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CompanyAcme Manufacturing Srl
SectorManufacturing — medical devices
Size150 employees (medium)
CountriesItaly, Germany, Bulgaria
IT team2 IT staff, no dedicated security
NIS2 tierImportant Entity

NIS2 Compliance Assessment Report

Generated by SerafinIT Compliance Engine · ENISA-aligned · July 2026 · Sample Report

DefinedOverall maturity
44%Readiness score (1.8/4)
4Critical gaps
13Domains assessed
ENISA Maturity Scale:
0 — Initial
1 — Managed
2 — Defined
3 — Quantitatively Managed
4 — Optimising
1.8

Overall NIS2 readiness: Defined

Acme Manufacturing has established some documented security controls — particularly in physical security and HR — but critical gaps remain in incident response, access control, and supply chain security. As an Important Entity operating medical device manufacturing across three EU member states, the organisation faces both NIS2 obligations and potential MDCG cybersecurity guidance. Immediate action on the critical gaps is required to avoid supervisory exposure.

Medical device manufacturers are subject to both NIS2 (as Annex II important entities) and sector-specific cybersecurity requirements under MDR/IVDR. Evidence of cybersecurity governance will increasingly be expected by notified bodies during conformity assessments.
Security Policy
2.0Defined
Risk Management
1.5Managed
Incident Handling
0.7Initial
Business Continuity
2.0Defined
Supply Chain
0.5Initial
System Security
1.5Managed
Effectiveness Review
1.0Managed
Cyber Hygiene
2.5Defined
Cryptography
1.0Managed
HR Security
2.5Defined
Access Control
0.7Initial
Asset Management
1.5Managed
Physical Security
3.5Q. Managed
Domain-by-domain analysis — all 13 domains (click to expand)
2.0

Domain 1: Security Policy

Defined · Art. 21(2)(a) · Policy on Security of Network and Information Systems

›
◑ Partial compliance

A documented security policy exists and has been approved by management, but it has not been reviewed in over 18 months. NIS2 requires policies to be regularly reviewed — at minimum annually, and following significant operational changes. The policy does not yet reference NIS2 obligations specifically.

✓ Compliant

Cybersecurity roles and responsibilities are documented and communicated to relevant staff. A named IT manager holds day-to-day security responsibility.

◑ Board engagement needed

Senior management has not been formally briefed on NIS2 personal liability obligations under Article 20. This represents a governance gap — board sign-off on cybersecurity strategy is a mandatory NIS2 requirement, not best practice.

Evidence provided by company: "We have an IT security policy document from 2022, signed by the MD. Roles are assigned informally — our IT manager covers most things."
1.5

Domain 2: Risk Management

Managed · Art. 21(2)(a) · Risk Analysis and Treatment

›
◑ Partial compliance

Annual risk assessments are conducted but documentation is inconsistent and a formal risk register does not exist. NIS2 requires a structured, documented risk management process with traceable treatment plans and ownership.

⚠ Gap identified

No independent cybersecurity audit has been conducted in the past 3 years. NIS2 Important Entities are subject to reactive supervision — but an audit trail demonstrating proactive risk management will be critical when the competent authority does engage.

◑ Partial compliance

Compliance monitoring relies on informal IT staff checks. No defined metrics, KPIs, or escalation procedures for identified risk deviations exist.

0.7

Domain 3: Incident Handling

Initial — Critical Gap · Art. 21(2)(b) + Art. 23 · Incident Detection, Response & Reporting

›
⚠ Critical gap

No formal Incident Response Plan (IRP) exists. Article 21(2)(b) explicitly mandates documented incident handling procedures. Without a tested IRP, the 24-hour early warning obligation under Article 23 cannot be met — this is the single highest regulatory risk identified in this assessment.

⚠ Critical gap

No Incident Response Owner has been named. In the event of a cyberattack, there is no defined escalation chain, no pre-identified national CSIRT contact, and no communication procedure. Recovery would be entirely ad hoc.

⚠ Gap identified

Current detection capability consists of basic endpoint antivirus only. There is no centralised logging, no SIEM, and no alerting system. Incidents could remain undetected for days or weeks — making the 24-hour reporting window effectively impossible without automation.

◑ Partial

Post-incident reviews are conducted informally after major IT issues. These should be formalised with documented root-cause analysis, remediation tracking, and lessons-learned integration into policy updates.

Evidence provided by company: "We don't have a formal incident plan. Our IT manager handles problems as they come up. We've had one ransomware attack in 2022 which took 3 days to recover from."
2.0

Domain 4: Business Continuity

Defined · Art. 21(2)(c) · BCP & Disaster Recovery

›
◑ Partial compliance

An IT recovery plan exists covering hardware failures but does not address cybersecurity scenarios — ransomware, data breach, or DDoS. Given the 2022 ransomware incident, this is an urgent gap. NIS2 requires BCP to explicitly cover cyber incident scenarios.

