NIS 2 Cyber Hygiene and Training Requirements

Key Takeaways

Point	Summary
Mandatory training	Both management and employees must receive cybersecurity training
Cyber hygiene	Basic security practices must be implemented and maintained across the organization
Management obligation	Article 20 specifically requires management body members to undergo training
Regular cadence	Training should be ongoing, not a one-time event
Measurable outcomes	Organizations should track training effectiveness and participation

Quick Answer: NIS 2 requires all in-scope organizations to implement basic cyber hygiene practices and provide cybersecurity training to their workforce. Management must also undergo specific cybersecurity training. These requirements apply to both essential and important entities.

What is Cyber Hygiene Under NIS 2?

Cyber hygiene refers to the fundamental cybersecurity practices that every organization should implement. While NIS 2 does not provide an exhaustive list, the following practices are generally expected:

Password and Authentication

Practice	Description
Strong passwords	Enforce minimum complexity requirements and password length
Multi-factor authentication	Implement MFA for access to critical systems and remote access
Password managers	Encourage or mandate the use of password management tools
No password sharing	Prohibit sharing of credentials between users
Regular rotation	Rotate passwords for privileged and service accounts

Software and System Management

Practice	Description
Patch management	Apply security patches promptly across all systems
Software inventory	Maintain an inventory of authorized software
Automatic updates	Enable automatic updates where feasible
End-of-life management	Replace or isolate systems that no longer receive security updates
Secure configuration	Apply security baselines to all systems before deployment

Network Security

Practice	Description
Network segmentation	Separate critical systems from general-purpose networks
Firewall management	Maintain and review firewall rules regularly
Secure Wi-Fi	Use WPA3 or WPA2-Enterprise for wireless networks
VPN for remote access	Require encrypted connections for remote work
DNS security	Implement DNS filtering to block known malicious domains

Data Protection

Practice	Description
Encryption	Encrypt sensitive data at rest and in transit
Data classification	Classify data by sensitivity level
Secure disposal	Properly destroy data when no longer needed
Backup procedures	Regular, tested backups with secure storage
Access control	Limit data access based on need-to-know

Physical Security

Practice	Description
Device security	Lock screens, disk encryption on endpoints
Clean desk policy	Secure physical documents and devices when unattended
Visitor management	Control and monitor visitor access to facilities
Removable media	Restrict or control the use of USB drives and other removable media

Training Requirements

Management Training (Article 20)

NIS 2 explicitly requires management body members to undergo cybersecurity training. This training should enable management to:

• Identify and assess cybersecurity risks
• Evaluate the impact of risks on the entity's operations
• Understand the entity's cybersecurity risk-management measures
• Make informed decisions about cybersecurity investments
• Fulfill their oversight and approval responsibilities

Recommended topics for management training:

• NIS 2 requirements and personal liability
• The organization's threat landscape and risk profile
• Cybersecurity governance and decision-making
• Incident response and reporting obligations
• Supply chain security considerations
• Current cyber threat trends relevant to the sector

Employee Training

All employees should receive regular cybersecurity awareness training covering:

Topic	Description
Phishing awareness	Recognizing and reporting phishing attempts
Social engineering	Understanding manipulation tactics
Safe browsing	Identifying malicious websites and downloads
Data handling	Proper classification and handling of sensitive information
Incident reporting	How to report suspected security incidents internally
Remote work security	Secure practices when working outside the office
Physical security	Protecting devices and documents
Password security	Creating and managing strong passwords

Role-Specific Training

Staff with specific security responsibilities should receive additional training:

Role	Additional Training
IT administrators	Secure configuration, patch management, access control
Developers	Secure coding practices, vulnerability management
Incident responders	Detection tools, forensics, communication protocols
HR/Procurement	Supplier security assessment, employee lifecycle security
Customer-facing staff	Data protection, social engineering awareness

Building a Training Program

Step 1: Assess Current Awareness Levels

• Conduct baseline phishing simulations
• Survey employees on security knowledge
• Review past incident data for human-factor root causes
• Identify high-risk roles and departments

Step 2: Design the Program

• Create role-based training tracks (management, general staff, technical staff)
• Include both initial onboarding training and regular refresher sessions
• Use varied formats: e-learning, workshops, simulations, newsletters
• Align content with the organization's actual threat landscape

Step 3: Implement and Deliver

• Roll out training on a regular schedule (at least annually, more frequently for high-risk topics)
• Conduct phishing simulations periodically (monthly or quarterly)
• Provide just-in-time training when new threats emerge
• Make training engaging and relevant to daily work

Step 4: Measure and Improve

Metric	Purpose
Training completion rate	Track participation across the organization
Phishing simulation results	Measure awareness improvement over time
Incident reports	Monitor whether employees are reporting more effectively
Knowledge assessments	Test retention of key security concepts
Time to report	Measure how quickly employees flag suspicious activity

Step 5: Document Everything

Maintain comprehensive records for NIS 2 compliance evidence:

• Training materials and curricula
• Attendance records and completion certificates
• Assessment results and improvement trends
• Management training participation logs
• Phishing simulation results and follow-up actions

Common Questions

How often should training be conducted?

NIS 2 does not specify a frequency, but best practice is to provide security awareness training at least annually for all employees, with more frequent reinforcement through simulated phishing exercises (monthly or quarterly), security newsletters, and targeted training when new threats emerge. Management training should be conducted at least annually.

Is online training sufficient?

Online training is acceptable and often practical for large organizations. However, a blended approach combining e-learning, workshops, tabletop exercises, and phishing simulations is generally more effective. The key is that training is regular, relevant, and measurable, regardless of the delivery format.

What if employees fail phishing simulations?

Failed phishing simulations should be treated as learning opportunities, not punitive events. Provide immediate educational feedback when an employee fails a simulation, offer additional targeted training, and track improvement over time. A culture of blame-free reporting encourages employees to report real phishing attempts promptly.