The deadline to implement the EU NIS2 directive is fast approaching. Is your organization fully compliant? Remember that all EU member states must adopt and publish the measures necessary for compliance. The punishments for not doing so are huge fines that could affect your company’s financial health, credibility, and reputation.
In a previous article, we discussed how to Prepare for the EU NIS2 Directive, which aims to strengthen the cybersecurity of network and information systems in the region. Here, we’ll dive into another important element you probably have overlooked - Coordinated Vulnerability Disclosure (CVD)
As with its predecessor, a prime component of NIS2 is effective vulnerability management. We already know that vulnerability management and disclosure can directly influence the effectiveness of incident response—a lesson we’ve learned from existing instruments like the GDPR and Regulation (EU) No 910/2014, among others.
However, the challenge is balancing transparent notification requirements with ensuring that incident containment and recovery efforts are not compromised. Also, keep in mind that there may be concerns with determining which supervisory authority or stakeholder to report/disclose incidents to, when to, and to what degree.
This complexity makes it significant to integrate Coordinated Vulnerability Disclosure (CVD) into your cybersecurity policies. And that’s why we’ll discuss this important component today.
How Responsible Disclosure Policies Help in Addressing Security Incidents
Responsible disclosure is a process that allows researchers and security teams to report vulnerabilities that have been found. It covers how vulnerabilities are reported, triaged, patched, and communicated. CVD, which focuses primarily on the disclosure aspect, ensures all parties collaborate effectively without jeopardizing the incident response efforts.
Under NIS2, Coordinated Vulnerability Disclosure requires a structured approach that aligns with regulatory standards and fosters trust between organizations, vendors, users, authorities, and the cybersecurity community. Organizations must balance the legal obligations of reporting and determining who should receive vulnerability information and when it should be shared while simultaneously addressing the practical need to secure systems.
This means properly managing the CVD process is necessary to ensure quicker vulnerability patching, a reduction in exploitation risks, and enhanced overall network resilience.
Moreover, CVD is an integral part of NIS2’s overarching security framework, particularly in terms of continuous monitoring and early detection of vulnerabilities. So, encouraging responsible vulnerability reporting allows organizations to identify weaknesses in their systems faster and address them before they are exploited.
Additionally, CVD aligns with NIS2’s emphasis on incident notification within tight timeframes and strict deadlines, ensuring that vulnerabilities are responsibly disclosed and communicated to the appropriate authorities and stakeholders without delay. This synergy between CVD and continuous monitoring promotes proactive threat mitigation and better compliance with NIS2’s regulatory requirements.
Article 12: Integrating Coordinated Vulnerability Disclosure to Achieve NIS2 Compliance
If you’re scratching your head about complying with NIS2, you don’t have to worry about vulnerability management. The reporting obligation is one gray area for many organizations, but integrating CVD can help clear that up.
The Role of CSIRTs in Reporting Vulnerabilities
For most organizations, when a vulnerability is discovered, it usually involves third-party vendors providing critical services or products. So, it’s important that the service provider is made aware of any vulnerabilities found while using their product or service.
To support this, the final text of the NIS2 directive (Article 12) mandates that EU member states designate a Computer Security Incident Response Team (CSIRT). The CSIRT acts as a trusted intermediary, facilitating communication between the organization reporting the vulnerability and the relevant service providers, vendors, or manufacturers.
When integrating a CVD program to support NIS2 compliance, your CSIRT is responsible for:
Negotiating disclosure timelines with vendors and service providers.
Identifying and contacting relevant entities affected by the vulnerability.
Assisting natural or legal persons in reporting a vulnerability. This may include managing multi-party vulnerability disclosures involving vulnerabilities affecting multiple organizations.
It is also important to remember that disclosing vulnerabilities to relevant authorities—and potentially notifying users—is a key requirement. Given the number of parties involved in the notification process, the NIS2 directive provides a structured CVD framework to ensure smooth coordination.
Under NIS2, vulnerabilities must be reported in a way that allows them to be diagnosed and remedied before any public disclosure.
Since premature publicity may hinder effective incident response, organizations are allowed to prioritize technical mitigation over notifying affected data subjects.
However, this notification becomes compulsory once your organization can mitigate the vulnerability and when public disclosure cannot compromise your response efforts.
Phased Incident Reporting
NIS2’s responsible disclosure framework also requires organizations to follow a phased incident reporting approach. This includes:
Initial notification: Within 24 hours of becoming aware of the incident, organizations must send a notification with only the necessary information to alert the competent authorities and seek assistance.
Detailed report: Within 72 hours, a more comprehensive report must be submitted, followed by a final, detailed report not later than one month after the incident.
The final report must include:
A detailed description of the incident, its severity, and its impact.
The type of threat or root cause that likely triggered the incident.
The mitigation measures applied and any ongoing response efforts.
This two-tiered reporting process allows organizations to focus on incident handling and response while ensuring that critical updates are provided to authorities without overwhelming the incident response team.
ENISA’s European Vulnerability Database
The second part of Article 12 describes the role the European Union Agency for Cybersecurity (ENISA) plays in supporting the implementation of CVD under NIS2.
Upon consultation with the Cooperation Group, ENISA is responsible for developing and maintaining a European vulnerability database. This database will ensure that entities, including their suppliers, can voluntarily and securely disclose publicly known vulnerabilities in ICT products and services.
The European vulnerability database will include the following:
Information that describes the nature of the vulnerability.
The affected ICT products or services, along with an assessment of how severe the vulnerability could be under various circumstances in which it may be exploited.
