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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

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:

1. Clear Categorization: The 10 Top Level Cyber Threat Clusters provide a more precise and cybersecurity-focused categorization of threats, which could help refine NIS2's broad definitions.
2. Focused Scope: By adopting a threat cluster approach, NIS2 could maintain a clearer focus on genuine cyber threats while still acknowledging their connections to broader IT and operational risks.
3. Improved Risk Management: The threat cluster concept offers a more structured approach to risk management, potentially making it easier for entities to comply with NIS2 requirements in a way that's truly relevant to cybersecurity.
4. Alignment with Operational Reality: The threat clusters, derived from a logical thought experiment, better reflect the actual landscape of cyber threats, potentially making NIS2 more effective and easier to implement.
5. Enhanced Threat Intelligence: Incorporating the threat cluster concept could improve the directive's approach to threat intelligence sharing and incident reporting, making these processes more targeted and effective.

By integrating the cyber threat cluster concept, NIS2 could address the current lack of precision in its threat definitions, potentially leading to a more focused, effective, and implementable cybersecurity framework across the EU.

NIS2 Gaps: CSIRT Cooperation and Threat Landscape Comparability

While NIS2 aims to enhance cybersecurity across the EU, there are significant gaps in two critical areas:

1. 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.
2. 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:

1. 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.
2. 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.
3. 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.
4. 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.
5. 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

In conclusion, your 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.