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Compliance Guide
NIS2 Implementation Guide: Identity Governance for Critical Infrastructure
Who should read this:
CISOs, infrastructure operators, identity leaders, and compliance owners in essential or important entities.
Immediate Takeaways
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Treat privileged and supplier identities as critical assets, not just user accounts.
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Map Article 21 measures to access control, MFA, asset ownership, cyber hygiene, supplier access, and evidence testing.
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Prepare incident workflows for early warning, incident notification, and final reporting windows.
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Give management a monthly access-risk register with owners, gaps, remediation dates, and accepted residual risk.
Action Plan
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Week 1: build the inventory of critical apps, privileged accounts, third-party identities, and service accounts.
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Weeks 2-3: enforce MFA, least privilege, emergency access controls, joiner-mover-leaver automation, and supplier expiry dates.
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Weeks 4-5: run access certification for critical systems and document exceptions.
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Week 6: rehearse an identity incident, produce evidence, and brief management.
Action Plan
-
Week 1: build the inventory of critical apps, privileged accounts, third-party identities, and service accounts.
-
Weeks 2-3: enforce MFA, least privilege, emergency access controls, joiner-mover-leaver automation, and supplier expiry dates.
-
Weeks 4-5: run access certification for critical systems and document exceptions.
-
Week 6: rehearse an identity incident, produce evidence, and brief management.