Cyber threats are evolving faster than ever, and the Network and Information Systems Directive (NIS2) is pushing organizations across the EU to step up their cybersecurity defenses. With stricter risk management, incident response, and security assessment requirements, businesses in critical and high-risk sectors must take a proactive approach to protecting their infrastructure.
One of the most effective ways to meet these new demands is penetration testing – a powerful tool that helps organizations uncover vulnerabilities before attackers do. Beyond compliance, pen testing strengthens cyber resilience, prevents costly breaches, and ensures long-term security. In this blog, we’ll explore why penetration testing is essential for NIS2 compliance, how it enhances security, and how organizations can integrate it effectively.
Key Security Requirements Under NIS2
The NIS2 directive primarily addresses processes that are closely linked to network and information systems security, introducing enhanced cybersecurity obligations for essential and important entities across various industries. One of the core compliance requirements is a risk-based approach to cybersecurity, which mandates organizations to:
- Implement incident detection and response capabilities
- Conduct regular vulnerability management and risk assessments
- Perform regular security testing, including pen testing
If you’re new to NIS2 and want a deeper dive into its key changes and requirements, check out our previous blog post: What is NIS2? Key Changes and How They Impact Your Organization.
Where Does Penetration Testing Fit Into NIS2
According to Article 21 of NIS2, essential and important entities “must take appropriate and proportionate technical, operational and organizational measures to manage the risks posed to the security of network and information systems”. That includes implementing security measures, such as risk analysis, incident handling, business continuity, supply chain security, system maintenance, and vulnerability management. It also emphasizes cybersecurity training, encryption policies, access controls, and multi-factor authentication mechanisms to strengthen overall cyber resilience.
Penetration testing directly supports these requirements by simulating cyber attacks to identify weaknesses, identify missing updates, test defenses, and improve cybersecurity measures before real attackers exploit them.
To Whom Does the NIS2 Directive Apply
The NIS2 Directive applies to essential entities across sectors that impact the cybersecurity of network and information systems, including digital service providers, healthcare, finance, energy, and more.
Entities that meet the defined criteria ‘Section 8.1’ must implement management based on penetration testing to stay NIS2 compliant and fulfil key security objectives. For organizations that aim at getting grip on NIS2, regular penetration tests are crucial.
Now the NIS2 directive targets increased number of industries, not just critical infrastructure. These new industries now include finance, healthcare, transport, security services providers, digital infrastructure providers and space.
Marko Simeonov, CEO of AMATAS
Why Penetration Testing Matters for NIS2 Compliance
Penetration testing is a core component of a strong cybersecurity strategy and a key tool for meeting NIS2 requirements. Unlike basic vulnerability scans, pen testing goes further by simulating real-world cyber attacks to identify security gaps before attackers do.
For a broader overview of what exactly are penetration tests and their benefits, read our blog post: Why Penetration Testing is Important – The Simple Answer.
Here’s how penetration testing directly supports NIS2 compliance:
- Identifies Security Weaknesses – Regular testing uncovers hidden security flaws in applications, networks, and systems, or missing updates, and weak password controls ensuring the identified vulnerabilities are addressed before they can be exploited.
- Supports Risk Management Requirements – NIS2 focuses on processes and mandates a risk-based approach to cybersecurity. Thus, penetration testing is required for NIS2 compliant and effective risk management that helps organizations quantify risks, prioritize mitigation efforts and take care of the identified vulnerabilities.
- Enhances Incident Preparedness – Testing is of key importance for NIS2 as it provides insights into how well an organization can detect and respond to attacks, strengthening its incident response plan.
- Demonstrates Due Diligence – Regular security and risk assessments, including pen testing, help organizations prove compliance and avoid potential penalties.
By integrating penetration testing into their security program, businesses not only align with Network and Information Systems (NIS2) directive but also build cyber resilience, ensuring they can detect, respond to, and recover from security incidents effectively.
