A few months ago, I sat across from a compliance officer who looked visibly frustrated. “We’ve implemented everything—at least we think we have,” she told me. “But when it comes to preparing for a NIS2 audit, we don’t know what the auditors will be looking for. It’s like preparing for an exam without seeing the syllabus.”
That sentiment isn’t rare. The NIS2 Directive—the EU’s ambitious step-up from NIS1—has expanded scope, stricter oversight, and broader enforcement teeth. For organizations falling under its scope, navigating audit readiness is more than a matter of ticking boxes. It requires operational clarity, risk maturity, and structured documentation.
Let’s walk through what makes a NIS2 compliance audit different, what you’ll need to prove, and how you can prepare with both confidence and clarity.
What makes a NIS2 audit different?
Audits under NIS2 are no longer abstract exercises in theoretical resilience. They are regulatory mechanisms with real implications. The NIS2 Directive, formally enforced as of October 2024, introduces binding cybersecurity obligations across essential and important entities in sectors like energy, healthcare, finance, digital infrastructure, and more.
The audit process under NIS2 is based on Article 32 and Article 41, which empower national authorities to conduct both regular and ad hoc audits, require access to documentation and systems, and issue binding instructions or penalties in case of shortcomings.
Here’s how NIS2 oversight typically differs from earlier frameworks:
Key differences between NIS1 and NIS2 audit frameworks
| Criteria | NIS1 | NIS2 |
| Audit enforcement | National-level discretion | Harmonized across EU with mandatory audits |
| Sector scope | Limited to critical sectors | Broadened to 18 sectors (essential & important entities) |
| Security requirements | General guidance | Specific risk management and incident response measures |
| Penalties | Often symbolic or light | Up to €10M or 2% of global turnover |
| Reporting obligations | Limited to major incidents | Broader, stricter, and with time-bound reporting |
The broader scope alone means many organizations—especially digital service providers—are preparing for their first-ever cybersecurity audit. And while the framework aims for consistency across member states, national authorities still interpret it within local contexts. Preparation requires both EU-wide and country-specific diligence.
Understanding NIS2 audit requirements
Before you can prepare for an audit, you need to understand what’s being assessed. Auditors aren’t just interested in whether you’ve installed firewalls or run pen tests—they’re evaluating systemic resilience, governance involvement, and your organization’s ability to detect, respond to, and recover from incidents.
The NIS2 audit requirements are tied to Article 21 of the directive, which outlines ten core security elements organizations must implement. These elements span governance, supply chain security, encryption, authentication, and more.
Core NIS2 audit requirement categories
| Requirement area | Focus of evaluation |
| Risk analysis & policies | Formal risk assessments, documented procedures |
| Incident handling | Detection, response plans, forensics, reporting chain |
| Business continuity | Recovery plans, disaster drills, continuity governance |
| Supply chain security | Third-party risk management and vendor assessments |
| Security in system design | Secure development lifecycle and architectural review |
| Vulnerability handling | Patching processes and coordination with CSIRTs |
| Testing and auditing | Internal audits, penetration testing, red/blue teaming |
| Personnel security | Security training, role-based access controls |
| Cryptography and encryption | Use of cryptographic measures where appropriate |
| Authentication | MFA, identity verification, privileged access control |
Each of these areas needs documentation, policy evidence, and demonstration during audits. Your systems may be secure—but if your documentation is disorganized or incomplete, it will count against you.
Building your NIS2 audit checklist
I’ve worked with multiple organizations who thought they were ready, only to realize their preparation lacked structure. A well-structured checklist translates compliance theory into operational action. It bridges the gap between regulation and practice.
Below is a simplified NIS2 audit checklist to help structure your internal assessment and gap analysis.
NIS2 audit readiness checklist template
| Audit readiness task | Responsible owner | Status | Evidence location | Last reviewed |
| Conduct formal risk assessment | CISO | Risk Register | ||
| Review and update incident response plan | Head of Security Ops | IRP Document Repository | ||
| Verify backups and recovery tests | IT Infrastructure Lead | BCP Audit Logs | ||
| Evaluate vendor risk management processes | Procurement | Third-party Risk Reports | ||
| Perform security training for key personnel | HR & Compliance | Training Logs / HR LMS | ||
| Document cryptographic standards used | IT Security | Security Architecture Docs | ||
| Perform internal penetration testing | External Vendor | Testing Reports | ||
| Review MFA enforcement for privileged accounts | IAM Administrator | Identity Management Console |
This template is your living document. Update it quarterly or whenever significant system changes occur. Use it during pre-audit self-assessments or as a walkthrough with regulators.
How to prepare for a NIS2 internal audit
When preparing for a NIS2 internal audit, think like an external auditor. The goal is not just to pass—it’s to uncover gaps before someone else does. You’ll want to test both the strength and the consistency of your security framework.
Start with a scoped readiness review. Are all your in-scope entities mapped? Do you have a comprehensive inventory of systems, applications, and third-party connections?
Then move into simulated audit scenarios. What happens when you declare a major incident? Who speaks to the authorities? How do you pull system logs? These runbooks aren’t just hypothetical—they’re often evaluated during audits.
Treat documentation as part of your control environment. For each policy, have corresponding technical controls, ownership, review cycles, and audit trails.
Also, ensure board-level oversight. Under NIS2, executives can be held personally accountable. This isn’t just an IT problem—it’s a governance imperative.
A good practice is to assign an internal audit lead and conduct walkthroughs using the template above. Partner with legal, compliance, and IT to ensure full alignment across the business.
Are you audit-ready or just hoping for the best?
Preparing for a NIS2 audit isn’t a matter of chance or luck—it’s the result of proactive alignment between policy, practice, and preparedness. From understanding NIS2 audit requirements to structuring a practical NIS2 audit checklist, organizations that succeed take a programmatic and cross-functional approach.
A rushed or improvised audit preparation may pass once—but it won’t survive repeated scrutiny. As the regulatory environment matures, so will expectations. The organizations that embed resilience into their operations will find audits less stressful—and more valuable.
If you’re unsure where your biggest gaps are, don’t wait until your NIS2 internal audit. Use the checklist, assign clear ownership, and document everything. And above all—treat your security posture not just as a compliance duty, but as a competitive asset.
Let me know if you’d like a customizable version of the checklist as an editable Excel or Google Sheet—I’d be happy to provide it.
