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Annex.I.5 NIS2

NIS2 Annex.I.5: Banking and Financial Market Infrastructure Cybersecurity Requirements

What This Control Requires

Annex I identifies the banking sector (credit institutions as defined in Regulation (EU) No 575/2013) and financial market infrastructures (operators of trading venues and central counterparties).

In Plain Language

A successful cyber attack on a major bank or trading platform can undermine public confidence, freeze economic activity, and cascade through the entire financial system. NIS2 classifies banking and financial market infrastructure as highly critical - but for financial entities, the real compliance story involves DORA as well. Financial organisations face one of the most layered regulatory environments for cybersecurity anywhere. The Digital Operational Resilience Act (DORA) provides a comprehensive ICT risk management framework built specifically for the financial sector. DORA largely supersedes NIS2 on cybersecurity requirements for financial entities, though NIS2 remains relevant for areas DORA does not explicitly cover. The threat landscape matches the regulatory intensity. Nation-state groups, organised crime syndicates, and hacktivists all target financial systems - payment platforms, SWIFT interfaces, trading systems, and customer accounts represent high-value targets that attract the most sophisticated attack techniques. Financial entities typically run more mature cybersecurity programmes than other sectors, and they need to.

How to Implement

Use DORA as your primary compliance framework and map NIS2 requirements against it to identify any gaps. Since DORA is more detailed and sector-specific, treating it as the baseline gives you most of your NIS2 coverage by default. Build a comprehensive ICT risk management framework as DORA requires. Cover identification and classification of all ICT-supported business functions, protection and prevention measures, detection capabilities, response and recovery procedures, and mechanisms for learning and continuous improvement. Run regular digital operational resilience testing. Perform vulnerability assessments and network security assessments annually. For significant financial entities, conduct advanced threat-led penetration testing (TLPT) at least every three years. Test business continuity and disaster recovery plans against realistic scenarios. Get a firm grip on third-party ICT risk. Financial entities depend heavily on technology providers for cloud, core banking, and payment processing. Address DORA's requirements on concentration risk for critical ICT providers, contractual security obligations, ongoing provider monitoring, and the European oversight framework for critical ICT third-party providers. Set up incident reporting that satisfies both NIS2 and DORA timelines. The two frameworks have their own classification and reporting requirements that differ in specifics. Build a single process that captures both efficiently rather than running parallel workflows. Join sector information sharing initiatives - FS-ISAC or equivalent financial sector bodies. DORA specifically encourages voluntary cyber threat intelligence sharing between financial entities, and the practical value of peer intelligence in this sector is substantial. Maintain thorough audit trails and evidence packages for regulatory examinations. Financial supervisors (ECB, national regulators) scrutinise cybersecurity posture intensively, and you will face their examinations alongside NIS2 competent authority reviews.

Evidence Your Auditor Will Request

  • ICT risk management framework aligned with DORA requirements
  • Digital operational resilience testing reports (TLPT, vulnerability assessments)
  • Third-party ICT risk management programme and provider assessments
  • Incident classification and reporting procedures covering both NIS2 and DORA
  • Participation in financial sector information sharing (FS-ISAC or equivalent)

Common Mistakes

  • NIS2 and DORA compliance managed in silos without integrated approach
  • Digital operational resilience testing conducted infrequently or with narrow scope
  • Concentration risk on critical ICT third-party providers not assessed or managed
  • Incident reporting processes do not address both NIS2 and DORA timelines
  • Legacy banking systems with accumulated technical debt and security vulnerabilities

Related Controls Across Frameworks

Framework Control ID Relationship
ISO 27001 A.5.1 Related
SOC 2 CC1.1 Related

Frequently Asked Questions

Does DORA replace NIS2 for financial entities?
Largely, yes. DORA is treated as lex specialis - sector-specific legislation that takes precedence over NIS2 on ICT risk management and incident reporting. However, NIS2 may still apply to areas DORA does not explicitly cover. In practice, comply with both frameworks but use DORA as your primary reference and check NIS2 for anything additional.
What is TLPT and is it mandatory?
Threat-Led Penetration Testing (TLPT) goes well beyond a standard pentest. It simulates the actual tactics, techniques, and procedures of real threat actors targeting your organisation. Under DORA, significant financial entities must undergo TLPT at least every three years. The testing follows the TIBER-EU framework (or equivalent) and must be conducted by qualified external testers. It is considerably more thorough and realistic than typical vulnerability scanning or penetration testing.

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