Article 25: Standardisation

Article 25: standardisation requirement means you should align your NIS 2 security measures with recognized European and international cybersecurity standards where practical, while staying technology-neutral and ready to explain your choices. Operationalize it by mapping Article 21 controls to a standards baseline, documenting deviations, and using standards to drive consistent implementation across jurisdictions. (Directive (EU) 2022/2555, Article 25)

Key takeaways:

• Pick a standards baseline (or a small set) and map it to your Article 21 measures, then run execution through that mapping.
• Document “why this standard, why this scope, why these deviations” so supervision doesn’t turn into an opinions debate.
• Keep evidence exam-ready: mappings, control operation proof, and third-party alignment for critical dependencies.

Article 25 is short, but it changes how you should defend your NIS 2 program in supervision. It does not mandate a specific framework and it does not let a regulator pick your tooling. Instead, it pushes convergence: consistent implementation of the cybersecurity measures in Article 21 across Member States by encouraging the use of European and international standards and technical specifications relevant to network and information system security. (Directive (EU) 2022/2555, Article 25)

For a Compliance Officer, CCO, or GRC lead, the practical impact is simple: you need a standards position that is deliberate, documented, and operational. If your controls are “homegrown,” you can still be compliant, but you should expect more questions about completeness, consistency, and how you measure maturity. A recognized standard turns those questions into a structured mapping exercise.

This page gives requirement-level guidance to implement the article 25: standardisation requirement quickly: who it applies to, what to do step-by-step, what artifacts to retain, common audit hangups, and a practical execution plan that a serious operator can run.

Regulatory text

Text (excerpt): Member States shall, without imposing or discriminating in favour of a particular type of technology, encourage the use of European and international standards and technical specifications relevant to the security of network and information systems, to promote convergent implementation of Article 21(1) and (2). (Directive (EU) 2022/2555, Article 25)

Operator interpretation (what you must be ready to show):

• You selected an appropriate set of cybersecurity standards/technical specifications to guide your Article 21 security measures.
• Your implementation is technology-neutral: you can justify controls by outcomes and risk, not by a mandated product stack.
• You can demonstrate consistency and repeatability across business units and jurisdictions using a common control language (the standard), even if local execution differs.

This is an “expectation-setting” requirement more than a checkbox. Your risk is not failing to name a standard. Your risk is having an inconsistent, hard-to-defend control program that cannot be compared, assessed, or supervised cleanly.

Plain-English meaning of the article 25: standardisation requirement

Article 25 pushes you to “speak standards” when you design and run NIS 2 controls. That usually means:

• You maintain a defined security control baseline (for example, ISO 27001/27002 or another widely used European/international standard).
• You map your actual safeguards (policies, technical controls, and operational processes) to that baseline.
• You use the mapping to drive implementation, testing, and corrective actions, instead of relying on informal practices or one-off decisions.
• You keep the program tool-agnostic. If you use specific tools, you justify them as one way to meet the control outcomes.

Who it applies to (entity and operational context)

Direct legal addressee: Member States (they “encourage” standard use). (Directive (EU) 2022/2555, Article 25)

Practical operational impact: If you are an entity in scope of NIS 2 and implementing Article 21 measures, you should assume national authorities will expect standards alignment as a normal way to evidence control completeness and governance maturity, because that is the explicit policy direction in Article 25. (Directive (EU) 2022/2555, Article 25)

Where it shows up in your operations:

• Control framework decisions: choosing and scoping your cybersecurity framework(s).
• Multi-country implementation: keeping one control baseline while meeting local transposition nuances.
• Third-party risk: requiring critical third parties to meet equivalent standard-based expectations (for example, aligning contract requirements and assurance to your baseline).
• Audit and supervision readiness: answering “how do you know your controls are complete?” with a mapping, not opinions.

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

Step 1: Set your standards “position” (one page)

Create a short standards position statement that answers:

• What standard(s)/technical specifications you use as your baseline for NIS 2 Article 21 measures.
• What scope is covered (entities, systems, services).
• How you handle exceptions and compensating controls.
• How you keep technology neutrality (controls specify outcomes; tooling is implementation detail). (Directive (EU) 2022/2555, Article 25)

Tip: Keep it decision-grade. Name an executive owner and a governance forum that approves changes.

Step 2: Build an Article 21 → standards crosswalk

Article 25 exists to support convergent implementation of Article 21 measures, so your core artifact is a crosswalk that links:

• Each relevant Article 21 measure area (as implemented in your program), to
• Specific control families/control statements in your chosen standard(s), to
• Your internal controls, policies, and operational procedures. (Directive (EU) 2022/2555, Article 25)

Deliverable format that works in exams: a table with columns for requirement, standard control reference, internal control ID/title, control owner, evidence pointer, status, notes on deviations.

Step 3: Convert the crosswalk into an “obligation register” with ownership

You need accountable execution, not just a mapping. Maintain a register that includes:

• Jurisdictional applicability notes (because supervision is national),
• Control owners,
• Implementation milestones,
• Known gaps and remediation actions.

This is also the fastest way to keep consistency as business units interpret NIS 2 differently.

Step 4: Operationalize through three exam-sensitive workflows

Supervisors test reality. Focus on workflows that create defensible evidence:

1. Incident triage, escalation, and reporting workflow

• Define severity criteria, escalation paths, and reporting triggers.
• Record time-stamped decisions and communications.
• Keep evidence packages per incident (who decided what, when, and on what basis).

2. Risk assessment workflow that includes third parties

• Identify critical dependencies and map them to services/systems.
• Assess third-party control alignment to your standards baseline (contractually and through assurance).
• Track remediation when gaps are found.

3. Control testing workflow

• Define how you test controls derived from the standard (self-assessments, internal audit, technical validation).
• Track findings to closure with clear owners and dates.