✓ Compliant

Automated daily backups are in place with offsite cloud copies. Restore tests are conducted quarterly. This is a strong foundation — but immutable backups (unmodifiable by ransomware) should be considered as an enhancement.

◑ Partial compliance

RTOs and RPOs are defined informally for the ERP system but not for all critical systems. No formal crisis communication procedure exists for external stakeholders (customers, regulators, press).

0.5

Domain 5: Supply Chain Security

Initial — Critical Gap · Art. 21(2)(d) · Supply Chain & Third-Party Security

›
⚠ Critical gap

No supplier security assessments have been conducted. The company uses 4 cloud-based suppliers (ERP, CRM, file storage, HR) with direct access to production data. None have been assessed for cybersecurity posture. Article 21(2)(d) requires entities to address security risks in the supply chain — this is among the most enforced NIS2 obligations.

⚠ Critical gap

No cybersecurity clauses exist in supplier contracts. None of the 4 key suppliers are contractually required to notify Acme of a security incident. If a supplier is breached and affects Acme's systems, Acme cannot meet its own 24-hour reporting obligation — cascading regulatory exposure.

⚠ Gap identified

No supplier security register exists. The company does not have a documented view of which suppliers access which systems, with what level of privilege, and under what contractual conditions.

Evidence provided by company: "We use SAP Business One (cloud), Salesforce, Dropbox Business, and an HR platform. All have their own security but we've never formally assessed them."
1.5

Domain 6: System Security

Managed · Art. 21(2)(e) · Network & Information Systems Security

›
◑ Partial compliance

Monthly scheduled patching occurs but critical patches are sometimes delayed beyond 30 days due to operational constraints. NIS2 best practice requires critical patches within 72 hours, high within 7 days. A formal patch SLA policy should be adopted.

⚠ Gap identified

Production floor network (PLCs, industrial controllers) shares the same network segment as corporate IT. A successful ransomware infection in the office could propagate directly to manufacturing equipment — a scenario with both safety and regulatory implications for medical device manufacturing.

◑ Partial compliance

Ad hoc vulnerability scanning occurs after incidents. No continuous scanning capability or CVE monitoring is in place. No formal vulnerability disclosure policy exists.

1.0

Domain 7: Effectiveness Review

Managed · Art. 21(2)(f) · Assessing Control Effectiveness

›
⚠ Gap identified

No penetration testing has been conducted. The 2022 ransomware incident was the de facto "test" of security controls — and the result was a 3-day outage. Annual penetration testing is the minimum acceptable standard under NIS2 Article 21(2)(f) for Important Entities.

◑ Partial compliance

No formal cybersecurity KPIs are defined or reported to management. The board currently has no quantitative basis for judging whether security investments are effective.

2.5

Domain 8: Cyber Hygiene & Training

Defined · Art. 21(2)(g) · Security Awareness & Training

›
✓ Compliant

Annual security awareness training is conducted for all staff. Content is updated and completion tracked. This is a genuine strength — particularly important for a manufacturing environment where staff interact with both IT and OT systems.

◑ Partial compliance

A basic password policy exists but is not technically enforced — staff can choose passwords below the minimum standard. A password manager has not been deployed. Technical enforcement is now the expected standard.

◑ Partial compliance

No phishing simulations have been conducted. Given that the 2022 ransomware incident likely originated via a phishing email, this is a priority gap to address alongside technical controls.

Evidence provided by company: "We do annual online training via a platform. About 90% completion rate. We had a basic password policy but people don't always follow it."
1.0

Domain 9: Cryptography

Managed · Art. 21(2)(h) · Encryption & Key Management

›
⚠ Gap identified

Company laptops are not encrypted. Given that Acme processes patient-adjacent medical device data across 3 EU countries, an unencrypted laptop loss would constitute a simultaneous NIS2 incident and GDPR personal data breach — double regulatory exposure.

✓ Compliant

All external-facing web services and cloud platforms use HTTPS/TLS. This is confirmed by the use of SAP Business One and Salesforce cloud editions, which enforce TLS by default.

⚠ Gap identified

Several internal applications on the LAN communicate over unencrypted HTTP. While internal-only, lateral movement by an attacker could expose these communications. TLS should be enforced end-to-end.

2.5

Domain 10: HR Security

Defined · Art. 21(2)(i) · Human Resources Security

›
✓ Compliant

Employment contracts include confidentiality and data protection obligations. Reference checks are conducted for all new hires. Background checks are performed for roles with system administrator access.

