The regulatory landscape across the EU is tightening, and organizations are feeling the pressure. Between NIS2’s expanded cybersecurity requirements and DORA’s operational resilience mandates, businesses are asking the same question: “How do we comply without breaking the bank?”
Here’s the reality: compliance doesn’t have to be a budget-buster. The key lies in understanding what regulators actually want to see. In some cases this may not be a comprehensive, enterprise-grade solution with maximum coverage at maximum cost. The truth is that by understanding the actual regulatory requirements and implementing targeted solutions, you can achieve compliance while preserving resources for business growth and innovation.
Today we are going to examine this case – how to meet the regulations requirements without the enterprise price tag.
Decoding What NIS2 and DORA Actually Require
NIS2 Security Testing Requirements
The NIS2 Directive fundamentally reshapes cybersecurity obligations for essential and important entities across the EU. At its core, NIS2 mandates a risk-based approach to cybersecurity, requiring organizations to implement robust security measures including regular vulnerability assessments, penetration testing, and incident response capabilities.
For a comprehensive understanding of how NIS2 impacts your organization, including sector-specific requirements and implementation timelines, check out our detailed analysis: What is NIS2: Key Changes and How They Impact Your Organization. We also explore the specific role of penetration testing in meeting these requirements in our blog: NIS2 and Penetration Testing: Ensuring Compliance and Cyber Resilience.
DORA’s Operational Resilience Testing
DORA focuses specifically on the financial sector’s digital operational resilience, introducing five key pillars that organizations must address. These include ICT risk management, incident reporting, operational resilience testing, information sharing, and third-party risk management.
The regulation requires financial entities to conduct regular digital operational resilience testing, including threat-led penetration tests every three years, alongside annual risk assessments. For detailed information about DORA’s requirements and implementation strategies, see our comprehensive guide: DORA Compliance: all you need to know.
The Overlap Advantage
Here’s where smart organizations gain a significant advantage: NIS2 and DORA requirements overlap in several key areas, particularly around penetration testing, risk management, and incident response. Rather than treating these as separate compliance exercises, you can design a unified approach that satisfies both regulations.
They require regular security testing, comprehensive risk assessments, and documented incident response procedures. By implementing a single, well-designed testing program, you can meet the requirements of both regulations while avoiding duplicate efforts and costs. This overlap represents a genuine opportunity to achieve compliance efficiency without compromising on security or regulatory adherence.
The “Minimum Viable Compliance” Approach
What Regulators Actually Want to See
Regulators aren’t looking for perfection – they’re looking for evidence of systematic, ongoing security practices. Specifically, they want to see:
Evidence of regular, systematic testing that demonstrates you’re actively identifying and addressing vulnerabilities. This doesn’t mean testing everything, everywhere, all the time. It means having a documented, consistent approach to security assessments.
Documented risk assessment processes that show you understand your threat landscape and are making informed decisions about security investments. Regulators want to see that you’re thinking strategically about risk, not just implementing random security controls.
Clear remediation plans and timelines that demonstrate you’re not just finding problems but actually fixing them. This includes prioritization frameworks that show you’re addressing the most critical issues first, along with retesting procedures to verify that identified vulnerabilities have been properly remediated.
Audit trails and reporting capabilities that provide transparency into your security posture and decision-making processes. Regulators need to be able to trace your compliance efforts during inspections and audits.
Common Over-Engineering Mistakes
Many organizations make costly mistakes by assuming they need more comprehensive solutions than regulations actually require:
Full-scope penetration testing when essential testing delivers compliance: Some businesses conduct extensive, enterprise-wide penetration tests when focused, risk-based testing would meet regulatory requirements at a fraction of the cost.
Annual testing when quarterly might be required: Misunderstanding testing frequency requirements can lead to over-testing (wasting resources) or under-testing (creating compliance gaps).