These workflows translate “encouraged standards use” into consistent execution and proof. (Directive (EU) 2022/2555, Article 25)

Step 5: Document and govern deviations

No organization implements a standard perfectly. Your goal is to make deviations non-controversial:

• Record each deviation from the baseline.
• State rationale (risk-based, compensating control, scope limitation).
• Identify approver and review cadence.
• Link to evidence of compensating control operation. (Directive (EU) 2022/2555, Article 25)

Step 6: Make it repeatable across jurisdictions

Because Article 25 is about convergence, design for repeatability:

• One enterprise baseline.
• Local annexes for national transposition specifics.
• A single evidence model (same artifact types, consistent naming, consistent retention).

Where Daydream fits naturally: Daydream can hold the obligation register, the Article 21-to-standards crosswalk, and the evidence pointers in one place, so you can answer supervisory questions from a single source of truth without rebuilding spreadsheets each cycle.

Required evidence and artifacts to retain

Retain artifacts that prove both design alignment (standards choice and mapping) and operational effectiveness (controls actually run):

Standards alignment (design)

• Standards position statement (approved and versioned).
• Article 21 → standards crosswalk, including scope and deviations. (Directive (EU) 2022/2555, Article 25)
• Exception register with compensating controls and approvals.

Operational evidence (run-state)

• Incident management runbooks; incident records with timestamps, decisions, and communications.
• Risk assessments that explicitly include critical third-party dependencies and outcomes.
• Third-party due diligence/assurance records tied to your baseline controls.
• Control testing plan, test results, findings log, remediation tickets, closure evidence.
• Governance minutes showing periodic review of the baseline and deviations.

Common exam/audit questions and hangups

Expect questions like:

• “Which European/international standards do you follow, and why those?” (Directive (EU) 2022/2555, Article 25)
• “Show me how your Article 21 measures map to that standard.”
• “Where do you deviate from the standard, and who approved the exception?”
• “How do you ensure technology neutrality when selecting tools?”
• “How do you ensure third parties align to your baseline for critical services?”
• “Prove the incident workflow works end-to-end: triage, escalation, reporting triggers, and evidence retention.”

Hangup: Teams can describe controls but cannot produce a clean evidence trail. Fix this by building “evidence pointers” into the crosswalk (link to ticket, log, report, minutes, or attestation).

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails in supervision	How to avoid it
Picking a standard but not mapping it to Article 21 execution	Looks like shelfware	Build and maintain the crosswalk and tie it to owners and evidence (Directive (EU) 2022/2555, Article 25)
Over-focusing on a single tool as “compliance”	Conflicts with technology-neutral expectation	Define controls as outcomes; document tooling as one implementation option (Directive (EU) 2022/2555, Article 25)
Exceptions handled informally in email	No governance trail	Maintain a formal exception register with approvals and compensating controls
Third-party coverage stops at procurement	Critical dependencies remain unmanaged	Include third parties in risk assessment, assurance, and remediation tracking
Inconsistent local implementations	Breaks convergence	Use one enterprise baseline plus local annexes; standardize evidence artifacts

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so don’t anchor your plan to case law. Treat Article 25 as a supervision accelerant: a regulator can assess your program faster if it is standards-based, and they can challenge you more easily if you have no baseline and no documented rationale. (Directive (EU) 2022/2555, Article 25)

Practical execution plan (30/60/90)

A dated plan would be a numeric claim. Use these phases instead.

Immediate (stabilize decisions)

• Appoint an owner for standards selection and maintenance.
• Publish a one-page standards position statement with scope.
• Inventory existing frameworks already in use (security, privacy, IT service management) and decide which one is the primary NIS 2 baseline.

Near-term (build the exam spine)

• Build the Article 21 → standards crosswalk and add owners, evidence pointers, and deviations.
• Stand up the obligation register with jurisdiction notes and milestone tracking.
• Normalize incident and third-party workflows so they create consistent evidence packages.

Ongoing (operate and prove)

• Run periodic control testing against the baseline and track remediation to closure.
• Review deviations and update standards mapping when architecture, services, or national transposition changes.
• Use internal audit or a structured second-line review to confirm evidence quality and traceability.

Frequently Asked Questions

Does Article 25 force us to adopt a specific standard like ISO 27001?

No. Article 25 says Member States must encourage the use of European and international standards without imposing or discriminating in favor of a particular technology. Your job is to pick a defensible baseline and document why. (Directive (EU) 2022/2555, Article 25)

We already have a homegrown control framework. Is that acceptable?

It can be, but you should map it to a recognized European/international standard to show coverage and comparability. Keep a deviation log for gaps and compensating controls so your rationale is reviewable. (Directive (EU) 2022/2555, Article 25)

What does “technology-neutral” mean for audits?

It means your control requirements should describe security outcomes (for example, access control, logging, incident handling) rather than mandating a specific product. If you standardize on a tool, document why it meets the outcome and what alternatives could also satisfy the control. (Directive (EU) 2022/2555, Article 25)

How do we apply this to third parties?

Flow your baseline control expectations into third-party security requirements, due diligence, and assurance for critical dependencies. Then retain evidence that the third party meets the requirement or that you have compensating controls and remediation tracking.

What evidence will a regulator actually ask for under Article 25?

Expect requests for your standards selection rationale, your Article 21-to-standards crosswalk, exception governance, and proof that mapped controls operate (incident records, risk assessments including third parties, testing results). (Directive (EU) 2022/2555, Article 25)

We operate in multiple EU countries. Do we need different standards per country?

Usually you want one enterprise baseline to support consistent implementation, with local annexes that reflect national transposition and supervisory expectations. The key is consistency of control intent and evidence, even if local processes differ.