How to Create a Realistic Plan for NIS2 Implementation Without an In-House Security Team
The European NIS2 Directive introduces new cybersecurity obligations that will affect thousands of Czech companies. If your organization falls into the category of “regulated entities,” you’ll be required to adopt technical and organizational measures, maintain a supplier registry, provide employee training, and be prepared for audits—all within a relatively short timeframe.
The good news? Achieving NIS2 compliance doesn’t necessarily mean building a full internal security team. The key is to have a well-thought-out plan, make smart use of available tools, and break the implementation into manageable steps.
Step 1: Self-Identification – Does NIS2 Apply to You?
The first step is to confirm whether the new rules actually apply to your business. NIS2 targets companies in critical sectors (such as IT, healthcare, transport, or digital infrastructure) with more than 50 employees or an annual turnover above €10 million. The exact categorization and scope of obligations are defined in the Czech Cybersecurity Act (ZoKB).
If you’re unsure, you can consult an expert or use online assessment tools that provide a quick evaluation after answering a few basic questions about your company. Try one of them here.
Step 2: Run a GAP Analysis to See Where You Stand
A GAP analysis is the foundation of any NIS2 implementation. It compares your current measures with NIS2 requirements and highlights gaps—areas where you need to update documentation, processes, or technical controls. We wrote about GAP analyses in one of the previous articles.
While such assessments used to take weeks or even months of consultant work, today AI-powered tools can deliver results in minutes. The outcome is a clear list of missing measures, often with concrete recommendations on how to fix them.
Step 3: Build a Realistic Implementation Plan
Based on your GAP analysis and risk mapping, create a phased plan that prioritizes activities according to urgency and available resources. A practical timeline might look like this:
0–3 months: Self-assessment, GAP analysis, define roles and responsibilities, draft policies
3–6 months: Employee training, third-party risk management, documentation, and incident scenarios
6–12 months: Implement technical measures, run tests, conduct internal audits, set up continuous monitoring
Having such a plan also helps demonstrate your compliance efforts if audited by NÚKIB.
Step 4: Map Risks and Third-Party Dependencies
NIS2 doesn’t just address internal processes—it also emphasizes risk management across your supply chain. Even smaller companies need to know who provides their critical services, the risks involved, and the potential impact of disruptions.
Key tasks include:
Creating a supplier and third-party registry
Assessing risks and dependencies
Performing a basic Business Impact Analysis (BIA)
Updating contracts to reflect new requirements
Tools like Auditmaster.ai make it easier to manage all this information in one place, simplifying audit readiness and ongoing compliance.
Step 5: Don’t Overlook Documentation and Responsibility
One of NIS2’s core requirements is clearly defined accountability for cybersecurity. Prepare key documents such as security policies, training plans, access control policies, and incident response procedures.
Whirr Crew can support you across this area—through consulting, drafting tailored documents, or even outsourcing key roles like CISO or security auditor. We also provide ready-to-use templates for security documentation.
Step 6: Set Up Continuous Monitoring and Compliance
Implementation doesn’t stop once the measures are in place. You’ll need to:
Regularly review compliance status
Keep records of employee training and audits
Be ready to report and respond to incidents or cyberattacks
Again, Auditmaster.ai helps by managing documentation, tracking obligations, and maintaining evidence for audits.
NIS2 Compliance Without an Internal Security Team Is Possible
The key to successful NIS2 implementation is a solid plan, smart use of tools, and effective project leadership. You don’t need a large in-house security team—as long as you have access to the right people and technologies.
At Whirr Crew, we specialize in efficient, sustainable NIS2 compliance. From initial assessments and policy development to long-term support, we help you navigate the entire process with minimal cost and maximum confidence.
Curious how this could work in your organization?