CISO vs. CEO: Who's Accountable for IT Security?

Why Accountability for IT Security Lies with the CEO

In many organizations, there's a dangerous misunderstanding: The Chief Information Security Officer (CISO) is seen as the person "responsible" for the company's security. However, this oversimplified view leads to structural problems in IT security governance and can have fatal consequences in critical situations.

The reality is more complex and nuanced: It's not the CISO who's ultimately accountable for security, but the CEO. This distinction is not merely semantic but has far-reaching practical and legal consequences for the organization.

The Subtle but Critical Difference: Responsible vs. Accountable

In German, we often use just one word, "Verantwortung," for all types of responsibilities. English offers a more important differentiation that has become standard in modern governance models like RACI (Responsible, Accountable, Consulted, Informed):

Responsible means: in charge of execution, operational implementation, and management of a task.

Accountable means: bears the ultimate risk, must provide accountability, and is legally and commercially liable.

This separation is fundamental for a functioning security organization. When it's missing or ignored, governance gaps emerge that make the company vulnerable.

The Three Levels of Security Responsibility

1. The Board/CEO is Accountable

The CEO or board carries the ultimate accountability for the company's security. This means specifically:

They make the final decisions about security investments and priorities
They approve the budget for security measures, tools, and personnel
They bear the risk and must be accountable in case of a security incident to the supervisory board, shareholders, customers, and regulators
They prioritize between business objectives and security requirements

This role cannot be delegated. Under NIS2, DORA, and other regulatory frameworks, this personal liability of management is increasingly being specified and strengthened.

2. The CISO is Responsible

The CISO is operationally responsible for security management. Their core tasks include:

Managing the security function across all areas of the company
Creating transparency about the current security posture
Risk communication: Explaining complex security risks so the CEO can make informed decisions
Developing strategies and policies for information security
Coordinating between IT, business units, and management

The CISO advises, recommends, and warns. They create the decision-making foundation. But the final decision on risk acceptance lies with the CEO.

3. Business Units and IT are Implementation-Responsible

The actual implementation of security measures occurs where systems are operated and data is processed:

IT administrators patch servers and configure firewalls
Development teams implement secure coding practices
Business units implement data protection and security policies in daily operations
All employees contribute to overall security through security-conscious behavior

The CISO doesn't patch the server themselves but defines the requirement and verifies implementation. This separation is crucial for scalability and efficiency.

What a Modern CISO Really Needs

The CISO role has fundamentally changed in recent years. From technical specialist to strategic advisor and communicator. The most important competencies of a successful CISO are:

Communication and "Translation"

The ability to translate complex technical security risks into business risks is perhaps the most important CISO competency. The CEO must understand: What does this vulnerability mean for our revenue, our reputation, our compliance? Only then can they decide.

Business Understanding

A CISO must understand how the company makes money. Which processes are critical? Which data is valuable? Where are the real business risks? Only with this understanding can they prioritize security meaningfully and contribute to business success rather than hinder it.

Leadership Without Disciplinary Authority

In most organizations, the CISO has no direct authority over IT or business units. Yet they must still enforce security objectives. This requires influencing skills, persuasiveness, and the ability to forge alliances.

Integrity and Calm in Crisis

When there's a fire, such as during a cyberattack, the company needs a CISO who remains calm, communicates clearly, and proceeds systematically. Panic is the enemy of good decisions.

What's Often Overrated

Surprisingly, hardcore technical skills are less central in the modern CISO role than many think:

Super-hacker skills: Nice to have, but not decisive
Conducting pen tests yourself: There are specialists for that
Configuring firewalls via CLI: That's the job of IT administration

A CISO must be able to understand and assess these topics but doesn't need to execute them operationally. Their time is better invested in strategy, communication, and coordination.

The Navigation Metaphor: Clearly Defining Roles

An apt metaphor for role distribution:

The CISO provides the navigation system and weather forecast. They show possible routes, warn of dangers, and give recommendations.

The CEO must drive and be accountable for the route. They decide which risk is acceptable, which route to take, and bear the consequences.

This clarity protects both roles and the entire organization. The CISO can speak openly about risks without fear of being held personally liable for every decision. The CEO can decide, knowing they bear full accountability.

Practical Implementation: How to Succeed with Role Clarification

How can companies establish this role distribution in practice?

Document roles and responsibilities in a security governance structure (e.g., with RACI matrix)
Establish regular security briefings for management
Define decision processes for security investments and risk acceptance
Communicate the role distribution clearly throughout the organization
Train the CEO in fundamental cyber risks and their personal accountability

Conclusion: Governance is the Key

Many security problems in companies are not technical problems but governance problems. When roles are unclear, responsibilities are blurred, and decision paths are not defined, even the best technical measures cannot achieve their effectiveness.

The clear distinction between "accountable" and "responsible" is more than a linguistic detail. It's the foundation for a functioning security organization in which the CISO can act as a strategic advisor and the CEO consciously fulfills their entrepreneurial responsibility.

The question is not whether your company needs a CISO. The question is: Does your CEO know they're accountable?

This governance clarity becomes even more critical as regulatory requirements intensify. With frameworks like NIS2 and DORA, personal liability of management is no longer theoretical but has concrete legal consequences. CEOs who delegate security responsibility without retaining accountability are taking a significant personal and professional risk.

How is Role Distribution Regulated in Your Organization?

The successful implementation of this governance model requires ongoing dialogue. Regular security committee meetings, clear escalation paths, and documented risk decisions create the necessary transparency. The CISO becomes a trusted advisor who can speak truth to power, and the CEO becomes an informed decision-maker who understands and accepts their accountability.

In the end, effective cybersecurity is not just about technology, tools, or talent. It's about governance, clarity, and accountability. When everyone knows their role and can fulfill it effectively, the organization becomes not just more secure but also more agile and resilient.

The modern CISO doesn't need to be a super-hacker. They need to be a bridge builder, translator, and strategic thinker who enables the CEO to make informed decisions. And the CEO needs to embrace their role as the ultimately accountable party, not delegate it away.

That's how security governance works in the 21st century.