Rapid NIS2 Questionaire - Checkmarx

NIS2 ICT Risk Framework Integration

Question 1 of 14:

Have you integrated Application Security (AppSec) into your organization's overall risk management framework, including risk identification, assessment, mitigation, tolerance, and monitoring, as required by NIS2?

Guidance

Integrating AppSec into the organization’s overall risk management framework ensures that application-related threats are identified, assessed, and mitigated consistently across the software lifecycle.
It enables proactive decision-making, clear accountability, and traceable documentation of risks, controls, and remediation efforts.
A mature AppSec risk management process treats vulnerabilities and software supply chain issues as business risks, aligning technical actions with organizational resilience and compliance objectives.

NIS2 Article:
Article 21(2)(a): Explicitly establishes the foundation for a risk-based approach: AppSec objectives and controls should therefore reflect enterprise risk tolerance, contribute to overall ICT resilience, and be supported by regular review and improvement cycles.
Essential and Important Entities must ‘take appropriate and proportionate technical, operational and organizational measures to manage the risks posed to the security of network and information systems’. This includes integrating AppSec into the organization’s broader risk management lifecycle – from identifying vulnerabilities in applications to assessing their potential business impact and defining mitigating controls.

NIS2 Goals & Objectives

Question 2 of 14:

Have you defined clear goals and objectives for your Application Security (AppSec) program that are aligned with your organization's overall risk appetite and NIS2 requirements?

Guidance

Goals and objectives are often used interchangeably, but there are significant differences.
– A goal is a broad, overarching idea or vision of where you want to reach. Objectives are the steps or milestones that towards reaching the identified goals.
– Objectives are important because they keep the goal alive and are the smaller, time-bound steps to help getting towards the overall goal.
To be part of the corporate governance function of an organization, the goals, and objectives of the AppSec program should be tied to the risk appetite of the organization. For this purpose, the risk appetite of the organization’s executive leadership needs to be captured and aligned with the goals and objectives of the AppSec program. The organization’s leadership should vet and approve the set of goals.

NIS2 Articles:
Article 21(2)(a): Organizations must adopt ‘policies on risk analysis and information system security.’ This means your AppSec goals and objectives should be grounded in risk management, they must reflect your organization’s specific threats, critical assets, and tolerance for security risks.
Article 21(2)(f): Requires ‘policies and procedures to assess the effectiveness of cybersecurity risk-management measures.’ This reinforces the need for measurable objectives: without them, it’s impossible to evaluate whether your AppSec program effectively mitigates risk in line with NIS2 expectations.

NIS2 AppSec Governance Policy

Question 3 of 14:

Do you have an Application Security (AppSec) policy and related standards in place, that are communicated, applied, and regularly reviewed in line with NIS2 governance requirements?

Guidance

An AppSec policy defines the intent, principles, and responsibilities governing secure software development and maintenance. It sets expectations, defines standards, and ensures consistent implementation across the organization.

NIS2 Articles:
Article 21(2)(h): Requires organizations to establish ‘basic cyber hygiene practices and cybersecurity training.’ While this article focuses on awareness and hygiene, it implies the need for clear, documented governance and policy structures to sustain those practices across the organization.
Article 21(2)(f): Mandates ‘policies and procedures to assess the effectiveness of cybersecurity risk-management measures.’ Regularly reviewing and updating AppSec policies ensures they remain effective and aligned with evolving threats and compliance needs.

NIS2 Strategic KPIs

Question 4 of 14:

Do you have strategic Key Performance Indicators (KPIs) for your Application Security (AppSec) program that allow you to assess its effectiveness and alignment with NIS2 requirements?

Guidance

A Key Performance Indicator (KPI) is a measurable value that demonstrates how effectively your organization is achieving key objectives. In the AppSec context, strategic KPIs help assess how well your program mitigates software-related risks, supports compliance, and aligns with your organization’s goals.

NIS2 Article:
Article 21(2)(f): Requires organizations to implement ‘policies and procedures to assess the effectiveness of cybersecurity risk-management measures.’
This directly supports the definition and use of KPIs: they are the mechanism that allows you to measure, monitor, and demonstrate the effectiveness of your AppSec program over time.

NIS2 AppSec Training and Awareness

Question 5 of 14:

Have you defined and implemented an education and guidance strategy for your Application Security (AppSec) program in line with NIS2 training and awareness requirements?