Enterprise-grade solutions for mid-market compliance needs: Not every organization needs the same level of security infrastructure as a multinational corporation. Right-sizing your approach to your actual risk profile and regulatory requirements is crucial.
These mistakes often stem from vendor recommendations or fear-based decision making rather than careful analysis of actual regulatory requirements.
The Cost-Effective Framework
A smart compliance approach focuses on three key principles:
Risk-based testing prioritization ensures you’re investing testing resources where they’ll have the greatest impact on both security and compliance. This means focusing on systems and processes that are most critical to your operations and most likely to be targeted by attackers.
Essential testing scope vs. comprehensive assessments means understanding the difference between what’s required and what’s ideal. While comprehensive testing might be valuable, essential testing that covers your most critical assets and regulatory requirements provides the compliance foundation you need.
Optimal testing frequency for compliance involves understanding the minimum testing requirements and designing a schedule that meets those requirements without unnecessary over-testing. This includes coordinating different types of assessments to maximize efficiency.
Essential Penetration Testing – The Practical Solution
What Makes Testing “Essential”
Essential penetration testing represents a fundamental shift in how organizations approach security assessments. Rather than comprehensive testing that examines every possible vulnerability, essential testing is focused on regulatory requirements and business-critical assets.
This approach is focused on regulatory requirements. Essential testing specifically addresses the vulnerabilities and attack vectors that regulators care about most, ensuring you can demonstrate compliance without unnecessary scope expansion.
The process features streamlined procedures designed for compliance documentation. Every test is conducted with compliance reporting in mind, generating the evidence and documentation that auditors and regulators expect to see.
Faster turnaround times ensure you can meet regulatory timelines without compromising on quality. Essential testing is designed to provide actionable results quickly, allowing you to address findings and maintain compliance momentum.
Cost Comparison Reality Check
Understanding the true cost of different approaches helps clarify why essential testing makes financial sense:
Traditional penetration testing typically involves extensive scope, lengthy timelines, and comprehensive reporting that goes far beyond regulatory requirements. While thorough, this approach often includes testing that doesn’t directly contribute to compliance objectives.
Essential penetration testing focuses specifically on regulatory requirements and business-critical assets. This targeted approach reduces costs while ensuring you meet all necessary compliance objectives. The streamlined process also means faster results and quicker remediation.
Non-compliance costs provide crucial context for testing investments. NIS2 fines can reach €10 million or 2% of global annual turnover, while DORA penalties can be equally severe. The average cost of a data breach in 2024 was €4.88 million, making proactive security testing a necessary investment rather than an optional expense.
Scalable approach that grows with your organization: Essential testing establishes a foundation that can be expanded as your organization grows or as regulatory requirements evolve. This approach ensures you’re not over-investing in the beginning while maintaining the flexibility to enhance your security posture over time.
Conclusion
Compliance with NIS2 and DORA doesn’t have to be a financial nightmare. By understanding what regulators actually require and implementing targeted solutions like essential penetration testing, organizations can meet their compliance obligations efficiently and cost-effectively.
The key is focusing on the minimum viable compliance approach – meeting all regulatory requirements without unnecessary over-engineering. This strategic approach allows you to allocate resources more effectively, maintaining strong security while preserving budget for business growth and innovation.
Essential penetration testing represents your path to cost-effective compliance, providing the security assessments, documentation, and evidence that regulators require without the enterprise-grade price tag.
Ready to Meet NIS2 and DORA Requirements Without the Enterprise Price Tag?
Don’t let compliance costs derail your business objectives. AMATAS’s essential penetration testing service provides the targeted, efficient approach to security testing that meets both NIS2 and DORA requirements while keeping costs manageable.
Our compliance-focused methodology ensures you get the evidence, documentation, and security insights you need to satisfy regulators without paying for unnecessary scope expansion.
Book a meeting with our experts today to discover how essential penetration testing can streamline your compliance journey and protect your organization’s future. Let’s discuss your specific requirements and design a cost-effective path to regulatory compliance.
