Comments of the European Signature Dialog (ESD) on the Draft of NIS2 Implementing Regulation

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Cybersecurity Rules Must Reflect the Reality of Trust ServicesClear, Proportionate and Standards-Based Requirements Are Key to Harmonised NIS2 Implementation.

Consultation Responses · July 17, 2024

Effective cybersecurity regulation needs to be both ambitious and workable in practice. In its response to the draft NIS2 Implementing Regulation, ESD calls for clearer and more proportionate requirements that recognise the different functions and criticality of individual trust services. ESD advocates realistic incident-reporting thresholds, precise legal definitions and greater reliance on established standards, particularly ETSI EN 319 401 for qualified trust services. A harmonised, standards-based approach can strengthen cybersecurity while supporting consistent supervision, cross-border trust services and a functioning Digital Single Market.

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