TLCTC Blog - 2025/04/12
NIS 2 Directive: Definitions, Scope of Threats, and Potential Improvement
The NIS2 Directive aims to address cybersecurity threats, but its definitions potentially broaden the scope to include a wider range of IT and operational risks:
Key Definitions and Scope:
- Cyber Threat (Article 6(10)): "Any potential circumstance, event or action that could damage, disrupt or otherwise adversely impact network and information systems, the users of such systems and other persons." This broad definition could encompass more than just cyber-specific threats.
- All-Hazards Approach (Article 21(2)): Calls for measures "based on an all-hazards approach that aims to protect network and information systems and the physical environment of those systems from incidents", explicitly broadening the scope beyond pure cyber threats.
- Risk Management Scope (Article 21): Entities must "manage the risks posed to the security of network and information systems". This could be interpreted to include broader IT and operational risks impacting these systems.
- Physical Security: Inclusion of measures like "human resources security, access control policies and asset management" (Article 21(2)(i)) touches on physical security aspects.
- Supply Chain Security (Article 21(2)(d)): Potentially brings in a wider range of operational and business risks.
While primarily focused on cybersecurity, NIS2's definitions and scope could be interpreted to encompass a broader range of IT risks and some aspects of operational risk, reflecting the interconnected nature of cyber risks with other forms of organizational risk in modern digital environments.
Conclusion: Potential Improvement with Cyber Threat Clusters
| NIS2 Challenge | How TLCTC Addresses It | Benefit |
|---|---|---|
| Broad and ambiguous definitions | 10 Top Level Cyber Threat Clusters provide precise categorization | Refined definitions with cybersecurity focus |
| Overly broad scope | Threat cluster approach maintains clearer focus | Balance between cyber threats and their connections to broader risks |
| Complex risk management requirements | Structured approach to risk management | Easier compliance with NIS2 requirements |
| Misalignment with operational reality | Clusters derived from logical thought experiment | Better reflection of actual cyber threat landscape |
| Inefficient threat intelligence sharing | Standardized categorization system | More targeted and effective intelligence sharing |
The broad and potentially ambiguous definitions in NIS2 could lead to confusion in implementation and possibly dilute the focus on core cybersecurity issues. This is where the concept of cyber threat clusters could significantly improve the directive.
NIS2 Gaps: CSIRT Cooperation and Threat Landscape Comparability
Critical Gaps in NIS2
- Common Language for CSIRTs: NIS2 doesn't provide a standardized terminology or framework for CSIRTs (Computer Security Incident Response Teams) across EU member states to exchange threat information effectively.
- Comparability of Threat Landscapes: The directive lacks a unified approach to assess and compare cyber threat landscapes across different EU states.
How the Cyber Threat Cluster Concept Addresses These Gaps
Standardized Threat Categorization
The 10 Top Level Cyber Threat Clusters provide a common framework that CSIRTs across the EU could use to categorize and communicate about threats. This would significantly enhance the clarity and efficiency of information exchange.
Unified Threat Assessment
By adopting the threat cluster approach, EU member states could assess their cyber threat landscapes using a consistent methodology. This would make it much easier to compare threat levels and patterns across different countries.
Improved Incident Reporting
The threat clusters could serve as a basis for a more structured incident reporting system, ensuring that incidents are categorized consistently across the EU. This would facilitate better trend analysis and cross-border cooperation.
Enhanced Strategic Planning
With a common understanding of threats based on the clusters, EU-wide strategic planning for cybersecurity would become more coherent and effective.
Facilitated Threat Intelligence Sharing
The threat cluster framework could serve as a common language for threat intelligence sharing platforms, making it easier for different national CSIRTs to collaborate and share insights.
Potential Impact
By incorporating the cyber threat cluster concept, NIS2 could:
- Significantly improve the effectiveness of cross-border CSIRT cooperation
- Enable more accurate comparisons of cybersecurity status across EU member states
- Facilitate more targeted and effective EU-wide cybersecurity strategies
- Enhance the overall resilience of the EU's digital infrastructure by ensuring a more unified approach to threat management
Conclusion
The cyber threat cluster concept could indeed play a vital role in addressing these critical gaps in NIS2, potentially transforming how cybersecurity is managed and coordinated across the European Union.
PROJECT REFERENCE: Cyber Threat Clusters
EXTERNAL REFERENCE: NIS 2 Directive
No additional updates are scheduled at this time.