for gradual security improvements without operational disruptions.

The flexible Zero Trust approach allows for a step-by-step optimization of the security architecture during ongoing operations. This integration not only enhances security but also improves system efficiency.

NIS-2 Compliant Authentication: Implementing Secure Access Control

Establishing robust authentication mechanisms forms the foundation of any Zero Trust implementation:

• Multi-factor Authentication (MFA) for all users at login
• Biometric verification at critical access points
• Contextual authentication based on location, device, or behavior patterns
• Regular re-authentication even during active sessions

Zero Trust Framework Through Micro-segmentation: Implementation Steps

Micro-segmentation divides your network into isolated zones with strict traffic control between segments. Successful implementation can be achieved in five steps:

1. Inventory network resources: Create a complete inventory of all systems, applications, and data.
2. Analyze data traffic: Identify legitimate communication patterns between different systems.
3. Define segments: Group resources based on security requirements and data classification.
4. Establish traffic policies: Precisely determine which communication between segments is allowed.
5. Set up a monitoring system: Implement continuous monitoring of cross-segment traffic.

Zero Trust Monitoring: Detecting and Reporting Security Incidents

A powerful logging and monitoring system is indispensable for NIS-2 compliant incident response. Effective systems must:

• Log network activities in real-time
• Conduct automated anomaly detection
• Trigger immediate alerts for suspicious activities
• Ensure centralized log collection and analysis

NIS-2 Compliant Supply Chain Security Through Zero Trust Framework

The NIS-2 Directive requires comprehensive security along the entire supply chain. The Zero Trust Framework supports this requirement by:

• Precise access controls for external service providers
• Strict resource restrictions based on the principle of least privilege
• Comprehensive monitoring of all external accesses
• Regular reassessment of access permissions

NIS-2 Compliance Checklist: Five Steps to Zero Trust Framework Implementation

For successful NIS-2 compliance and enhanced cybersecurity, we recommend these five core steps:

1. Conduct a comprehensive inventory: Identify and classify all data, applications, devices, and users in your network.
2. Establish Zero Trust access control: Implement strict authentication mechanisms (e.g., MFA) and the principle of least privilege (e.g., in the form of role-based rights management: read, write, delete).
3. Consistently segment the network: Divide your network into logical segments with strict and cross-segment traffic control.
4. Implement comprehensive monitoring: Introduce comprehensive monitoring and logging systems and continuously evaluate the results with weekly and/or monthly reports.
5. Conduct regular security reviews: Continuously test your security measures with penetration tests and audits.

NIS-2 Implementation in Europe: Country Overview and Strategies

NIS-2 in Germany: Delays and Recommendations

The implementation of the NIS-2 Directive in Germany is significantly delayed. The originally planned national implementation through the “NIS2 Implementation and Cybersecurity Strengthening Act” (NIS2UmsuCG) has been postponed multiple times—also due to political uncertainties surrounding the federal election. To date, no finalized legal text is available. Nevertheless, the Federal Ministry of the Interior and Community (BMI) is working intensively with the Federal Office for Information Security (BSI) on the implementation.

The BSI is preparing information packages for affected companies and plans to establish a central reporting platform through which security incidents can be recorded in compliance with NIS-2 in the future. Companies should not be complacent despite the delay, as the draft law is expected to contain very specific requirements for reporting obligations, risk management, and minimum standards.

Recommended measures for German companies:

• Conduct a gap analysis based on NIS-2 requirements
• Gradually introduce a Zero Trust Framework (e.g., MFA, micro-segmentation, monitoring)
• Develop a documented incident response plan
• Raise awareness and train employees on NIS-2 and Zero Trust

NIS-2 Pioneer France: Implementation Details and Best Practices

France is one of the first EU countries to present a draft law for the national implementation of NIS-2. On October 15, 2024—two days before the EU implementation deadline—the draft law titled “Loi relatif à la résilience des activités d’importance vitale, à la protection des infrastructures critiques, à la cybersécurité et à la résilience opérationnelle numérique du secteur financier” was introduced in the French Parliament, defining clear responsibilities and concrete sanctions for violations. The National Institute for Security Studies and Culture (ANSSI) acts as the central enforcement authority.

Notably, the scope has been expanded to include all departments, municipalities with over 30,000 inhabitants, overseas territories, and research institutions—France thus goes significantly beyond the EU minimum requirements.

Additionally, the French government pursues a holistic approach: The draft law integrates not only NIS-2 but also DORA and the Directive on the Resilience of Critical Entities (RCE). French companies should familiarize themselves early with the combined requirements, examine their potential scope, and actively engage with ANSSI. A Zero Trust Framework provides a robust foundation for meeting the new requirements—particularly through granular access controls, network segmentation, and continuous monitoring.