Guidance

An AppSec education and guidance strategy ensures that every stakeholder – developers, testers, auditors, and managers – understands secure development practices, common vulnerabilities, and how to mitigate them. This builds a consistent security culture and reduces the risk of human error.

NIS2 Article:
Article 21(2)(g): Requires ‘policies and procedures regarding cybersecurity training and basic cyber hygiene practices.’
This means your AppSec program must include structured, role-based education and awareness initiatives that ensure all relevant personnel are trained to handle security responsibilities effectively.

NIS2 Third-Party AppSec Requirements

Question 6 of 14:

Do your contracts with third-party providers explicitly include AppSec and software supply chain security requirements, such as vulnerability management, secure development, and incident notification, as required by NIS2?

Guidance

Effective third-party security management ensures that vendors, service providers, and software suppliers comply with the organization’s AppSec and cybersecurity standards.
It includes defining and enforcing security requirements within procurement, contracts, and onboarding processes, covering aspects such as secure development practices, vulnerability management, and disclosure obligations.
A mature approach continuously monitors supplier compliance and integrates third-party risk into the broader AppSec and enterprise risk management framework.

NIS2 Article:
Article 21(2)(d): Entities must implement ‘supply chain security, including security-related aspects concerning the relationships between each entity and its direct suppliers or service providers.’
This means AppSec obligations should extend beyond internal teams to third-party developers, cloud providers, and service vendors that impact your application landscape.

NIS2 Incident Review & Lessons Learned

Question 7 of 14:

Do you participate in secure and structured information-sharing initiatives related to AppSec threats and incidents with relevant authorities and trusted industry peers, in line with NIS2?

Guidance

An effective information-sharing process ensures that AppSec-related threat intelligence, vulnerabilities, and incident details are communicated promptly within the organization and, where appropriate, with trusted external partners or industry groups.
This collaboration enhances situational awareness, accelerates response to emerging threats, and strengthens collective resilience across the software supply chain.
A mature approach defines clear channels, responsibilities, and criteria for secure information exchange, balancing transparency with confidentiality and regulatory obligations.

NIS2 Article:
Article 21(2)(e): Organizations must promote and maintain ‘policies and procedures regarding the use of cryptography and, where appropriate, encryption, and the use of cybersecurity-related information sharing.’
This article recognizes that timely information exchange enhances collective resilience, early detection, and mitigation of cybersecurity incidents.

Application Inventory with Risk Rating

Question 8 of 14:

Do you have an updated inventory of your applications, and do you perform a risk rating of those applications, as required by NIS2?

Guidance

An application inventory is the inventory of applications developed by the organization. This inventory should include the risk rating for each application. This inventory is essential to allocate the right priority and strategy for security measures and security testing strategy for each application.
The risk rating process is defined as the process to qualify and classify applications regarding their business risk and therefore the need for protection on the application layer. The result of the process is a categorization of the application in the application inventory.

NIS2 Articles:
Article 21(2)(a): Requires entities to maintain an updated inventory of their information systems or applications and to perform risk analysis, including risk rating of those applications, to ensure effective cybersecurity management: ‘implement and maintain appropriate and proportionate technical and organizational measures, including policies on risk analysis and information system security’.
Article 21(2)(f): Requires policies and procedures to regularly assess and verify the effectiveness of cybersecurity risk-management measures, which includes evaluating the risks associated with applications based on the inventory and risk ratings: ‘policies and procedures to assess the effectiveness of the cybersecurity risk-management measures’.

Security Testing Tools in use (Depth of coverage)

Question 9 of 14:

Do you use automated application security testing (AST) tools (e.g., SAST, DAST, SCA, IaC security) to identify and address vulnerabilities during the development and maintenance of software in line with NIS2 Article 21(2)(e)?

Guidance

Application Security Testing (AST) tools help organizations identify and mitigate vulnerabilities during software development and maintenance. These tools can include Static Application Security Testing (SAST) for analyzing source code, Dynamic Application Security Testing (DAST) for testing running applications, Software Composition Analysis (SCA) for managing open-source dependencies, and Infrastructure as Code (IaC) scanning for securing deployment configurations.
Mature organizations typically use a combination of complementary AST tools to achieve comprehensive coverage across their application landscape. By aggregating and correlating results from these tools, they gain a more complete view of application-level risks, enabling more effective vulnerability management and continuous improvement of security posture. This integrated approach also demonstrates alignment with regulatory expectations around secure development and maintenance practices.