◑ Partial compliance

Access revocation upon departure takes 3–5 business days. NIS2 best practice — particularly for a company with cloud systems accessible from anywhere — requires same-day or next-day revocation. This should be automated via HR system integration.

✓ Compliant

Confirmation provided that all known former employees have had access revoked, verified within the last 6 months. This is a positive control — maintain this verification on a quarterly basis going forward.

0.7

Domain 11: Access Control

Initial — Critical Gap · Art. 21(2)(i) · Access Control & Identity Management

›
⚠ Critical gap

No multi-factor authentication (MFA) is implemented on any system. All three cloud platforms (SAP, Salesforce, Dropbox) support MFA but it has not been enabled. Remote access via VPN uses username and password only. Article 21(2)(i) explicitly requires MFA for remote access — this is the most commonly cited enforcement failure in NIS2 inspections to date.

⚠ Critical gap

Most users have local administrator rights on their workstations. This means any malware executed by a user runs with full system privileges — significantly amplifying the impact of any successful phishing or social engineering attack.

⚠ Gap identified

No formal access rights review has been conducted in 24 months. With staff turnover and role changes, accumulated excessive permissions ("privilege creep") are likely across multiple systems.

Evidence provided by company: "We use standard Windows accounts. Most people have admin rights on their own machines because of the software they need. VPN is password-protected."
1.5

Domain 12: Asset Management

Managed · Art. 21(2)(i) · Asset Inventory & Lifecycle

›
◑ Partial compliance

A hardware asset spreadsheet exists but is updated manually and inconsistently. Software assets, SaaS subscriptions, and cloud services are not inventoried. Shadow IT (unauthorised cloud services) is likely given the lack of systematic tracking.

⚠ Gap identified

USB drives are used without restriction across the production floor and offices. This is a significant malware introduction and data exfiltration risk — particularly relevant in a manufacturing environment where USB devices are commonly used to transfer machine programs.

◑ Partial compliance

No formal data classification scheme exists. Medical device technical documentation, customer data, and internal communications are all stored with equivalent access — no sensitivity labelling or handling rules.

3.5

Domain 13: Physical Security

Quantitatively Managed · Art. 21(2)(j) · Physical & Environmental Security

›
✓ Compliant

Key card access, visitor logs, CCTV, and a secure server room are all in place and well-maintained. Physical security is the strongest domain in this assessment — a genuine organisational strength.

✓ Compliant

Full environmental controls operational: UPS, automated fire suppression, climate control, and redundant power. Tested annually. Generator backup planned for next financial year.

◑ Minor gap

Visitor escort procedure exists but enforcement is inconsistent in production areas adjacent to network cabling infrastructure. Standardise the procedure and include it in annual staff refresher training.

Evidence provided by company: "Our facilities team manages physical security — we have proper access cards, CCTV, and the server room is locked. Environmental systems are checked annually."
Prioritised remediation roadmap

Critical actions — 0 to 30 days

critical

Enable MFA on all cloud platforms and VPN

Activate MFA immediately on SAP Business One, Salesforce, Dropbox, and VPN for all users. Microsoft Authenticator is free and takes under 2 hours to deploy organisation-wide. This single control would have prevented or significantly limited the 2022 ransomware incident.

Art. 21(2)(i) — MFA for remote access
critical

Draft Incident Response Plan and appoint IRP Owner

Create a documented IRP including: detection triggers, internal escalation chain, CSIRT notification procedure, evidence preservation protocol, and crisis communications template. Name an IRP Owner with defined authority. Test the plan with a tabletop exercise within 60 days.

Art. 21(2)(b) + Art. 23 — Incident handling and reporting
critical

Remove local administrator rights from standard users

Migrate all standard users to non-administrator accounts. Create a defined process for temporary elevation when needed. This reduces the blast radius of any successful phishing attack from "full system compromise" to "user-level damage".

Art. 21(2)(i) — Least privilege access control

High priority — 1 to 3 months

high

Add cybersecurity clauses to all supplier contracts

Prioritise SAP and Salesforce (highest data access). Include minimum security standards, right-to-audit, and 24-hour incident notification obligation. Without this, a supplier breach makes your own NIS2 reporting obligation impossible to meet.

Art. 21(2)(d) — Supply chain security
high

Segment production OT network from corporate IT

Isolate PLC and industrial control systems from the office network using a dedicated VLAN and firewall rules. Given the medical device context, this also addresses MDR cybersecurity requirements and protects manufacturing integrity.

Art. 21(2)(e) — Network segmentation
high

Enable laptop encryption (BitLocker/FileVault)

Deploy BitLocker on all Windows laptops and FileVault on Macs. Enforce via Group Policy. Given cross-border operations and medical-adjacent data, an unencrypted laptop loss is a simultaneous NIS2 and GDPR breach.

