Article 14: Cooperation Group

Article 14 creates an EU-level “Cooperation Group” for Member States, so your job as a regulated entity is indirect: make your NIS 2 compliance program exam-ready across jurisdictions so your national authority can coordinate and compare your posture consistently. Operationalize this by maintaining a jurisdiction-mapped obligation register, repeatable incident reporting workflows, and third-party dependency evidence. (Directive (EU) 2022/2555, Article 14)

Key takeaways:

• Treat Article 14 as a “consistency requirement”: your controls and evidence must withstand cross-border supervisory coordination. (Directive (EU) 2022/2555, Article 14)
• Build one source of truth for NIS 2 obligations by Member State, with owners and milestones, to avoid scope drift and conflicting local interpretations. (Directive (EU) 2022/2555)
• Make incident handling and third-party dependency documentation audit-ready, because those are the artifacts authorities can request and exchange context about. (Directive (EU) 2022/2555)

Article 14: cooperation group requirement is short, but it changes how you should run a NIS 2 program. The Directive establishes a Cooperation Group to “support and facilitate strategic cooperation and the exchange of information among Member States” and to “strengthen trust and confidence.” (Directive (EU) 2022/2555, Article 14) That cooperation happens at the authority level, not directly between your company and the EU body. Still, it affects you because your regulator can align supervision expectations with other Member States, ask for comparable evidence, and challenge inconsistencies in how you apply NIS 2 across countries.

For a CCO or GRC lead, the operational implication is straightforward: you need a harmonized, jurisdiction-aware compliance operating model that produces consistent artifacts on demand. If your incident reporting is “mostly defined” but not proven, or if third-party dependency management exists but lacks traceable evidence, you create friction during supervisory interaction and any follow-up coordination with peer authorities.

This page gives requirement-level implementation guidance: who is in scope, what to build, what to retain, what exam teams ask, and how to execute quickly without overengineering.

Regulatory text

Text (excerpt): “In order to support and facilitate strategic cooperation and the exchange of information among Member States, as well as to strengthen trust and confidence, a Cooperation Group is established.” (Directive (EU) 2022/2555, Article 14)

What this means for an operator

• The legal obligation in Article 14 is on Member States/EU governance, but it creates a supervisory environment where your national competent authority can coordinate with others. (Directive (EU) 2022/2555, Article 14)
• Your operational requirement: avoid “local one-offs” that cannot be explained consistently across jurisdictions. Expect regulators to benchmark what “good” looks like and to request comparable artifacts. (Directive (EU) 2022/2555)

Plain-English interpretation

Article 14: cooperation group requirement exists to make Member State supervision more coordinated and more consistent. (Directive (EU) 2022/2555, Article 14) Practically, that means:

• If you operate in more than one EU Member State, you need a single control story with local applicability notes, not separate ad hoc programs by country. (Directive (EU) 2022/2555)
• You should be ready for information requests that assume standardization, especially around incident handling and supply chain dependencies, because those are common coordination topics. (Directive (EU) 2022/2555)

Who it applies to (entity and operational context)

You should treat Article 14 as applicable if:

• You are a NIS 2 regulated entity (essential or important) operating in one or multiple Member States, and you interact with a national competent authority. (Directive (EU) 2022/2555)
• You have cross-border operations, shared infrastructure, or centralized security operations that support EU-based services, because those operating models often produce “one process, many jurisdictions” compliance questions. (Directive (EU) 2022/2555)

Operational contexts where Article 14 pressure shows up:

• Multi-country incident response: one incident, multiple notification obligations, and multiple regulators comparing timelines and content. (Directive (EU) 2022/2555)
• Shared third parties: the same cloud, MSSP, or software provider supports multiple EU entities; authorities tend to converge expectations about due diligence and oversight. (Directive (EU) 2022/2555)
• Group-level governance: a parent company standard applies everywhere, but local transposition differs; you need documented local deltas. (Directive (EU) 2022/2555)

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

Step 1: Build a “jurisdiction-mapped” NIS 2 obligation register

Goal: one place to answer “what applies where, who owns it, what evidence proves it.” This is the fastest way to reduce cross-border inconsistency risk. (Directive (EU) 2022/2555)