NIS2 Article:
Article 21(2)(e): Requires entities to ensure the security of network and information systems acquisition, development, and maintenance, including the management and disclosure of vulnerabilities.
The explicit mention of ‘development and maintenance’ in this article establishes a direct link to Application Security (AppSec) practices, making AST a key mechanism for demonstrating compliance with this requirement.

Security Testing Tools in use (Pervasiveness)

Question 10 of 14:

For how many applications do you use automated security testing (AST) tools (e.g., SAST, DAST, SCA, IaC security) as part of secure development and maintenance in line with NIS2 Article 21(2)(e)?

Guidance

Automated Application Security Testing (AST) tools – such as Static Application Security Testing (SAST), Dynamic Application Security Testing (DAST), Software Composition Analysis (SCA), and Infrastructure as Code (IaC) scanning – help organizations identify and remediate vulnerabilities consistently throughout the software lifecycle. Applying these tools across a broad range of applications strengthens security assurance, minimizes risk exposure, and ensures that secure development and maintenance practices are systematically embedded in the organization’s processes.
This question assesses how comprehensively AST tools are deployed across the organization’s application portfolio. Typically, this includes applications that are developed, customized, or maintained internally, as these fall directly under the organization’s responsibility for secure development and maintenance practices. Broader AST coverage demonstrates a mature and proactive approach to vulnerability management and supports measurable compliance with regulatory expectations.

NIS2 Article:
Article 21(2)(e): Requires entities to ensure the security of network and information systems acquisition, development, and maintenance, including the management and disclosure of vulnerabilities.
The explicit reference to ‘development and maintenance’ establishes a direct connection to Application Security (AppSec), making the systematic use of AST tools an essential mechanism for demonstrating compliance with this provision.

SDLC Integration & Scanning Approach

Question 11 of 14:

Do you trigger application security scans automatically as part of your software development or DevOps lifecycle, in line with NIS2 Article 21(2)(e) requirements for secure development and maintenance?

Guidance

Integrating automated application security scans into the software development and DevOps lifecycle enables continuous detection and remediation of vulnerabilities. By embedding security testing directly into source control systems, build pipelines (CI/CD), and deployment processes, organizations ensure that security becomes an inherent and repeatable part of development rather than a one-off activity.
Mature organizations apply automated scanning consistently across their applications, monitor scan coverage, and regularly evaluate the effectiveness of these integrations. This proactive approach strengthens software assurance, reduces the window of exposure to vulnerabilities, and helps prevent security flaws from propagating into production environments.
Automated scanning not only supports secure development and maintenance practices but also contributes to broader cybersecurity resilience, enabling timely detection of vulnerabilities (Article 21(2)(d)) and reducing the likelihood of incidents arising from exploitable flaws (Article 21(2)(b)).

NIS2 Article:
Article 21(2)(b): Incident handling
Article 21(2)(d): Supply chain security, including security-related aspects concerning the relationships between each entity and its direct suppliers or service providers;
Article 21(2)(e): Requires entities to ensure the security of network and information systems acquisition, development, and maintenance, including the management and disclosure of vulnerabilities.
The explicit inclusion of ‘development and maintenance’ directly links this provision to Application Security (AppSec) practices, making automated security scanning within the DevOps lifecycle a practical and measurable means of demonstrating compliance.

Result Review & Remediation Process

Question 12 of 14:

Do you take action based on results from automated application security testing, in line with NIS2 Article 21(2)(e) requirements for secure development and maintenance?

Guidance

Taking action based on the results of automated Application Security Testing (AST) is critical to maintaining secure development and maintenance practices. It ensures that identified vulnerabilities are reviewed, prioritized, and remediated in a timely and structured manner, reducing the risk that weaknesses remain unresolved or are exploited in production environments.
Mature organizations define formal vulnerability remediation processes that include clear ownership, remediation timelines, and escalation paths. Increasingly, they use automation to streamline response – such as blocking insecure builds, using AI to for remediation guidance, automatically creating remediation tickets, or integrating results directly into issue tracking systems. These practices demonstrate operational maturity and strengthen the organization’s ability to continuously improve its security posture.