How Often Should Penetration Testing Be Conducted
Organizations should conduct pen testing at least annually or after significant system changes to align with NIS2 regulations. However, the frequency may vary depending on:
- Industry regulations – High-risk sectors (e.g., finance, healthcare) may require more frequent testing. For example, companies in the fintech industry must conduct regular penetration tests to ensure the protection of customers financial information.
- Threat landscape – If your industry experiences frequent cyber attacks, quarterly penetration testing is therefore of key importance.
- System updates & infrastructure changes – Major IT changes warrant immediate testing to ensure information systems security.
- Compliance requirements – Some industry-specific regulations may mandate more frequent testing.
How Penetration Testing Strengthens Cyber Resilience
While compliance with NIS2 is essential, organizations shouldn’t view penetration testing as just another regulatory checkbox. Instead, it should be a key component of a broader cybersecurity strategy, aimed at building long-term resilience against emerging threats.
Here’s how pen testing enhances cyber resilience:
- Simulating Real-World Attacks – By mimicking tactics used by real attackers, pen testing helps businesses understand how their security defenses would hold up in an actual cyber attack.
- Improving Incident Response Readiness – Testing helps organizations identify gaps in their security monitoring, detection, and response processes, ensuring teams are prepared to act swiftly in case of a breach.
- Preventing Financial and Reputational Damage – Based on penetration tests organization can identify and fix vulnerabilities before they are exploited and prevent costly breaches, regulatory fines, and reputational harm.
- Supporting Continuous Improvement – Cyber threats are constantly evolving. The periodic execution of pen testing helps organizations stay ahead of attackers by continuously assessing and strengthening their security posture.
By adopting a proactive mindset, organizations can use penetration testing not just for compliance with relevant standards but as an ongoing practice to enhance cyber resilience and minimize security risks.
Challenges Organizations Face in NIS2-Aligned Penetration Testing
Many businesses struggle to implement pen testing effectively due to limited in-house expertise and budget constraints. A key solution is partnering with a trusted Managed Security Services Provider (MSSP) with a proven track record in penetration testing service.
While some companies assume high-quality pen testing requires a huge investment, the financial impact of a data breach is far greater. 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.
Another major challenge is what happens after the pen test – interpreting and acting on the results. Many organizations lack the internal resources to properly analyze reports, prioritize vulnerabilities, and implement fixes. Without a structured remediation plan, security gaps remain unaddressed, leaving businesses exposed to potential cyber attacks.
Engaging an MSSP that not only conducts thorough pen tests but also provides clear remediation guidance and follow-up testing is of great importance for NIS2 compliant companies.
Best Practices for NIS2-Aligned Penetration Testing
To maximize the effectiveness of penetration testing under NIS2, organizations should follow these best practices:
1. Test Regularly, Not Just for Compliance
NIS2 compliance shouldn’t be the only reason to conduct penetration tests. Cyber threats evolve constantly, and businesses should perform tests regularly – at least annually or after significant infrastructure changes – to ensure continuous security and reduce existing attack vectors. Relying on a one-time penetration test is a dangerous misconception, as cybersecurity threats continuously evolve, requiring ongoing assessments to stay protected.
2. Define a Clear Scope
Penetration tests should be tailored to cover critical systems, applications, and digital infrastructure based on the organization’s risk profile. This includes:
- Internal and external networks
- Cloud environments
- Web applications and mobile apps
- IoT and operational technology (OT) systems
3. Combine Automated and Manual Penetration Testing
Automated vulnerability scans help in detecting known weaknesses and identifying relevant attack vectors, but manual pen testing provides deeper insights into complex security gaps that automated tools might miss. A combination of both ensures a thorough security posture assessment. You can read our article for more info on the Pros and Cons of Manual vs Automated Penetration Testing.
4. Prioritize and Act on Findings
Testing is only valuable if organizations act on the results. After each penetration test, security teams should:
- Perform vulnerability management based on risk level
- Try to (significantly) reduce existing attack surface
- Develop a remediation plan
- Perform a retest after fixes to validate improvements
5. Work with Certified Security Experts
Engaging experienced cybersecurity professionals guarantees thorough, high-quality pen testing that aligns with NIS2 requirements. Third-party testers bring essential services and extensive cross-industry experience, uncovering security flaws that in-house teams may miss. When selecting an external security provider, prioritize those with industry-recognized certifications such as CREST accreditation, OSCP, and CISSP, ensuring expertise, ethical standards, and compliance with best practices.