Minimum fields to include:

• Member State(s) in scope for each business line/service
• Essential vs important entity classification (as determined under national transposition)
• Requirement theme (governance, incident reporting, supply chain, etc.)
• Control owner (role name, not a person)
• Current state, target state, and a dated milestone plan
• Evidence pointers (links to policies, tickets, reports, test results)

Daydream fit (earned mention): Many teams build this in spreadsheets and lose version control. Daydream can serve as the system of record for NIS 2 obligations, owners, and evidence pointers so you can answer regulator questions consistently without rework. (Directive (EU) 2022/2555)

Step 2: Standardize incident triage, escalation, and reporting “as executed”

Article 14’s cooperation intent makes inconsistency visible. Your incident workflow must be both defined and provable. (Directive (EU) 2022/2555, Article 14)

Do this operationally:

1. Define severity tiers and decision rights (who declares a reportable incident).
2. Build an escalation matrix that includes Legal/Compliance, Security, IT Ops, and communications.
3. Create a notification readiness pack: pre-approved templates, required data fields, and a checklist for regulator follow-up.
4. Run a tabletop and retain evidence (agenda, scenario, decisions, action items).
5. Capture an audit trail in your ticketing/IR platform: timestamps, approvals, and exported summaries.

Step 3: Integrate critical third-party dependencies into your NIS 2 control set

Cooperation across Member States tends to highlight shared supply chain exposures. You need a defensible third-party dependency view that can be explained consistently. (Directive (EU) 2022/2555)

Execution steps:

1. Identify critical third parties by service criticality and data/system access.
2. Map each critical third party to the services and Member States it supports.
3. Set minimum due diligence and ongoing assurance expectations (security requirements, incident notification clauses, audit rights where feasible).
4. Track remediation to closure with an owner and due date.
5. Maintain an exception process that records rationale and compensating controls.

Step 4: Prepare a regulator interaction playbook

Even though Article 14 is authority-facing, you need a repeatable way to respond to information requests. (Directive (EU) 2022/2555, Article 14)

Include:

• Who receives regulator requests and who coordinates responses
• Target response workflow (intake, triage, drafting, review, submission)
• Translation/localization handling if operating in multiple jurisdictions
• Evidence packaging standards (naming conventions, versioning, redaction rules)

Required evidence and artifacts to retain

Keep artifacts that prove consistency and execution. Aim for “exportable on demand.”

Governance and scope

• NIS 2 applicability memo per Member State (or equivalent internal assessment) (Directive (EU) 2022/2555)
• Obligation register with owners, milestones, and evidence mapping (Directive (EU) 2022/2555)

Incident management

• Incident triage SOP and escalation matrix (Directive (EU) 2022/2555)
• Tabletop exercise records and post-exercise action tracking (Directive (EU) 2022/2555)
• Example incident records showing timestamps, decisions, and communications (Directive (EU) 2022/2555)

Third-party dependency management

• Inventory of critical third parties and services supported (Directive (EU) 2022/2555)
• Due diligence results, contract security addenda, and remediation tracking (Directive (EU) 2022/2555)

Common exam/audit questions and hangups

Expect questions that test cross-jurisdiction consistency:

• “Which Member States consider this entity in scope, and under what basis?” (Directive (EU) 2022/2555)
• “Show how your group policy is adapted to local requirements.” (Directive (EU) 2022/2555)
• “Walk us through your last significant incident: who decided, when, what was reported, and where is the evidence?” (Directive (EU) 2022/2555)
• “Which third parties are critical to service delivery, and how do you oversee them?” (Directive (EU) 2022/2555)

Hangups that slow teams down:

• Evidence scattered across tools with no index
• Local subsidiaries following different incident criteria with no documented reason
• Third-party inventories that exist for procurement but not for operational resilience/security

Frequent implementation mistakes and how to avoid them

1. Mistake: Treating Article 14 as “not applicable to us.”
   Fix: Classify it as an indirect operational driver and document the program decision: “We support supervisory cooperation by maintaining consistent, jurisdiction-mapped evidence.” (Directive (EU) 2022/2555, Article 14)