NIS-2 in Spain: Bridging Regulatory Gaps

Unlike France, Spain is significantly lagging in the implementation of the NIS-2 Directive and is among the laggards within the EU. To date, no official draft law for national implementation has been published. Public discussions or stakeholder dialogues are also hardly noticeable. Spain has clearly missed the legally set deadline for implementation on October 17, 2024.

This regulatory uncertainty means that companies do not have clear national guidelines available—although the requirements from the EU Directive are known. Affected organizations are therefore well advised to immediately align themselves with the European Directive and prepare technically for a higher security level.

Recommended measures for companies in Spain:

• Direct alignment with Articles 21 and 23 of the EU Directive
• Introduction of a Zero Trust Framework focusing on access control, network segmentation, and monitoring
• Evaluation and updating of existing technical and organizational measures
• Establishment of incident reporting processes according to the deadlines defined in NIS-2

United Kingdom and NIS-2: Brexit-Compatible Cybersecurity Standards

Although the United Kingdom is not directly obligated to implement NIS-2 post-Brexit, the national cybersecurity legislation closely aligns with NIS-2 principles.

For British companies with EU business relationships, alignment with NIS-2 is particularly important. Aligning with EU standards offers strategic advantages:

• Smooth international data exchange
• Consistent security architecture for multinational companies
• Improved global competitiveness

NIS-2 Compliance Strategies for International Companies

Despite different national implementation statuses, all companies share similar NIS-2 challenges:

• Complex compliance requirements
• Shortage of skilled professionals in the cybersecurity field
• High investment costs for advanced security technologies

For internationally active companies, it is recommended:

• Unified Zero Trust Framework for all locations
• Flexible, country-specific adaptable compliance programs
• Central cybersecurity team with expertise in national regulations

The expected timeline for full NIS-2 implementation in Europe:

• Pioneer countries (France): Implementation by the end of 2025
• Countries with delays (Germany): New draft law by fall 2025; implementation by mid-2026
• Laggards (Spain): End of 2026 or early 2027

Conclusion: Zero Trust as the Key to NIS-2 Compliance and Digital Resilience

The Zero Trust Framework proves to be an indispensable strategy for effective NIS-2 compliance and sustainable cyber resilience. By implementing this security model early, you can not only meet regulatory requirements but also elevate your entire security architecture to a new level.

In a time of growing cyber threats and inconsistent NIS-2 implementation in Europe, it is advisable to act proactively. A consistent Zero Trust Framework ensures NIS-2 compliance regardless of national legal status and simultaneously strengthens long-term competitiveness.

As our headline already makes clear: The Zero Trust Framework is the key to NIS-2 compliance—a key that not only fulfills regulatory requirements but also unlocks access to a more resilient digital future.

Kiteworks: Zero Trust for Maximum Protection of Sensitive Data

A proactive Zero Trust strategy not only provides protection but also the necessary resilience and agility for a secure digital future. The successful transition to a Zero Trust security model therefore requires a structured approach that goes beyond classic network security. Data classification, identity-based access controls, encryption, continuous monitoring, and cloud security are essential building blocks to effectively protect sensitive information, prevent unauthorized access, and consistently meet regulatory requirements.

Kiteworks applies Zero Trust where it matters: directly at the data. Instead of relying solely on network boundaries, Kiteworks offers a Zero Trust Data Exchange Platform that authenticates every access, encrypts every transmission, and monitors every interaction—regardless of where the data is located. With Kiteworks’ features, the protection of sensitive information is ensured throughout its entire lifecycle.

• Comprehensive encryption of all data at rest and in transit with AES-256 technology
• Granular access controls with dynamic policies that adapt based on user behavior and data sensitivity
• Automated compliance checks for regulatory requirements such as GDPR, BDSG, and industry-specific standards
• Detailed logging of all access attempts with AI-supported anomaly detection and real-time threat response
• Stateless editing without local file storage for secure document collaboration

By adopting Kiteworks’ data-driven Zero Trust model, you can reduce your attack surface, ensure compliance with data protection regulations, and protect sensitive content against evolving cyber threats.

The Private Content Network from Kiteworks offers sophisticated access controls that combine granular permissions with Multi-factor Authentication (MFA) to ensure that every user and device is thoroughly verified before accessing sensitive information. Through strategic micro-segmentation, Kiteworks creates secure, isolated network environments that prevent lateral movement of threats while maintaining operational efficiency.

Furthermore, end-to-end encryption protects data both during transmission and at rest with powerful encryption protocols such as AES 256 Encryption and TLS 1.3. Finally, a CISO Dashboard and comprehensive audit logs provide extensive monitoring and logging capabilities, offering companies complete transparency over all system activities and enabling rapid response to potential security incidents.

For companies seeking a proven Zero Trust solution that does not compromise on security or user-friendliness, Kiteworks offers a compelling solution. To learn more, schedule a personalized demo today.