Final Thoughts & Next Steps
NIS2 is setting a new standard for cybersecurity, pushing organizations to adopt stronger security measures like penetration testing for reliably detecting security gaps. While compliance is crucial, businesses should go beyond regulations and leverage pen testing as a strategic tool to reduce the chance of data leakage and significantly increase cyber resilience.
By investing in proactive cybersecurity measures, organizations can safeguard their operations, protect sensitive data, allow quick detection of threat actors and stay ahead of evolving cyber threats.
AMATAS’ Penetration Testing Service evaluate your security posture through the lenses of a CREST-accredited pen testers, identify the gaps in your defenses and ensure compliance with NIS2.
Book a call with our team today to discuss how pen testing can support your NIS2 compliance and long-term cybersecurity strategy.
FAQs
Does SOC 2 require penetration testing?
No, SOC 2 does not explicitly require penetration testing, but it strongly recommends it as part of a robust security program. The periodic execution of penetration tests is key in helping organizations identify vulnerabilities, strengthen controls, and demonstrate a proactive approach to security, which supports compliance with SOC 2’s security, availability, and confidentiality principles.
Who does NIS 2 apply to?
The EU’s NIS2 directive targets essential and important entities across critical sectors such as finance, healthcare, energy, transportation, and digital services. Organizations that provide critical infrastructure, manage sensitive data, or have a significant impact on the economy and society must comply with NIS2’s cybersecurity, risk management, and incident reporting requirements.
What is the difference between GDPR and NIS2?
GDPR focuses on data protection and privacy, ensuring personal data is handled securely, while NIS2 is about cybersecurity resilience, requiring organizations to implement risk management and security measures to protect critical infrastructure and services. While both regulations enhance security, NIS2 extends beyond data protection to cover broader cybersecurity risk based vulnerability management requirements.
How does NIS2 penetration testing help my organization maintain compliance?
NIS2 penetration testing helps identify and remediate security vulnerabilities, relevant attack vectors preventing data leakage, ensuring compliance with risk management and cybersecurity requirements. Regular testing strengthens defenses against threats, supports incident response readiness, provides documented security assessments to demonstrate compliance during audits.
How often should we conduct penetration testing to align with NIS2 regulations?
Organizations should conduct penetration testing at least annually or after significant system changes to align with NIS2 regulations. More frequent testing may be required for high-risk environments to address evolving threats and maintain compliance with the directive’s risk management approach.
Can internal teams conduct NIS2 penetration tests, or is an external provider required?
While internal teams can perform penetration tests, NIS2 recommends third-party testing for unbiased risk assessments. External providers bring specialized expertise, advanced attack simulation techniques, and independent validation, ensuring comprehensive compliance with regulatory requirements.
What is the financial impact of not performing regular NIS2 penetration tests?
Failing to conduct regular penetration tests can result in regulatory fines, data breaches, and operational disruptions, leading to significant financial losses. Non-compliance with NIS2 may also damage business reputation, cause loss of trust, and increase remediation costs after an incident.
Why is NIS2 penetration testing important for financial and operational stability?
NIS2 penetration testing reduces financial risk and ensures business continuity by identifying security gaps before attackers exploit them. It helps prevent costly breaches, downtime, and regulatory penalties, safeguarding business operations stability and maintaining trust with customers and partners.
How does penetration testing differ from general cybersecurity assessments?
Penetration testing actively simulates real-world attacks to identify exploitable vulnerabilities, while general cybersecurity assessments focus on broader risk evaluations, policies, and controls. Penetration testing provides a deeper, hands-on evaluation of security weaknesses, ensuring compliance with NIS2’s proactive risk and vulnerability management requirements.