2. Mistake: One global policy, no local applicability notes.
   Fix: Add a “local delta” section per Member State in your obligation register and record the control owner for each delta. (Directive (EU) 2022/2555)

3. Mistake: Incident process exists only in narrative form.
   Fix: Prove it with artifacts: ticket exports, approval trails, and a tested notification pack. (Directive (EU) 2022/2555)

4. Mistake: Third-party risk is a questionnaire library, not a dependency model.
   Fix: Start from operational dependency mapping (service-to-third-party-to-country) and then attach diligence and contract controls. (Directive (EU) 2022/2555)

Enforcement context and risk implications

No public enforcement cases were provided for Article 14 in the supplied source catalog, so this page does not cite case outcomes. (Directive (EU) 2022/2555)

Risk to manage anyway:

• Supervisory friction risk: inconsistent answers across Member States can trigger deeper inquiries, more frequent evidence requests, and less trust in your control maturity. (Directive (EU) 2022/2555, Article 14)
• Response risk: if cooperation drives faster exchange of incident context, your timelines and records need to be defensible across jurisdictions. (Directive (EU) 2022/2555)

Practical 30/60/90-day execution plan

First 30 days (stabilize scope and ownership)

• Assign a single accountable owner for the NIS 2 obligation register and define RACI across Security, Legal, Privacy, Procurement, and IT. (Directive (EU) 2022/2555)
• Stand up the obligation register with Member State applicability notes and evidence pointers, even if initial entries are incomplete. (Directive (EU) 2022/2555)
• Document the regulator interaction workflow: intake mailbox, triage meeting, and approval path. (Directive (EU) 2022/2555)

Days 31–60 (make execution provable)

• Convert incident response documentation into “as executed” workflows inside your ticketing/IR tooling, with required fields and approvals. (Directive (EU) 2022/2555)
• Build the notification readiness pack and run at least one tabletop exercise; log actions to closure. (Directive (EU) 2022/2555)
• Identify critical third parties and map them to key services and Member States. (Directive (EU) 2022/2555)

Days 61–90 (harden evidence, reduce variance)

• Perform an internal audit-style evidence pull: pick one Member State and one cross-border service, then assemble the complete evidence package from your register. Fix gaps. (Directive (EU) 2022/2555)
• Standardize third-party remediation tracking and exception handling, and ensure it ties back to the service map. (Directive (EU) 2022/2555)
• Operationalize metrics that are safe to produce without statistics: open items by owner, overdue evidence requests, and tabletop actions pending closure. (Directive (EU) 2022/2555)

Frequently Asked Questions

Does Article 14 require my company to join the Cooperation Group or attend meetings?

Article 14 establishes the Cooperation Group for Member States, not for regulated entities. Your practical task is to be ready for coordinated supervision by maintaining consistent, jurisdiction-aware evidence. (Directive (EU) 2022/2555, Article 14)

What should I show an auditor to prove we’ve addressed the article 14: cooperation group requirement?

Show your jurisdiction-mapped NIS 2 obligation register, your regulator interaction playbook, and “as executed” incident and third-party artifacts that can be produced consistently across Member States. (Directive (EU) 2022/2555)

We operate in one Member State only. Do we still care?

Yes, because your competent authority may align expectations through the Cooperation Group, which can shape what they ask for and how they benchmark your controls. Keep your evidence clean and standardized anyway. (Directive (EU) 2022/2555, Article 14)

How do we prevent country teams from creating conflicting NIS 2 interpretations?

Require each local team to document local deltas in the obligation register, with a control owner and linked evidence. Central GRC should approve deltas and track them like remediation items. (Directive (EU) 2022/2555)

What’s the fastest way to get “exam-ready” for cross-border incident questions?

Pick one recent incident and reconstruct a defensible audit trail: detection, severity decision, escalation, communications, and any notifications. Use that as the template for future incidents and tabletops. (Directive (EU) 2022/2555)

Where does third-party risk management fit under Article 14?

Article 14 itself is about Member State cooperation, but coordinated supervision often focuses on shared dependency risks. Maintain a critical third-party dependency map tied to services and countries, with diligence and remediation evidence attached. (Directive (EU) 2022/2555)