ISO 27001 and NIS 2: Key differences explained

ISO 27001 is a globally recognized standard for building robust information security management systems (ISMS). The standard is closely aligned with NIS 2—a mandatory EU directive designed to fortify the cybersecurity posture of critical infrastructure among Member States.

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These two frameworks form a unique symbiotic relationship due to the potential overlap in the requirements and controls. To clarify this relationship, this guide covers:

• Quick facts about NIS 2 and ISO 27001
• The way these two frameworks are connected
• The most notable differences between ISO 27001 and NIS 2 

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NIS 2: An overview

NIS 2 is a comprehensive cybersecurity directive introduced by the European Union Agency for Cybersecurity (ENISA). It’s an extension of the original NIS directive introduced in 2016, which was revised in 2020 due to enforcement challenges and a narrow scope.

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To address these issues, NIS 2 encompasses more sectors than its predecessor and introduces other notable changes, including:

• Higher non-compliance penalties
• Clearer security requirements
• Enhanced governance and oversight

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NIS 2 affects 15 sectors, which are divided into two categories—essential and important. The following table outlines both:

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As the directive came into effect on October 17, 2024, efficient compliance is crucial. Among its various requirements, NIS 2 obligates organizations to review and update their:

• Risk management and business continuity practices
• Incident reporting processes
• Internal accountability chain

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ISO 27001: An overview

ISO 27001 is an international, certifiable security standard designed to help organizations build an effective ISMS that ensures comprehensive data security and privacy. Unlike NIS 2, the standard has been around for a long time—it was introduced in 2005 and has been adopted by organizations across sectors and geographic locations.

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Since its introduction, ISO 27001 has undergone numerous updates that account for the ever-changing threat landscape. As of this writing, the most recent update was in 2022, and the latest ISO 27001 version encompasses various cybersecurity measures and controls.

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As ISO 27001 is heavily focused on risk management, organizations that adopt it can effectively protect sensitive data and mitigate cybersecurity risks.

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The relationship between NIS 2 and ISO 27001

Despite their shared overarching goal, NIS 2 and ISO 27001 aren’t interchangeable. The two frameworks have a complementary relationship, and complying with the latter can considerably simplify NIS 2 compliance.

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While NIS 2 is mainly focused on what organizations should do to improve their security posture, it’s limited in guidance on how to do it. ISO 27001, with its specific and precise controls, fills this gap with prescriptive guidance that may contribute to practical NIS 2 compliance.

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ENISA acknowledges this correlation, which is why NIS 2 mentions the implementation of ISO 27001. Specifically, Preamble 79 suggests implementing cybersecurity risk management measures according to international standards, including the ISO 27000 series.

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4 key differences between ISO 27001 and NIS 2

Even though NIS 2 and ISO 27001 are complementary, they differ in four key aspects:

1. Legal context
2. Applicability
3. Underlying focus
4. Structure

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Below we’ll elaborate on these differences in more detail.

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1. Legal context

NIS 2 is a mandatory directive that emphasizes the accountability of C-level executives regarding security incidents. This means that in-scope organizations must comply to avoid legal issues and related operational disruptions.

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In case of an incident, top-level managers might be temporarily removed from their positions. This measure relates to essential entities and can be enforced in case of repeat NIS 2 violations. Other penalties include:

• Compliance orders
• Binding instructions
• Threat notification to a non-compliant entity’s customers
• Demands for a public statement highlighting the personal responsibility of natural and legal person(s)

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NIS 2 also imposes considerable fines for non-compliant entities, which depend on the organization’s classification:

• Essential entities: A maximum fine level of at least €10,000,000 or 2% of the global annual revenue, whichever is higher
• Important entities: A maximum fine level of at least €7,000,000 or 1.4% of the global annual revenue, whichever is higher

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By contrast, non-compliance with ISO 27001 won’t expose you to any administrative penalties or legal issues—the standard is voluntary, so you can choose to implement it to improve your organization’s security posture and credibility. Doing so brings additional advantages, most notably:

• Improved operational resilience: ISO 27001 offers holistic protection from security threats, improving your organization’s resilience to accidental or intentional incidents
• Easily demonstrable security posture: An ISO 27001 certificate is widely recognized among industries and serves as proof of your organization’s commitment to comprehensive cybersecurity
• Implementation of industry-standard security controls: ISO 27001 is continuously updated to encompass emerging security threats, so its implementation gives you access to industry-accepted controls

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2. Applicability

NIS 2 is primarily aimed at mid-sized and large organizations. The former are typically considered important entities, while large organizations are almost exclusively deemed essential. Still, some mid-sized organizations like DNS providers are classified as essential, regardless of their size.

