NIS 2 for Startups: What Growing Companies Need to Know
Most startups fall below the NIS 2 size thresholds and are not directly subject to the directive. However, as your company grows or if you operate in specific sectors, NIS 2 compliance can become relevant quickly. Even if you are not directly in scope, your enterprise customers may impose NIS 2-aligned requirements through their supply chain obligations. Understanding NIS 2 early helps you build security practices that scale.
Key Takeaways
| Point | Summary |
|---|---|
| Size threshold | NIS 2 generally applies to organizations with 50+ employees or 10M+ turnover |
| Exceptions | DNS providers, TLD registries, trust service providers, and certain telecoms providers are in scope regardless of size |
| Indirect impact | Enterprise customers may require NIS 2-aligned security from their suppliers |
| Growth planning | Building NIS 2-ready practices early reduces future compliance costs |
| ISO 27001 path | ISO 27001 certification provides a strong foundation for future NIS 2 compliance |
Quick Answer: Most startups are exempt from NIS 2 due to size thresholds (50+ employees or 10M+ turnover). However, startups in specific sectors like DNS, trust services, or cloud infrastructure may be in scope regardless of size. Even exempt startups benefit from building NIS 2-ready practices early, especially when selling to regulated enterprises.
Are You in Scope?
Likely Exempt
Your startup is probably exempt from NIS 2 if you:
- Have fewer than 50 employees and less than 10M annual turnover
- Do not operate in a regulated sector listed in Annex I or Annex II
- Do not provide DNS, TLD, or qualified trust services
Likely in Scope (Regardless of Size)
Your startup is in scope regardless of size if you:
- Provide qualified trust services
- Operate DNS services or TLD name registries
- Provide public electronic communications networks or services
- Are identified as a critical entity under the CER Directive
Growing Into Scope
Plan for NIS 2 compliance if:
- You are approaching the 50-employee or 10M-turnover thresholds
- You operate in any of the 18 NIS 2 sectors (energy, health, digital infrastructure, manufacturing, etc.)
- Your growth trajectory suggests you will cross thresholds within 12-24 months
Indirect NIS 2 Impact on Startups
Even if your startup is not directly in scope, NIS 2 may affect you through the supply chain:
Customer Requirements
NIS 2 entities must manage supply chain security. This means their suppliers, including startups, may face:
- Security questionnaires during procurement processes
- Contractual cybersecurity requirements
- Requests for security certifications (ISO 27001, SOC 2)
- Incident notification obligations
- Regular security assessments or audits
Competitive Advantage
Startups that can demonstrate strong cybersecurity practices gain a competitive edge when selling to NIS 2-regulated enterprises:
| Differentiator | Impact |
|---|---|
| ISO 27001 certification | Directly demonstrates security maturity to NIS 2 entities |
| SOC 2 report | Valued by enterprise customers, especially in US/global markets |
| Documented security policies | Shows maturity beyond the startup's size |
| Incident response capability | Addresses customer concerns about supply chain incidents |
| MFA and encryption | Meets specific NIS 2 requirement areas |
Building NIS 2-Ready Practices
Even if you are not in scope today, investing in foundational security practices now pays dividends later:
Priority 1: Security Basics
- Implement multi-factor authentication across all systems
- Encrypt data at rest and in transit
- Establish access control policies based on least privilege
- Deploy endpoint protection and regular patching
- Enable logging and monitoring on critical systems
Priority 2: Governance
- Create a basic information security policy
- Define incident response procedures
- Establish a simple risk assessment process
- Document your supplier/vendor security practices
- Brief founders and leadership on security responsibilities
Priority 3: Incident Readiness
- Define what constitutes a security incident for your organization
- Create a basic incident response plan with roles and contacts
- Understand your notification obligations (GDPR, NIS 2 if applicable)
- Document your incident communication plan
Priority 4: Supply Chain
- Maintain a list of critical suppliers and their access levels
- Include security clauses in vendor contracts
- Assess cloud provider security practices
- Monitor for vulnerabilities in third-party components
The ISO 27001 Path
For startups planning to scale into NIS 2 scope, pursuing ISO 27001 certification is the most efficient strategy:
| Benefit | Description |
|---|---|
| NIS 2 alignment | Covers approximately 70-80% of NIS 2 requirements |
| Customer confidence | Internationally recognized certification |
| Scalable framework | Grows with your organization |
| Competitive advantage | Differentiates you from competitors without certification |
| Startup timeline | Achievable in 3-4 months with expert guidance |
| Investment | 10,000-20,000 for startups |
Adding NIS 2-specific requirements on top of ISO 27001 is relatively straightforward once the ISMS is established.
Cost-Effective Approaches
| Approach | Description | Cost |
|---|---|---|
| Managed compliance | Partner like Bastion handles the heavy lifting | Predictable monthly cost |
| Platform-based | Use compliance automation tools for policy management and evidence collection | 5,000-15,000/year |
| ISO 27001 first | Build the ISMS foundation, add NIS 2 specifics when in scope | 10,000-20,000 initial |
| Minimal viable security | Implement the basics (MFA, encryption, policies) and add as you grow | 2,000-5,000 to start |
Common Questions
Should startups worry about NIS 2?
If you are below the size thresholds and not in an excepted sector, NIS 2 is not an immediate legal obligation. However, if you sell to European enterprises in regulated sectors, expect indirect requirements through supply chain obligations. Building good security practices from the start is always cheaper than retrofitting them later.
When should we start preparing for NIS 2?
Start when you can see a clear path to crossing the size thresholds (50 employees or 10M turnover) or when enterprise customers begin requesting NIS 2-aligned security evidence. For many B2B startups, this happens earlier than expected since customer requirements often anticipate regulatory obligations.
Is GDPR compliance enough?
GDPR compliance addresses data protection but not the full scope of cybersecurity measures required by NIS 2. While there is overlap in security measures and incident reporting, NIS 2 adds requirements around business continuity, supply chain security, management liability, and sector-specific obligations that GDPR does not cover.