Home Backup systems as a key element of ICT risk management under the NIS2 Directive

Backup systems as a key element of ICT risk management under the NIS2 Directive

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ICT Risk

ICT risk, or Information and Communications Technology risk, includes all threats related to the operation of information and communication systems that may affect the confidentiality, integrity, and availability of data, as well as the business continuity of an organization.

The sources of these risks include, among others:

  • cyberattacks, especially ransomware, phishing, and deliberate acts of sabotage,
  • human errors, lack of security awareness, and improperly designed or unused procedures,
  • infrastructure failures, software failures, or loss of access to strategic IT resources,
  • dependencies on external providers, including cloud services and IT outsourcing.

NIS2 requires organizations to identify, analyze, and reduce these risks, rather than merely respond to their consequences. In this context, backup should be seen as an element of ICT risk management architecture. Its role is to limit the impact of incidents on system availability and ensure the ability to restore key services within a defined, acceptable time frame and with an acceptable level of data loss.

Why NIS2 changes the way backup systems are perceived

In the previous regulatory approach, backup copies were primarily treated as an element of IT best practices, often separated from the formal risk management process. The NIS2 Directive changes this perspective by directly linking the backup system with the obligation to ensure business continuity, the ability to restore services after an incident, and the resilience of information systems.

In this context, backup functions as one of the fundamental technical measures for limiting the impact of incidents, especially in the areas of system availability and continuity of critical processes.

The NIS2 Directive requires organizations to demonstrate that, in the event of a serious cyber incident, infrastructure failure, or compromise of the production environment, they have mechanisms in place that enable the restoration of critical services within an acceptable time and scope.

A backup system is therefore assessed not only in terms of its existence, but also in terms of its effectiveness — including resilience to ransomware attacks, the ability to restore data, the testability of procedures, and consistency with risk analysis and business continuity plans.

An effective backup system:

  • reduces service downtime to a level acceptable from the perspective of the organization’s operations,
  • minimizes data loss to a level resulting from risk analysis and the criticality of processes,
  • enables the continuity of critical processes in the event of ICT incidents,
  • reduces the impact of an incident on customers, business partners, and the market,
  • ensures the ability to restore systems effectively and repeatedly, confirmed by regular testing,
  • provides a key data security response, especially to ransomware attacks.

These are areas in which the NIS2 Directive places responsibility on management for ICT risk management, together with the possibility of sanctions in the event of insufficient technical and organizational measures.

NIS2 requirements and the real quality of a backup system

One of the most common mistakes made by organizations covered by NIS2 is equating the mere possession of backup copies with operational resilience. From the perspective of the Directive, the fact that backup exists is not enough. What matters is whether it serves as an effective and adequate ICT risk management measure.

Its quality, resilience, and alignment with the organization’s real needs are therefore subject to assessment.

A backup architecture should include elements such as logical and physical separation of backup copies from the production environment, resistance to data modification or encryption, and access control for backup systems. A backup that can be compromised together with the production system does not fulfill its role as a mechanism for limiting the consequences of risk.

Cyclical testing is equally important. NIS2 indirectly requires organizations to be able to demonstrate that recovery procedures actually work. This is why regular recovery tests are so important — they verify both the effectiveness of backup copies and the organization’s readiness to respond to incidents.

Backup should be an integral part of IT infrastructure as a tool for protecting data and maintaining business continuity in the event of, for example, a ransomware attack or another failure resulting in the loss of production data.

Management responsibility for the backup system

The NIS2 Directive clearly indicates management’s responsibility for implementing and supervising ICT risk management measures. The management board should therefore know which processes are protected, what the real recovery capabilities are, and which risks remain unaddressed.

The lack of an effective backup system, or a backup system that is not adapted to the scale and nature of the organization’s operations, may be considered an insufficient implementation of the technical and organizational measures required under NIS2.

As a result, it increases operational risk, regulatory risk, and the responsibility of senior management.

Support in Implementing NIS2-Compliant Backup Systems

We support organizations in designing and implementing backup systems as part of ICT risk management, business continuity, and operational resilience in line with the requirements of the NIS2 Directive.

As an integrator of backup and storage solutions, we help select an architecture adapted to the criticality of processes, the level of risk, and regulatory obligations, and then support its practical integration with existing IT environments.

Our scope of support includes, among others:

  • analysis of the current backup architecture in terms of NIS2 requirements and business continuity,
  • design and implementation of backup systems, including solutions based on LTO tape libraries,
  • integration of backup systems with tools for backup management and post-incident recovery,
  • configuration of mechanisms that increase backup resilience, such as data immutability, environment separation, and encryption,
  • support in recovery testing and verification of the real ability to restore critical services.

If you want to verify whether your current backup system is an effective ICT risk management measure and meets NIS2 requirements in practice, contact us. We will help assess its maturity and design a solution tailored to your organization’s specifics, risk level, and regulatory obligations.