Article 7: National cybersecurity strategy

To operationalize the article 7: national cybersecurity strategy requirement, treat it as a jurisdiction-by-jurisdiction obligation to (1) identify each EU Member State’s adopted national cybersecurity strategy and transposed NIS 2 expectations, then (2) map those expectations into your governance, incident readiness, and third-party risk program with named owners and exam-ready evidence. (Directive (EU) 2022/2555, Article 7)

Key takeaways:

• Article 7 is a Member State duty, but it drives what your local regulator expects to see in scope, priorities, and coordination. (Directive (EU) 2022/2555, Article 7)
• Your fastest operational move is an obligation register that ties strategy themes and transposition measures to controls, owners, and milestones. (Directive (EU) 2022/2555)
• Expect supervisory scrutiny on incident workflows and critical third-party dependencies, because those are the proof points of real readiness. (Directive (EU) 2022/2555)

Article 7 sits in a part of NIS 2 many companies skim because it speaks to what Member States must do. That’s a mistake. Even though you do not “write” the national cybersecurity strategy, your regulators and competent authorities will use their national strategy and national transposition package to set supervision priorities, expectations for coordination, and what “good” looks like across essential and important entities. (Directive (EU) 2022/2555, Article 7)

For a Compliance Officer, CCO, or GRC lead, the operational question is simple: can you demonstrate that you understand which national approach applies to your footprint, and have you translated that into actionable requirements with accountable owners? You should be able to show this without a scramble: an obligation register, a clear incident triage/escalation/reporting workflow, and an inventory of critical third-party dependencies that is actually used in risk decisions. (Directive (EU) 2022/2555)

This page is written to get you from “we’ve read Article 7” to “we can evidence our readiness under the national regime(s) that implement NIS 2.”

Regulatory text

What the law says (excerpt):
“Each Member State shall adopt a national cybersecurity strategy that provides for the strategic objectives, the resources required to achieve those objectives, and appropriate policy and regulatory measures, with a view to achieving and maintaining a high level of cybersecurity. The national cybersecurity strategy shall include:” (Directive (EU) 2022/2555, Article 7)

Operator interpretation:

• The direct obligation is on Member States to define strategy, resources, and measures. (Directive (EU) 2022/2555, Article 7)
• Your indirect but examinable obligation is to track and implement the national measures that flow from that strategy, because NIS 2 becomes real through national transposition, supervision, and guidance. (Directive (EU) 2022/2555)
• Practically, this requirement becomes: “Prove you know your national NIS 2 expectations and you have operationalized them into governance, incident readiness, and third-party risk controls.”

Plain-English requirement (what you must be able to show)

You need to be able to show, for each Member State where you are in scope as an essential entity or important entity, that you:

1. Identified the national cybersecurity strategy and the local NIS 2 implementing requirements that apply to you. (Directive (EU) 2022/2555, Article 7)
2. Converted those requirements into internal obligations with owners, timelines, and control mappings. (Directive (EU) 2022/2555)
3. Built “exam-ready” evidence that the program operates, especially for incident handling and third-party dependencies. (Directive (EU) 2022/2555)

If you cannot answer “which national regime applies to this business line and why,” Article 7 is where that gap gets exposed during scoping.

Who it applies to (entity and operational context)

Directly applies to:

• EU Member States (they must adopt the national strategy). (Directive (EU) 2022/2555, Article 7)

Operationally relevant to (your organization):

• Organizations in scope of NIS 2 as essential entities or important entities, operating in one or more Member States and therefore subject to national transposition and supervision priorities. (Directive (EU) 2022/2555)
• Multi-country groups where corporate security sets global policy but local entities face different notification routes, oversight bodies, and documentation expectations.

Where you feel it day-to-day:

• Regulatory change management (tracking national implementation details).
• Incident triage and reporting readiness (who notifies whom, and how fast you can produce facts).
• Third-party risk management (critical suppliers, managed services, cloud, telecom, and operational technology support).

What you actually need to do (step-by-step)

Step 1: Build a “national-to-local” obligation register

Create a register that ties jurisdiction → national strategy / transposition measures → your internal obligations. Keep it simple and auditable.

