Chief Information Security Officer

Jun 25, 2025

7 min. read

ISO 27001 regulations and implementation in Greece

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ISO 27001 regulations and implementation in Greece

ISO 27001 arrives in Greece as a verbatim standard—ΕΛΟΤ EN ISO/IEC 27001:2023—yet organisations soon discover that full compliance depends on a patchwork of national laws, sector rules and accreditation conditions. Understanding how these overlays interact is the first step toward building an information-security management system (ISMS) that satisfies regulators, wins tenders and strengthens operational resilience. 

In this article I outline those Greek-specific requirements, explain implementation tactics, quantify business impact and extract strategic lessons for security leaders. 

Country-specific requirements

ISO 27001 is adopted without changes as ΕΛΟΤ EN ISO/IEC 27001:2023, but nine national schemes extend or tighten its application. The Hellenic Accreditation System (ESYD) sits at the centre, because only ESYD-accredited certification bodies can issue certificates that the market trusts. According to the official ESYD register, more than 180 Greek entities already hold valid ISO 27001 credentials, and contracting authorities routinely verify each certificate number online.

AreaGreek requirementWhat changes compared with “plain” ISO 27001
Certification and accreditationOnly ESYD-accredited bodies may certifyBuyers and regulators reject non-ESYD certificates
Horizontal cyber-security lawLaw 5160/2024 transposes NIS 2An ISO 27001 certificate gives “presumption of conformity” if the Statement of Applicability lists every Law 5160 control and security incidents are reported within 24 h / 72 h
Legacy implementing decreeMinisterial Decision 1027/2019 (still referenced)Defines the self-assessment and corrective-action plan templates for interim reports
National strategy and maturity toolsNCSA Strategy 2020-2025 and Self-Assessment Guide 2022Thirty-eight baseline controls map one-to-one to ISO 27001; annual scorecards for ministries and municipalities
Public-sector and Gov-Cloud rulesDigital Governance Code, arts 145–150Most public RFPs require ISO 27001 + ISO 27017 / 27018 and a Greek SoA mapped to art 148
Telecom and 5 G operatorsADAE Regulation 205/2013Operators must run an ISO 27001-style ISMS, undergo external audit every three years and file annual security reports
Financial services and FMIsBank of Greece Act 190/2021 (implements EBA GL/2019/04)Clause 9 metrics populate the yearly ICT-risk report and, from January 2025, the <a href=”https://eur-lex.europa.eu/eli/reg/2023/2554″>Digital Operational Resilience Act</a> dashboards
Healthcare and e-healthe-Health Integration Guide 2025Hospitals and e-Prescription platforms base security plans on ISO 27001 controls and submit annual maturity self-checks
Data-protection interplayHDPA certification schemeISO 27001 controls recognised as “state of the art” under GDPR Art 32, limiting fines
Greek overlays to ISO 27001

Because these overlays are cumulative, one organisation—say, a cloud provider serving banks—may need to satisfy several rows at once. That reality shapes implementation choices and leads naturally to the next topic.

How organisations implement ISO 27001 in Greece

Greek practitioners treat ISO 27001 as the core and every national overlay as an annex. The first design step is to build a control-mapping matrix and paste it into the Statement of Applicability (SoA). ESYD auditors and National Cyber-security Authority inspectors routinely request that matrix, so creating it early prevents painful revisions later.

Synchronising different audit and reporting calendars avoids assessment fatigue. The next table shows the default cycles and a proven alignment tactic for each framework.

FrameworkMandatory cycleAlignment tip that reuses ISO 27001 evidence
ISO 27001Three-year certificate plus annual surveillanceSchedule the second-year surveillance audit at the same time as the first Law 5160 external cyber-audit
Law 5160 (NIS 2)External conformity assessment at least every two years; incident KPIs each quarterReuse ISO 27001 internal-audit minutes and clause 9 dashboards
ADAE 205/2013Full audit every three years with an annual security reportExport the ADAE report directly from ISO 27001 metrics
BoG Act 190 / DORAYearly ICT-risk report (and quarterly soon under DORA)Feed the report from the same KPI lake used for ISO 27001
NCSA self-assessmentAnnual scorecardGenerate answers directly from the ISO 27001 risk register
Aligning audit and filing cycles

Greek law also requires certain artefacts—risk analyses, incident playbooks and Law 5160 submissions—to be written in Greek. Dual-language policies speed up audits by foreign customers, maintaining the export flexibility many tech firms value. Automated data tagging completes the job: when SIEM events or vulnerability scans are labelled once, they populate every dashboard and statutory report downstream.

