NIS 2 & DORA Readiness Checklist

A practical, no-jargon checklist to gauge how ready your organization is for NIS 2 and DORA. Work through each item, mark what is in place, and turn the gaps into a plan. Free to use and share.

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NIS 2 readiness

NIS 2 (Directive (EU) 2022/2555) expands scope and raises minimum security measures. Article 21 lists the baseline; management bodies are accountable for approving and overseeing them.

Governance & accountability

  • Management body formally approves and oversees the cyber risk-management measures.
  • Management and key staff complete cybersecurity risk training.
  • Roles, responsibilities and an accountable owner for cybersecurity are defined.

Risk management & policies

  • Documented risk analysis and information system security policies.
  • Asset inventory and data classification kept up to date.
  • Policies and procedures to assess the effectiveness of the measures (audits, tests, pentests).

Incident handling

  • Incident detection, handling and response procedures are in place and tested.
  • Ability to meet reporting deadlines: 24h early warning, 72h notification, final report.

Continuity & supply chain

  • Backups, disaster recovery and crisis management, tested regularly.
  • Supply-chain security: security requirements and assessment for suppliers and service providers.

Technical baseline

  • Security in acquisition, development and maintenance, including vulnerability handling and disclosure.
  • Basic cyber hygiene practices and security awareness training for all staff.
  • Cryptography and encryption policy where appropriate.
  • Human resources security, access control and asset management (screening, least-privilege access, timely revocation).
  • Multi-factor authentication (MFA) or continuous authentication, and secured voice, video and text communications.

DORA readiness

DORA (Regulation (EU) 2022/2554) sets digital operational resilience rules for financial entities and their ICT providers, built on five pillars.

ICT risk management

  • Board-approved ICT risk-management framework, reviewed regularly.
  • Mapping of ICT assets, business functions and dependencies.
  • ICT business continuity policy, response and recovery plans, and tested backups.

ICT incident management & reporting

  • Process to detect, classify and report major ICT-related incidents to the competent authority.

Operational resilience testing

  • Regular resilience testing programme (vulnerability assessments, scenario tests).
  • Threat-Led Penetration Testing (TLPT) for entities in scope.

Third-party & information sharing

  • Register of ICT third-party providers, contractual requirements and concentration-risk monitoring.
  • Arrangements to share cyber threat intelligence with peers.

This checklist is a practical guide, not legal advice. Obligations depend on your sector, size and role under each framework.

Need help closing the gaps?

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