The Role of Vulnerability Management and Penetration Testing in NIS2 and DORA Compliance

Both the NIS2 Directive and the Digital Operational Resilience Act (DORA) emphasise the need for robust cybersecurity measures to ensure the resilience of critical infrastructure and financial services across the EU. Vulnerability management and penetration testing play essential roles in achieving compliance with these regulations by proactively identifying, assessing, and mitigating security risks.

This article explores how vulnerability management and penetration testing help organisations comply with NIS2 and DORA, including their integration with risk management frameworks, reporting obligations, and regulatory audits.

1. Overview of NIS2 and DORA

The NIS2 Directive applies to organisations that provide essential and important services across various sectors, including healthcare, energy, transportation, and digital infrastructure. It mandates strict cybersecurity controls to protect critical infrastructure.

The Digital Operational Resilience Act (DORA) focuses on financial institutions and ICT providers in the EU, requiring them to strengthen their operational resilience against cyber threats and IT failures. It applies to banks, insurance companies, investment firms, payment service providers, and related ICT service providers.

Both regulations share key objectives, including:

• Enhancing risk management practices.

• Requiring continuous monitoring and proactive risk mitigation.

• Mandating incident response and regular reporting.

• Ensuring third-party security and accountability.

Vulnerability management and penetration testing are critical components of these requirements.

2. What is Vulnerability Management?

Vulnerability management is the process of identifying, assessing, and remediating security weaknesses in an organisation’s IT infrastructure. It involves continuous monitoring, prioritisation, and mitigation of vulnerabilities to reduce the risk of exploitation by threat actors.

The vulnerability management lifecycle includes the following stages:

1. Discovery: Identifying vulnerabilities through automated scans and manual assessments.

2. Assessment: Evaluating the risk level based on severity, business impact, and exploitability.

3. Prioritisation: Focusing remediation efforts on high-risk vulnerabilities.

4. Remediation: Applying patches, reconfiguring systems, or implementing other security measures.

5. Verification: Conducting follow-up scans to confirm that vulnerabilities have been resolved.

Vulnerability management aligns with the risk-based approach advocated by both NIS2 and DORA.

3. What is Penetration Testing?

Penetration testing (pentesting) involves simulating real-world cyberattacks to assess the effectiveness of an organisation's security measures. Unlike vulnerability scans, which identify known vulnerabilities, penetration tests actively exploit weaknesses to understand the impact and identify gaps in security.

Types of penetration testing include:

• External Testing: Focuses on public-facing infrastructure, such as websites and VPNs.

• Internal Testing: Simulates insider threats by assessing internal systems and networks.

• Web Application Testing: Identifies vulnerabilities specific to web applications, such as SQL injection and cross-site scripting (XSS).

• Social Engineering Testing: Evaluates the effectiveness of security awareness by simulating phishing attacks or other manipulation tactics.

Penetration testing provides valuable insights into how attackers might exploit vulnerabilities, helping organisations strengthen their defences.

4. How Vulnerability Management Supports Compliance with NIS2 and DORA

Both NIS2 and DORA require organisations to implement risk-based cybersecurity measures. Vulnerability management directly supports compliance in several ways.

4.1. Proactive Risk Identification

NIS2 and DORA mandate continuous risk assessment to ensure that critical systems remain secure. Regular vulnerability scans help organisations identify security weaknesses before attackers can exploit them.

Compliance Connection:

• Under NIS2, organisations must adopt measures to "prevent, detect, and respond to incidents" by securing their networks and information systems.

• DORA requires financial institutions to "assess ICT risks regularly" and implement appropriate controls.

4.2. Prioritisation of Critical Vulnerabilities

Compliance frameworks encourage a risk-based approach to cybersecurity. Vulnerability management tools, such as those using Vulnerability Priority Rating (VPR) and Known Vulnerability Exploitation (KVE) data, help organisations prioritise remediation based on real-world threats.