Minimum fields that work in practice

• Member State / legal entity / in-scope service
• Competent authority contact channel (as implemented locally)
• Applicable obligations (plain English)
• Control mapping (policy, standard, procedure, technical control)
• Owner (named role) and backup
• Evidence pointer (where the proof lives)
• Open gaps and remediation milestone

This is the fastest way to avoid the common failure mode: “global policy exists, but no one can prove local applicability.”

Daydream note: If you already use Daydream for third-party risk and control tracking, store this obligation register alongside your control library and map each national delta to a tracked control task so it cannot disappear in email threads.

Step 2: Align governance to national priorities (without rewriting your whole program)

Take the national strategy themes and ask three governance questions:

1. Decision rights: Who can accept cyber risk for in-scope services, and where is that recorded?
2. Resources: Do you have a resourcing narrative that matches your risk profile (people, tooling, services), even if budgets are held centrally?
3. Policy and regulatory measures: Where do you track externally imposed changes and prove implementation?

Your output is not a new governance framework. It’s a documented mapping from national expectations to your existing governance objects (committees, risk acceptance, control exceptions, internal audit coverage).

Step 3: Codify incident triage, escalation, and reporting so it survives real pressure

Article 7 itself is about national strategy, but supervision driven by that strategy will test your incident readiness quickly. Your workflow must be explicit and rehearsed.

Operational minimum

• Written triage criteria (what qualifies as a potential reportable incident under the applicable national regime)
• Escalation matrix (SOC → incident commander → legal/privacy → compliance → exec)
• Notification decision log (what you knew, when you knew it, why you decided to report or not)
• Evidence retention plan (tickets, timelines, key communications)

A regulator does not need perfect outcomes. They look for controlled execution and traceability.

Step 4: Bring critical third-party dependencies into scope as first-class risks

National strategies and national regulatory measures consistently emphasize resilience and supply-chain exposure. Treat third-party dependencies as part of your service delivery model, not procurement paperwork.

Do this concretely

• Identify “critical third parties” by service criticality and concentration risk (single points of failure, shared infrastructure, privileged access).
• Link each critical third party to: the in-scope service, the risk assessment, required controls/assurances, and an exit or contingency plan.
• Track remediation items with owners and due dates, and tie them to renewal and onboarding gates.

Step 5: Create an exam-ready package per Member State

Prepare a folder (or GRC workspace) per Member State containing:

• Obligation register extract for that jurisdiction
• Entity/service scope statement (what’s in scope and why)
• Incident workflow and last tabletop results
• Critical third-party list for in-scope services and last review outcomes
• Open issues log and management reporting

This reduces supervision cost. It also forces clarity.

Required evidence and artifacts to retain

Use this as your evidence checklist:

Regulatory change & applicability

• NIS 2 applicability memo per entity/service and Member State (Directive (EU) 2022/2555)
• Obligation register with owners and milestones (Directive (EU) 2022/2555)

Governance

• Cyber risk governance charter or committee terms of reference
• Risk acceptance / exception register entries tied to in-scope services
• Management reporting pack showing oversight of cyber risks and remediation

Incident readiness

• Incident response plan and triage criteria
• Escalation matrix and on-call roster
• Tabletop exercise records and after-action items
• Incident decision logs and evidence retention guidance

Third-party risk

• Inventory of critical third parties supporting in-scope services
• Due diligence and assurance artifacts (SOC reports where applicable, security attestations, contract security schedules)
• Concentration and dependency analysis (narrative is acceptable if it’s specific)
• Remediation tracking and renewal gating evidence

Common exam/audit questions and hangups

Questions you should be ready for

• “Which Member State regime applies to this service, and where is that documented?” (Directive (EU) 2022/2555)
• “Show me the control owners and how you track completion of national deltas.”
• “Walk through your incident triage. Who decides whether to notify, and what evidence supports that decision?”
• “Which third parties are critical to your in-scope services, and what is your contingency if one fails?”