NIS2 Articles:
Article 21(2)(e): Requires entities to ensure the security of network and information systems acquisition, development, and maintenance, including the management and disclosure of vulnerabilities.
The explicit reference to ‘development and maintenance’ directly connects this provision to Application Security (AppSec) practices, making structured remediation of AST findings a key mechanism for demonstrating compliance and operational resilience under NIS2.
Articles 21(2)(b) and (d): Taking consistent, timely action on vulnerabilities also supports broader cybersecurity resilience. It contributes to Article 21(2)(d) by ensuring that vulnerabilities discovered through testing are effectively handled and disclosed, and to Article 21(2)(b) by reducing the likelihood that unremediated vulnerabilities lead to incidents.

Architecture, Deployment Model, and sizing

Question 13 of 14:

Have you defined and implemented the deployment model, architecture, and scale required for your application security testing infrastructure, in line with NIS2 Article 21(2)(e) requirements for secure development and maintenance?

Guidance

An effective Application Security Testing (AST) program depends on a well-defined and properly scaled testing infrastructure. This includes establishing a deployment model, architecture, and capacity that can support the organization’s testing requirements with sufficient reliability, scalability, and security. Deployment models may range from SaaS or public cloud to private cloud, on-premises, or hybrid configurations – selected based on regulatory, confidentiality, and data residency considerations.
A mature AST infrastructure design addresses availability, scalability, and data management requirements, including secure handling, retention, and segregation of testing results. Regular reviews of architecture and capacity ensure the infrastructure continues to meet evolving application security needs, supports efficient vulnerability detection, and aligns with organizational risk management objectives.
A robust AST infrastructure is not only a technical necessity but also a compliance enabler. By ensuring the tools and environments used for secure development and maintenance are properly governed, organizations can demonstrate adherence to NIS2’s expectations for operational resilience and system security.

NIS2 Article:
Article 21(2)(e): Requires entities to ensure the security of network and information systems acquisition, development, and maintenance, including the management and disclosure of vulnerabilities.
The explicit focus on ‘development and maintenance’ directly connects to the need for reliable and secure testing infrastructure. A well-architected and properly scaled AST environment is a foundational element for demonstrating compliance with this requirement and for maintaining continuous assurance of software security.
Article 21(2)(a) and (h): Beyond secure development and maintenance, such planning supports compliance with broader NIS2 obligations – Article 21(2)(a) (alignment with risk management and security policies) and Article 21(2)(h) (training and awareness for personnel involved in ICT security and development).

Planning in General

Question 14 of 14:

Do you have a roll-out plan, adoption plan, resource plan, and training plan in place for your Application Security (AppSec) program, in line with NIS2 Article 21(2)(e) requirements for secure development and maintenance?

Guidance

An effective Application Security Testing (AST) program depends on a well-defined and properly scaled testing infrastructure. This includes establishing a deployment model, architecture, and capacity that can support the organization’s testing requirements with sufficient reliability, scalability, and security. Deployment models may range from SaaS or public cloud to private cloud, on-premises, or hybrid configurations – selected based on regulatory, confidentiality, and data residency considerations.
A mature AST infrastructure design addresses availability, scalability, and data management requirements, including secure handling, retention, and segregation of testing results. Regular reviews of architecture and capacity ensure the infrastructure continues to meet evolving application security needs, supports efficient vulnerability detection, and aligns with organizational risk management objectives.
A robust AST infrastructure is not only a technical necessity but also a compliance enabler. By ensuring the tools and environments used for secure development and maintenance are properly governed, organizations can demonstrate adherence to NIS2’s expectations for operational resilience and system security.

NIS2 Article:
Article 21(2)(e): Requires entities to ensure the security of network and information systems acquisition, development, and maintenance, including the management and disclosure of vulnerabilities.
The explicit focus on ‘development and maintenance’ directly connects to the need for reliable and secure testing infrastructure. A well-architected and properly scaled AST environment is a foundational element for demonstrating compliance with this requirement and for maintaining continuous assurance of software security.
Article 21(2)(a) and (h): Beyond secure development and maintenance, such planning supports compliance with broader NIS2 obligations – Article 21(2)(a) (alignment with risk management and security policies) and Article 21(2)(h) (training and awareness for personnel involved in ICT security and development).

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