Compliance Connection:
Both regulations expect organisations to address vulnerabilities in a manner that aligns with the potential impact on their business operations and critical services.

4.3. Integration with Incident Response Plans

NIS2 and DORA require organisations to maintain effective incident response capabilities. Vulnerability management supports these efforts by:

• Providing data on exploited vulnerabilities during an incident.

• Informing post-incident reviews and security improvements.

Compliance Connection:
Organisations must demonstrate that they can detect and respond to security incidents under both NIS2 and DORA.

4.4. Evidence for Regulatory Audits

Regulatory authorities under NIS2 and DORA will conduct periodic audits to verify compliance. Documentation of vulnerability scans, risk assessments, and remediation activities serves as critical evidence during these audits.

Best Practices:

• Maintain detailed vulnerability scan reports.

• Document remediation timelines and actions taken.

• Track recurring vulnerabilities and lessons learned.

5. How Penetration Testing Supports Compliance with NIS2 and DORA

Penetration testing enhances compliance by providing a deeper understanding of security risks. It complements vulnerability management by simulating real-world attacks, helping organisations identify gaps that automated scans might miss.

5.1. Testing the Effectiveness of Security Controls

Penetration tests evaluate whether existing security controls, such as firewalls, access management, and intrusion detection systems, are effective against simulated attacks.

Compliance Connection:
Both NIS2 and DORA require organisations to "test and evaluate the effectiveness of their technical measures" regularly.

5.2. Scenario-Based Resilience Testing

DORA mandates that financial institutions conduct scenario-based testing to assess their ability to withstand and recover from cyber incidents. Penetration tests can simulate various scenarios, such as:

• Distributed denial-of-service (DDoS) attacks.

• Data breaches targeting sensitive information.

• Ransomware attacks on critical infrastructure.

Best Practices:

• Develop test scenarios aligned with regulatory expectations.

• Involve both internal and external stakeholders in the testing process.

• Use findings to improve incident response and recovery plans.

5.3. Identification of Zero-Day and Complex Threats

Unlike vulnerability scans, which rely on known vulnerability databases, penetration tests can uncover zero-day vulnerabilities and complex attack vectors. These findings provide organisations with actionable insights to strengthen their defences.

5.4. Enhancing Awareness and Training

Penetration tests, particularly those involving social engineering, highlight areas where human factors may compromise security. These tests help organisations improve employee awareness and training programmes.

Compliance Connection:
Both regulations emphasise the importance of cybersecurity awareness and training as part of a comprehensive risk management strategy.

6. Best Practices for Implementing Vulnerability Management and Penetration Testing

To ensure compliance with NIS2 and DORA, organisations should adopt the following best practices:

1. Develop a Comprehensive Cybersecurity Framework:
   Align vulnerability management and penetration testing activities with a broader risk management strategy.

2. Perform Regular Assessments:
   Schedule vulnerability scans and penetration tests on a recurring basis (e.g., quarterly, annually) to maintain continuous visibility into risks.

3. Prioritise High-Risk Assets:
   Focus assessments on critical systems and services that have a high impact on business operations and regulatory compliance.

4. Collaborate with Third Parties:
   Involve third-party ICT providers in security testing and ensure they comply with contractual obligations under NIS2 and DORA.

5. Document and Report Findings:
   Maintain detailed records of assessments, remediation efforts, and lessons learned. Use this documentation to demonstrate compliance during audits.

7. Conclusion

Vulnerability management and penetration testing are integral to achieving compliance with both the NIS2 Directive and the Digital Operational Resilience Act (DORA). These practices help organisations identify and mitigate risks, improve resilience against cyber threats, and maintain the trust of customers and regulators. By adopting a proactive approach to security testing, organisations can strengthen their defences and meet regulatory expectations for operational resilience.

For expert assistance with vulnerability management, penetration testing, and compliance audits, contact our cybersecurity specialists today.