Availability of patches, or in cases where patches are not yet available, guidance from authorities or CSIRTs on how to reduce potential risks posed by this vulnerability.
ENISA is also responsible for maintaining the security and integrity of this database by establishing appropriate information systems, policies, and procedures.
Why You Need to Leverage Managed Responsible Disclosure Services for NIS2 Compliance
When you think of how damaging cyberattacks can be on your organization and the complexities behind the disclosure process, particularly for NIS2 compliance, leveraging managed responsible disclosure services is a strategic choice.
WebSec provides a managed responsible vulnerability disclosure program (VDP) designed to simplify every aspect of the vulnerability management process—from receiving and documenting vulnerabilities to triaging, patching, and communicating findings.
This program will include a thorough report detailing identified vulnerabilities, assessing their potential impacts, and outlining effective remediation strategies. This proactive approach will reflect your dedication to managing and addressing future vulnerabilities responsibly and also enable your cybersecurity team to concentrate on the technical aspects of mitigating identified threats.
Therefore, combining centralized oversight with expert guidance will help ensure prompt and effective responses to emerging security threats, reinforcing your organization’s defenses against cyber risks.
Do you have a security issue to discuss? Get in touch now.
Continuous Monitoring and CVD
Continuous monitoring is a major compliance tool under NIS2. Not only does it help maintain an updated view of your security posture, but it also simplifies the path to NIS2 compliance. As part of your CVD efforts, continuous monitoring allows you to ensure there are no post-exploitation threats or residual vulnerabilities following the discovery of an initial vulnerability or after an incident has occurred. This proactive approach minimizes the risk of further exploitation and ensures that mitigative actions are fully effective.
Your CSIRTs must continuously monitor network traffic and system activities to detect anomalies and potential security incidents in real-time. Doing so allows them to quickly respond to new threats and ensure that vulnerabilities are managed effectively, supporting the broader goals of NIS2.
What Security Incident Requires Reporting Under NIS2?
It's important to understand what qualifies as a significant incident. Any breach that disrupts operations or compromises the integrity of your network and information systems falls under this category. If your organization is subject to NIS2, there is no room for discretion here—you must have mechanisms in place to swiftly detect, assess, and report these incidents with precision. This makes it necessary to leverage a managed responsible disclosure service in place.
Comparing NIS2 with Other Cybersecurity Regulations
Below is a quick rundown comparing NIS2 and some major cybersecurity regulations that are available right now.
NIS2 vs DORA
To recap our earlier article, the Network and Information Systems Directive 2 (NIS2) focuses on strengthening the cybersecurity of critical infrastructure and essential services across the EU. It broadens the scope of its predecessor (NIS1) to include more sectors and imposes stricter incident reporting requirements, such as the need to notify significant incidents within 24 hours.
On the other hand, the Digital Operational Resilience Act (DORA) primarily targets the financial sector, ensuring that financial entities can withstand, respond to, and recover from all types of ICT-related disruptions and threats. DORA includes specific requirements for third-party risk management, with a heavy focus on operational resilience. Note that all entities within the scope of the DORA legislation must be fully compliant by January 17, 2025.
NIS2 vs CER
Complementary to NIS2, the Critical Entities Resilience (CER) Directive focuses on ensuring the physical and digital resilience of essential entities in sectors like energy, transport, and healthcare. CER includes risk assessments and crisis preparedness, emphasizing continuity in essential services. The CER Directive officially entered into force on 16 January 2023, replacing the 2008 ECI Directive (European Critical Infrastructure Directive).
NIS2 vs CRA
The Cyber Resilience Act (CRA) targets the manufacturers and developers of products with digital elements. It mandates security by design, ensuring products sold in the EU market are secure from the outset. CRA imposes strict requirements on software and hardware vendors for the cybersecurity of their products, which extends beyond the critical sectors covered by NIS2. The Cyber Resilience Act entered into force in the second half of 2024. Therefore, manufacturers are required to place compliant products on the Union market by 2027.
To summarize the nuances between these cybersecurity instruments, while NIS2 covers essential services across multiple sectors, DORA focuses on financial services, CER emphasizes both physical and digital resilience in critical entities, and CRA targets product security in the EU market.
Although these directives are different, they are all necessary instruments aimed at improving the cybersecurity posture in the European Union. Considering how devastating and regular security incidents have become, these legislations are necessary for creating a unified, robust defense across critical sectors, ensuring that organizations can quickly respond to threats, protect sensitive information, and maintain operational resilience.
Ultimately, such a comprehensive approach is vital for safeguarding the digital economy and the essential services that citizens and businesses rely on daily.
Conclusion
Ensuring responsible disclosure through Coordinated Vulnerability Disclosure (CVD) is a critical component of your NIS2 compliance and overall cybersecurity strategy. By integrating CVD into your vulnerability management framework, you can effectively mitigate security risks while maintaining transparency with regulators, vendors, and other stakeholders.
A proactive approach ensures that security gaps are addressed early, minimizing the risk of exploitation. This not only helps your organization avoid hefty fines and operational disruptions but also strengthens its overall digital resilience.
Additionally, continuous monitoring and a structured vulnerability disclosure program play a key role in identifying threats in a timely manner and reinforcing your cybersecurity posture. Prioritizing responsible disclosure not only demonstrates regulatory compliance but also builds trust with customers, partners, and regulatory authorities—an essential factor for organizations handling sensitive customer data and critical business systems.
To further optimize this process, a managed responsible disclosure program can support a structured and efficient approach to vulnerability management. This ensures that your organization has a robust process for receiving, assessing, and mitigating vulnerabilities while maintaining focus on operational continuity.