Impact of ISO 27001 on businesses in Greece

Adopting ISO 27001 in Greece is not merely a regulatory box-ticking exercise. It opens tenders, lowers fines and even reduces cyber-insurance deductibles. The next table summarises the gains most often cited by Greek CISOs and compliance officers.

Impact areaEffect felt in daily operations
Tender eligibilityPublic-sector RFPs and Gov-Cloud framework agreements exclude bidders lacking ISO 27001, often demanding ISO 27017 / 27018 as well
Regulatory shieldRecognised as “state of the art” under GDPR Art 32, Law 5160, ADAE 205/2013 and BoG Act 190, narrowing inspection scope and shrinking maximum fines
Supply-chain trustLarge corporates verify certificates in the ESYD register; ISO 27001 shortens vendor-risk questionnaires
Insurance and EU fundsCyber-insurers quote lower deductibles; Recovery and Resilience Facility or Horizon Europe grants award extra points to certified projects
Operational resilienceThe continual-improvement loop in ISO 27001 dovetails with Law 5160 incident SLAs, ADAE outage rules and BoG / DORA stress tests, accelerating recovery and audit readiness
Practical business benefits

These effects show why Greek boards now treat information security as a growth enabler, not a cost centre. The next question is how to sustain that momentum.

Key takeaways

Three mantras guide successful Greek security leaders. First, operate one ISMS and assign multiple badges by annexing Law 5160, ADAE, BoG / DORA or Gov-Cloud controls. Second, stay under the ESYD umbrella so buyers and supervisors cannot dispute certificate validity. Third, collect evidence once and serve five masters by tagging logs and metrics up front. The closing table distils these lessons into a concise reference.

TakeawayWhy it matters in practice
Build a single ISO 27001:2022 core and attach sector-specific annexesAvoids duplication and ensures consistent risk treatment
Use ESYD-accredited certification bodiesRemoves approval delays with contracting authorities and regulators
Tag data so one dashboard serves every reportSlashes reporting time for Law 5160, ADAE, BoG and grant audits
Map ISO 27001 to Law 5160 earlyDelivers more than 80 percent NIS 2 compliance before secondary decrees arrive
Strategic lessons for Greek CISOs

Simplify Greek ISO 27001 compliance with CyberUpgrade

Navigating ΕΛΟΤ EN ISO/IEC 27001 alongside Greece’s NIS 2, ADAE, BoG, and public-sector mandates can overwhelm any security team. CyberUpgrade centralizes control mappings and automates bilingual evidence tagging, delivering real-time compliance prompts via Slack or Teams. By cross-mapping your SoA once, you satisfy ESYD, NCSA, ADAE, Bank of Greece, and e-Governance checks without redundant audits. This unified approach prevents overlooked deadlines and audit fatigue.

Automated breach-report workflows enforce 24 h/72 h incident notices to regulators and feed SIEM logs and vulnerability scans directly into every authority’s dashboard. CyberUpgrade’s dynamic KPI lake populates annual self-assessments, security reports, and DORA dashboards simultaneously, cutting manual effort by up to 80%. With evidence tagged once, your team spends less time chasing paperwork and more on strengthening controls. This efficiency frees capacity for strategic resilience rather than administrative tasks.

Fractional CISO support tailors your ISMS to Greek annexes—NIS 2, telecom 5 G controls, or financial-sector KPIs—without hiring full-time specialists. CyberUpgrade adapts to evolving local laws and integrates seamlessly into existing workflows, transforming compliance from a cost center into a competitive advantage. Accelerate public-sector tender success, lower insurance premiums, and build lasting supply-chain trust with a modular, multi-badge ISMS that’s ready for Greece’s next compliance leap.

Are you ready for the next compliance leap?

Greece will publish the secondary NIS 2 decrees in 2025. Organisations that have already cross-mapped ISO 27001 to Law 5160 will wake up to find most new controls already addressed. Those that wait will scramble for evidence across scattered spreadsheets. The choice today determines whether tomorrow’s audit feels like an administrative formality or a costly fire drill.

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Chief Information Security Officer

He is a cybersecurity leader with over a decade of experience building secure, resilient IT environments for fintech and tech firms. He specializes in ISO 27001–based security management, ITIL service delivery, and process automation, with deep expertise in IAM, risk assessment (GDPR, NIS2, DORA), and security governance. Zbignev advises on emerging security trends, helping organizations turn compliance and risk challenges into strategic advantages.

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