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🇪🇺 NIS2 / ReCyF

The European NIS2 Directive, transposed in France through the ReCyF framework, imposes cybersecurity obligations on essential and important entities in critical sectors.

1What is NIS2?

La directive NIS2 (Network and Information Security 2) significantly expands the previous NIS Directive to many sectors (energy, healthcare, transport, digital services, industry, waste management, etc.) and imposes cybersecurity obligations proportionate to the entity's status— essential or important —determined by its sector and size.

Rather than being a standalone risk-analysis method, NIS2 has two practical components: a compliance framework (controls organised into security objectives that can be assessed requirement by requirement like an ISO 27001 audit) and operational obligations —incident management with strict notification deadlines, supplier-risk management, and business continuity.

In Polyodos, requirement-by-requirement compliance tracking takes place in the Audit module (using a dedicated framework); the NIS2 module handles entity classification and the three operational registers, without duplicating the audit.

2The process, step by step

1. Classify the entity

Determine whether the organisation is an essential entity or important based on its sector and size. This status determines which objectives apply; essential entities have a broader scope.

2. Assess the 20 security objectives (4 pillars)

Review the objectives grouped into four pillars—governance, protection, defence, and resilience—and rate each one as compliant, partially compliant, non-compliant, or not applicable under the entity's regime.

3. Maintain the incident register

Record and track every significant incident and its regulatory milestones, calculated from the detection date (not the reporting date): early warning within 24 hours, incident notification within 72 hours, and final report within one month.

4. Maintain the critical-supplier register

Map service providers and suppliers whose compromise would affect the entity. This is the operational counterpart of the EBIOS RM ecosystem.

5. Maintain the business-continuity plan

Document continuity and recovery arrangements for major incidents.

3Example completed in Polyodos

Section to be completed — step-by-step example classifying an important entity and reporting an incident with its milestones, with Polyodos screenshots.

4Common mistakes

MistakeWhy it is a problem
Calculating deadlines from the report dateNIS2 milestones (24 hours, 72 hours, and one month) run from incident detection , not from when the team decides to report it.
Duplicating requirement-by-requirement trackingDetailed requirement compliance belongs in the Audit module. Rebuilding it in parallel in the NIS2 module would cause the records to diverge.
Marking out-of-scope objectives as non-compliantAn objective outside the entity's regime (e.g. OS16–OS20 for an important entity) must be marked not applicable, not recorded as a gap.
Attaching registers to a projectIncident, supplier, and continuity registers belong to the account or organisational group, not to an analysis project. Opening or closing a project must not change their content.

5Further reading

FR