Art. 21(2)(h) — Cryptography and encryption
high

Extend BCP to cover cyber incident scenarios

Add ransomware, data breach, and cloud provider outage scenarios to your existing BCP. Define RTOs and RPOs for all critical systems. Update crisis communication procedure to include regulatory notification workflow.

Art. 21(2)(c) — Business continuity

Medium priority — 3 to 6 months

medium

Commission annual penetration test

Engage a qualified penetration testing firm. Focus on external attack surface, cloud configuration, and network segmentation effectiveness. Given the 2022 ransomware incident, prioritise email and endpoint attack vectors.

Art. 21(2)(f) — Effectiveness review
medium

Implement USB media controls

Deploy Group Policy to block or require encryption on USB devices across office workstations. Create an exception process for legitimate production use cases. Communicate the policy change before technical enforcement.

Art. 21(2)(i) — Asset management
medium

Deploy organisation-wide password manager

Roll out a password manager (Bitwarden, 1Password, or similar) to all staff. Enforce unique passwords for all business accounts. Conduct phishing simulation within 30 days of deployment to measure baseline awareness.

Art. 21(2)(g) — Cyber hygiene
Quick wins — implement this week
Enable MFA on your CEO's and IT Manager's accounts first — highest-value targets, takes 15 minutes per person.
Identify and contact the Italian, German, and Bulgarian national CSIRTs — note their contact details in a shared document. This is a legal requirement you can complete in 30 minutes.
Request security incident notification clauses from SAP Business One and Salesforce — many SaaS providers have standard DPA addenda ready to sign.
Create a single-page "what to do if you suspect a cyberattack" poster and email it to all staff — name and phone number of IRP owner, steps to take, what NOT to do (do not restart the machine, do not pay ransom).
Schedule a 30-minute board briefing on NIS2 — focus on Article 20 personal liability and the 24-hour reporting obligation. Use this report as the briefing document.
NIS2 Article 21 Gap Register

Assign an owner and target date for each gap. This register serves as your compliance evidence — document every action taken against each item.

#DomainArticle 21GapSeverityActionOwnerTarget
1Incident HandlingArt. 21(2)(b)No IRP. 24h reporting impossible.criticalDraft IRP, appoint owner, test.___________0–30 days
2Access ControlArt. 21(2)(i)No MFA. Admin rights on all users.criticalEnable MFA. Remove local admin rights.___________0–30 days
3Supply ChainArt. 21(2)(d)No supplier assessments or clauses.criticalAssess 4 key suppliers. Update contracts.___________1–3 months
4CryptographyArt. 21(2)(h)Laptops unencrypted. Internal HTTP.highEnable BitLocker. Enforce TLS internally.___________1–3 months
5System SecurityArt. 21(2)(e)OT/IT networks shared. Patch SLAs informal.highSegment OT network. Define patch SLAs.___________1–3 months
6Business ContinuityArt. 21(2)(c)BCP excludes cyber scenarios.highExtend BCP. Add ransomware scenarios.___________1–3 months
7Effectiveness ReviewArt. 21(2)(f)No pentest in 3+ years. No KPIs.highSchedule pentest. Define security KPIs.___________3–6 months
8Risk ManagementArt. 21(2)(a)No risk register. No independent audit.mediumBuild risk register. Plan external audit.___________3–6 months
9Asset ManagementArt. 21(2)(i)No USB policy. Partial inventory.mediumImplement USB controls. Build full inventory.___________3–6 months
10Security PolicyArt. 21(2)(a)Policy outdated. No board sign-off.mediumReview policy. Obtain board approval.___________3–6 months

What to do after this report

1
Share this report with your board and senior management. NIS2 Article 20 requires management bodies to approve and oversee cybersecurity strategy — present this report at your next board meeting.
2
Complete the gap register above — assign an owner and target date for every item. Without named accountability, remediation stalls. One person per gap is sufficient.
3
Start with the three critical gaps immediately — MFA, IRP, and local admin rights removal. These are fast to implement and eliminate the highest regulatory exposure.
4
Contact the national CSIRT in each country of operation (Italy: CSIRT Italia, Germany: BSI, Bulgaria: CERT Bulgaria) and understand your local registration obligations.
5
Document every action taken — your compliance audit trail is as important as the controls themselves. Keep signed records of board decisions, policy approvals, and remediation evidence.
6
Reassess in 12 months. NIS2 requires ongoing compliance — not a one-time exercise. Return to the SerafinIT engine for your annual assessment, or sooner if significant operational changes occur.

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Sample report notice: This is an illustrative report based on a fictional company. All findings, scores, and recommendations are examples of what the SerafinIT Compliance Engine produces for a real assessment. Your actual report will be generated based on your specific answers and will reflect your organisation's real compliance posture. This document does not constitute legal advice.