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EU NIS 2 Compliance

The EU NIS 2 Directive requires essential and important entities to manage cybersecurity risk, including vulnerability
handling and secure development. Learn how ImmuniWeb helps with Article 21.

Read Time: 8 min. Updated: July 8, 2025
EU NIS 2 Directive Compliance
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EU NIS 2 Directive Compliance

What Is the EU NIS 2 Directive?

NIS 2 broadens the scope of EU cybersecurity rules to a wide range of sectors - including energy, transport, banking, health, drinking and waste water, digital infrastructure, ICT service management, public administration, manufacturing, food and more - classifying organizations as 'essential' or 'important' entities.

It sets baseline cyber risk-management measures, tightens incident reporting, and introduces management accountability and registration. Because it is a directive, the precise obligations apply through each member state's national transposition.

See how ImmuniWeb supports NIS 2 Article 21 measures - vulnerability handling and secure development for your applications.Request a demoor run a free Community Edition test.

Who Must Comply with NIS 2?

NIS 2 applies to a broad set of organizations:

  • Essential entities - larger organizations in high-criticality sectors (energy, transport, banking, health, digital infrastructure and more).
  • Important entities - medium-sized organizations in other covered sectors.
  • Note:exact thresholds and duties apply through each member state's national transposition.

The web, mobile and API applications these entities run fall within the Article 21 risk-management measures.

Key NIS 2 Requirements for Application Security

Application security is driven by the Article 21 risk-management measures:

  • • Security in development and maintenance: security in network and information systems acquisition, development and maintenance, including vulnerability handling and disclosure.
  • • Risk analysis and testing: policies on risk analysis and information system security, and assessment of the effectiveness of measures.
  • • Incident reporting (Article 23): early warning within 24 hours and notification within 72 hours of significant incidents.

NIS 2 Article 21 Measures in Depth

Article 21 - Risk-Management Measures

Article 21 requires, among other measures, security in the acquisition, development and maintenance of network and information systems, including vulnerability handling and disclosure, and the assessment of the effectiveness of cybersecurity measures. Penetration testing and vulnerability scanning of web and mobile applications are direct ways to handle vulnerabilities and evidence effectiveness.

Article 23 - Incident Reporting

Significant incidents must be reported - an early warning within 24 hours and a notification within 72 hours. Reducing incident likelihood through regular application testing is the most effective way to stay ahead of these duties.

Common Web & Mobile Application Risks to Address

The application vulnerabilities NIS 2 expects entities to handle map closely to the OWASP Top 10:

  • Broken Access Control — users reaching data or actions they should not.
  • Cryptographic Failures — weak or missing encryption exposing sensitive data.
  • Injection —SQL, command or other injection via unvalidated input.
  • Insecure Design — missing security controls by design, not just by bug.
  • Security Misconfiguration — default, incomplete or unsafe configuration.
  • Vulnerable & Outdated Components — unpatched libraries and frameworks.
  • Identification & Authentication Failures — weak login, session or credential handling.
  • Software & Data Integrity Failures — untrusted updates, insecure CI/CD pipelines.
  • Security Logging & Monitoring Failures — attacks going undetected.
  • Server-Side Request Forgery (SSRF) — the server tricked into making malicious requests.

For mobile apps, the OWASP Mobile Top 10 is the equivalent reference (insecure data storage, insecure communication, weak cryptography, and so on). Reliably finding these issues requires testing the running application, not just a documentation review.

How to Support NIS 2 Article 21 with ImmuniWeb

  1. Map your assets. Inventory internet-facing apps and your attack surface with ImmuniWeb Discovery.
  2. Handle vulnerabilities with Neuron scanning and On-Demand penetration testing.
  3. Test mobile applications with MobileSuite and Neuron Mobile.
  4. Secure development and maintenance with Continuous in CI/CD.
  5. Remediate and retest with actionable reports evidencing effectiveness.
  6. Monitor continuously with Discovery and Continuous.

How ImmuniWeb Helps You Achieve NIS 2 Compliance

ImmuniWeb supports the Article 21 measures on vulnerability handling, secure development and effectiveness testing.

Requirement What it requires ImmuniWeb products
Vulnerability handling Identify and remediate application vulnerabilities. Neuron, On-Demand, Discovery
Secure development & maintenance Security across acquisition, development and maintenance. On-Demand, Neuron, Continuous
Effectiveness assessment Test and evidence the effectiveness of measures. On-Demand, Neuron

ImmuniWeb On-Demand and MobileSuite deliver web and mobile penetration testing; Neuron and Neuron Mobile provide automated scanning; Continuous embeds testing into CI/CD; and Discovery maps your attack surface - supporting the Article 21 measures.

NIS 2 vs International Frameworks

If you already work to international standards, the same ImmuniWeb testing supports all of them:

Framework Application-security angle How ImmuniWeb maps
EU NIS 2 Article 21 risk-management measures Web/mobile pentest, scanning, ASM
EU DORA Resilience testing (financial sector) Same testing supports both
ISO/IEC 27001 Annex A technical controls Testing as control evidence
NIST CSF 2.0 Protect / Detect functions Application testing & monitoring

Penetration Testing vs Security Scanning

Both are needed. Automated scanning (DAST) gives broad, frequent coverage and is ideal for continuous testing in CI/CD; manual penetration testing finds business-logic and complex vulnerabilities that scanners miss and produces the depth auditors and regulators expect. Combine continuous scanning with periodic manual penetration testing, and re-test after significant changes.

Compliance Checklist (Application Security)

  • Inventory of internet-facing apps and exposed assets
  • Vulnerability handling across web and mobile apps
  • Security in development and maintenance (secure SDLC)
  • Effectiveness of measures tested and evidenced
  • Findings remediated and re-tested; records retained
  • Incident-reporting process aligned with Article 23
  • Attack-surface monitoring in place

Why NIS 2 Compliance Matters

NIS 2 is implemented through national law with significant enforcement powers: maximum fines for essential entities can reach EUR 10 million or 2% of global annual turnover (and up to EUR 7 million or 1.4% for important entities), alongside management accountability.

Because web and mobile applications are a leading source of incidents, demonstrably handling their vulnerabilities and testing effectiveness is one of the clearest ways to meet Article 21.

Frequently Asked Questions

  • Q
    What is the EU NIS 2 Directive?
    A
    Directive (EU) 2022/2555, which expands the EU's network and information security rules and had to be transposed into national law by 17 October 2024.
  • Q
    Who must comply with NIS 2?
    A
    Essential and important entities across a broad set of sectors, as defined in each member state's national transposition.
  • Q
    What does Article 21 require?
    A
    Cyber risk-management measures including security in development and maintenance, vulnerability handling and disclosure, and assessment of the effectiveness of measures.
  • Q
    Does NIS 2 require security testing?
    A
    Article 21's vulnerability-handling and effectiveness requirements are met in practice through penetration testing and vulnerability scanning of systems and applications.
  • Q
    How does ImmuniWeb help with NIS 2?
    A
    By testing and securing web and mobile applications to handle vulnerabilities, support secure development and evidence the effectiveness of measures.
  • Q
    What are the penalties under NIS 2?
    A
    Set in national law; maximum fines for essential entities can reach EUR 10 million or 2% of global annual turnover.
Please fill in the fields highlighted in red below

Talk to a Specialist about
EU NIS 2 Directive Compliance

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  • Receive personalized product pricing
  • Talk to our technical experts
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