Hangups auditors see

• Over-reliance on a global policy with no jurisdictional mapping.
• Incident plans that describe roles but not decision logs, triggers, or evidence retention.
• Third-party risk that stops at onboarding and ignores operational changes, sub-processors, and concentration.

Frequent implementation mistakes (and how to avoid them)

1. Mistake: Treating Article 7 as “not applicable” and moving on.
   Avoid it: Mark it as “Member State obligation with organizational operational dependency,” then link it to your change-management workflow and obligation register. (Directive (EU) 2022/2555, Article 7)

2. Mistake: No single source of truth for national requirements.
   Avoid it: Maintain one obligation register and require every local deviation to be recorded there before policy updates ship. (Directive (EU) 2022/2555)

3. Mistake: Incident readiness is theoretical.
   Avoid it: Require a completed decision log template for every high-severity incident, even if you later determine it is non-reportable.

4. Mistake: Third-party criticality is undefined.
   Avoid it: Establish a documented “critical third party” definition tied to in-scope services, privileged access, and operational substitutability, then apply it consistently.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so you should not expect a ready-made list of Article 7 actions to benchmark against.

Your practical risk is still real:

• If you cannot show how national expectations translate into your controls, you create supervision friction: more follow-up questions, broader evidence requests, and reduced confidence in your governance narrative. (Directive (EU) 2022/2555)
• In a major incident, weak documentation of triage and notification decisions becomes a compounding problem because you must explain your actions under stress.

Practical execution plan (30/60/90-day)

The plan below is written as phases so you can execute without relying on fixed calendar promises.

First 30 days (Immediate: make scope and ownership real)

• Confirm which legal entities and services are in scope per Member State and document the rationale. (Directive (EU) 2022/2555)
• Stand up the obligation register with named owners and a simple status model. (Directive (EU) 2022/2555)
• Draft an incident notification decision log template and require its use for severe incidents.
• Produce an initial list of critical third-party dependencies for in-scope services.

By 60 days (Near-term: make it operable and testable)

• Map each obligation register item to a policy/procedure/control and record the evidence pointer.
• Run a tabletop focused on cross-functional escalation and notification decisioning; log gaps as tracked remediation.
• Review contracts and due diligence coverage for critical third parties; open remediation items for missing security schedules, assurance, or contingency plans.

By 90 days (Stabilize: make it exam-ready)

• Create the Member State “exam-ready package” folders/workspaces and populate them.
• Implement a recurring governance cadence: obligation register review, incident readiness metrics, and third-party dependency changes.
• Add internal audit or second-line testing steps focused on incident decision logs and third-party remediation closure.

Frequently Asked Questions

Article 7 is a Member State obligation. Why should my company track it?

Because the national strategy drives national policy and regulatory measures that become your local supervisory expectations. You operationalize that by tracking national transposition deltas and proving your controls and evidence match them. (Directive (EU) 2022/2555, Article 7)

What’s the single most useful artifact to create first?

An obligation register that ties each Member State’s requirements to your internal controls, owners, and evidence locations. It prevents scope drift and makes supervision requests easier to satisfy. (Directive (EU) 2022/2555)

We have one global incident response plan. Is that enough?

It can be, if you add jurisdiction-specific notification decisioning: who decides, how you document rationale, and where evidence is retained. Regulators typically test execution traceability, not the elegance of the plan. (Directive (EU) 2022/2555)

How do we define “critical third party” for NIS 2 purposes?

Define it in terms of service criticality, concentration risk, and the third party’s ability to materially affect availability, integrity, or confidentiality for in-scope services. Then require that critical third parties have enhanced due diligence, ongoing monitoring, and contingency planning.

What should we do if different Member States interpret expectations differently?

Treat “most stringent applicable requirement” as your default baseline where feasible, and record deviations with a documented rationale and compensating controls. Keep the reasoning in the obligation register so it’s explainable under exam pressure.

Where does Daydream fit without adding process overhead?

Use Daydream as the system of record for your obligation register, control ownership, and third-party dependency tracking, so evidence pointers, remediation tasks, and renewals stay connected to the same requirement mapping. (Directive (EU) 2022/2555)