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NIS2: Building the Bridge Between Compliance and Technology

Alexander Busse·November 18, 2025
NIS2: Building the Bridge Between Compliance and Technology

The Gap Between Compliance and Technology: Why "Alibi Security" Emerges

In my recent post about NIS2 as a "management litmus test," I warned against "Potemkin Compliance." A compliance framework that looks perfect on paper but offers no real protection in reality. But how does this dangerous façade emerge? The answer lies in a deep, structural gap between compliance and technology, two worlds that often don't speak the same language.

This article shows you why this gap exists, how it creates "alibi security," and what central role a CISO or virtual CISO (vCISO) must play as a translator to build the bridge.

Two Worlds: Compliance vs. Technology

Left: The Compliance World

In the compliance world, everything revolves around order, documentation, and auditability. The language here is shaped by standards like ISO 27001, specifically controls such as A.5.1 (policies for information security).

The goal: The green checkmark in the audit. The critical questions are:

  • Is the policy approved?
  • Is the process documented?
  • Are we audit-ready?

The reality: Bright offices, organized processes, structured meetings. The compliance department works with frameworks, policies, and governance structures. From this perspective, IT technology often appears as chaotic, uncontrollable "chaos" that finally needs to be brought into orderly channels.

Right: The Technology World

In the technology world, a completely different dynamic prevails. Here, people speak the language of CVSS scores, vulnerability scans, and incident response. A CVSS 9.8 means: critical security vulnerability, highest priority.

The goal: Eliminate the red alert. The urgent questions are:

  • The system has a critical vulnerability!
  • It's on fire!
  • We need a maintenance window NOW!

The reality: Dark data centers, 24/7 availability, stress, ad-hoc firefighting. The IT department battles daily with real threats, zero-day exploits, and scarce resources. From this perspective, compliance often seems like unnecessary "bureaucracy" that distracts from the actual work.

How "Alibi Security" Emerges: The Compliance Silo

Right in this structural gap, what I call "alibi security" emerges. The mechanism is simple yet dangerous:

  1. Compliance treats GRC in isolation: Governance, Risk, and Compliance (GRC) are viewed as their own, separate "solution," often supported by a dedicated GRC tool.
  2. The compliance silo is born: This tool is supposed to manage the green checkmark, document the controls, and deliver audit-proof evidence. A perfect compliance silo is created, decoupled from technical reality.
  3. Technology must deliver additionally: While the IT department fights real threats (CVSS 9.8), it must simultaneously "feed" data, documentation, and status updates to the compliance silo.
  4. The focus shifts: Energy no longer flows primarily into real risk reduction, but into silo-feeding. You work for the audit, not for security.

The result: A compliance structure that looks perfect on paper but doesn't address real technical risks in practice. Potemkin compliance in its purest form.

The Management Vacuum: Both Sides Are Right

The tragic aspect of this situation: Both sides are completely right from their respective perspectives.

  • The compliance side is right that without clear processes, documentation, and governance structures, chaos emerges and the company fails audits.
  • The technology side is right that a critical security vulnerability with CVSS 9.8 must be closed immediately before an attacker exploits it.

The problem: Nobody translates between both worlds. A management vacuum emerges where strategic decisions are made based on incomplete information.

The Bridge: The CISO / vCISO as Translator

The solution is not to eliminate or dominate one side. The solution lies in bridge building. And the central figure of this bridge is the Chief Information Security Officer (CISO) or virtual CISO (vCISO).

The Translator's Role

The CISO doesn't stand on one side of the gap. They stand in the middle and must translate both worlds for management:

➡️ Translating technical risks into business risks: "CVSS 9.8" often means little to management. The CISO translates: "This security vulnerability can shut down our production for 48 hours. The business risk is 2 million euros in lost revenue plus reputational damage."

➡️ Translating compliance requirements into technical mandates: "A.5.1" sounds abstract. The CISO translates: "This is your management mandate and budget to structurally solve the problem, instead of just maintaining a compliance silo that won't protect us in an emergency."

The Bridge Builder's Competencies

A successful CISO or vCISO needs three core competencies:

  1. Technical understanding: They must speak the language of IT, assess CVSS scores, and evaluate technical solution approaches.
  2. Compliance know-how: They must understand standards like ISO 27001, NIS2, GDPR, and translate them into practical requirements.
  3. Business perspective: They must communicate risks in business language and speak with management on equal footing about investments, priorities, and resources.

NIS2 as an Opportunity: The Mandate for Bridge Building

With the NIS2 Directive, companies receive exactly the mandate they need to finally build this bridge. NIS2 makes cybersecurity a top management priority and demands:

  • Management responsibility: Executive leadership is personally liable for cybersecurity.
  • Risk management: Not compliance theater, but genuine risk analysis and risk reduction.
  • Integration: Cybersecurity must be integrated into business processes, not exist as an isolated silo.

NIS2 is therefore not just another compliance requirement. It's a call to management to finally hire the translator who mediates between compliance and technology.

Practical Recommendations

For Management:

  1. Identify your translator: Who stands in the gap in your organization? Do you have a CISO or vCISO who understands both worlds?
  2. Invest in the bridge: Give this role mandate, resources, and direct reporting line to executive leadership.
  3. Demand translations: Don't accept pure technical reports ("CVSS 9.8") or pure compliance reports ("A.5.1 fulfilled"). Demand business risk assessments.

For the Compliance Department:

  1. Leave the silo: GRC is not an end in itself. Actively seek dialogue with IT.
  2. Understand technical risks: Learn the basics of CVSS, vulnerabilities, and incident response.
  3. Measure effectiveness: The green checkmark is not the goal. The goal is risk reduction.

For the IT Department:

  1. Learn compliance language: ISO 27001, NIS2, and other standards are not bureaucracy but your management mandate for budgets and resources.
  2. Document systematically: Yes, it costs time. But in an emergency, only what's documented will protect you.
  3. Communicate business risks: Translate technical problems into business language.

Conclusion: Stop Cementing the Gap

The gap between compliance and technology is real, structural, and deep in many organizations. The answer must not be to cement this gap with additional compliance silos decoupled from technical reality.

NIS2 is the mandate to finally place a translator in the middle and build the bridge. This bridge is called CISO or vCISO. It connects compliance and technology, translates between both worlds, and makes cybersecurity a real business strategy instead of compliance theater.

The critical question for your organization is: Who stands in the gap in your company? Do you have a translator, or are compliance and technology still fighting against each other instead of working together?

The time for alibi security is over. The time for real integration is now.

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