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Note that start-ups and small organizations, typically out of NIS 2 scope, might still be impacted by it under specific conditions. You can go through the NIS 2 Article 2 for more information on the directive’s scope and the applicability criteria.

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As an EU directive, NIS 2 is geared towards organizations operating within the Member States. Organizations that meet the threshold criteria (such as size and turnover) and are classified as essential or important entities under NIS 2 are required to comply.

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Unlike NIS 2, ISO 27001 is agnostic to an organization’s size or location. This makes it applicable to any organization that wants to improve its security posture and get certified.

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3. Underlying focus

The main focus of NIS 2 is the protection of critical cybersecurity infrastructure through robust measures. Unlike its predecessor, this directive aims to harmonize the best cybersecurity practices among Member States to ensure simplified and more cohesive implementation.

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ISO 27001 has a more specific focus—developing and implementing an Information Security Management System that enables the confidentiality, integrity, and availability of an organization's data.

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While NIS 2 takes a macro approach, ISO 27001 is more focused on individual organizations and the specific controls they can put into place to manage their security posture more effectively.

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4. Structure

NIS 2 has 46 articles in total, but only two (Article 21 and Article 23) directly discuss the security measures and practices organizations should implement. Another relevant article is Article 20, which discusses governance and the liability of an entity’s management in case of non-compliance.

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Most of the remaining Articles are primarily aimed at Member States and how they can manage and oversee the directive’s implementation.

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In contrast, ISO 27001 maintains a complete focus on organizations and the prescribed security controls. The standard has 90+ controls split into four categories:

1. People
2. Physical
3. Technological
4. Organizational

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As such, it requires organizations to closely examine their security postures and make the changes necessary for ensuring protection against various security threats.

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Does ISO 27001 compliance make you NIS 2-compliant?

While NIS 2 and ISO 27001 have considerable overlaps, obtaining an ISO 27001 certificate doesn’t make your organization NIS 2-compliant by default. As of this writing, some Member States, like Belgium, have discussed accepting ISO 27001 certification as proof of NIS 2 compliance. Still, the extent to which this alignment will be implemented among other EU nations is unknown.

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Unless your specific jurisdiction instructs otherwise, NIS 2 and ISO 27001 compliance should be defined and addressed separately. You can choose whether to get a head start with ISO 27001 controls or pursue NIS 2 compliance directly.

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Separate treatment of NIS 2 and ISO 27001 combined with their control overlaps might expose your organization to the risk of duplicate workflows. You could unnecessarily repeat the review and implementation of specific controls you might have already addressed.

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Besides such inefficiencies, you might encounter several issues while pursuing NIS 2 and/or ISO 27001 compliance, such as:

• Extensive security reviews (especially if your organization doesn’t have a mature security program)
• Inefficient compliance tracking due to a lack of clear guidance and milestones
• Complex and laborious evidence collection and management

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To avoid these issues and achieve NIS 2 or ISO 27001 compliance more effortlessly, consider a compliance automation solution. The right platform can eliminate manual workflows to help you become compliant without extensive legwork.

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Enable effortless ISO 27001 and NIS 2 compliance with Vanta

Vanta is an AI-enabled compliance and trust management platform that automates up to 65% of NIS 2 compliance workflows. It offers a comprehensive NIS 2 compliance product with various useful resources and features, most notably:

• 50+ technical controls
• 100+ document templates
• 600+ relevant tests
• 10+ policies

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The platform also automatically maps and cross-references your existing controls with various standards and regulations, eliminating manual and duplicate workflows.

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If you wish to start with ISO 27001 compliance before pursuing NIS 2, you can use Vanta’s ISO 27001 product to do so without guesswork or laborious processes. Thanks to Vanta’s cohesive approach, you can also manage compliance with 35+ other frameworks within a unified hub.

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To see the NIS 2 product live and discover its many functionalities, schedule a custom demo for a hands-on overview.

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A note from Vanta: Vanta is not a law firm, and this article does not constitute or contain legal advice or create an attorney-client relationship. When determining your obligations and compliance with respect to relevant laws and regulations, you should consult a licensed attorney.