NIS2 Training for Executive Management: A Practical Guide

Members of the executive management of important and particularly important institutions must regularly participate in training that enables them to identify and assess cybersecurity risks and appropriate risk management measures. A general employee module on suspicious emails is not sufficient for this purpose. The training must align with management’s responsibilities: understanding risks, scrutinizing decisions, approving measures, and monitoring their implementation.

In Germany, this obligation is enshrined in Section 38(3) of the BSIG. Companies should therefore develop their own training format for executive management or the board of directors, update it regularly, and document it in a traceable manner.

Why NIS2 Addresses Senior Management Directly

NIS2 treats cybersecurity as a leadership and risk management issue. According to Article 20 of the NIS2 Directive, management bodies are required to approve cybersecurity risk management measures, monitor their implementation, and complete training.

The BSI clearly summarizes this expectation: Cybersecurity must be an integral part of business operations and risk management. Its Guidance on NIS 2 Executive Management Training serves as a guide for executive management and training providers regarding the scope and requirements.

This shifts the internal focus. It is no longer just a matter of whether the IT department runs an awareness program. Senior management must be able to assess whether the organization has selected appropriate measures, what residual risks remain, and whether identified gaps are actually being closed.

What Executive Management Should Be Able to Do After the Training

Good training does not impart technical detail for its own sake. It fosters decision-making capability.

After the training, executive management should, in particular:

be able to classify the key cyber risks associated with their own business model
understand the division of responsibilities among senior management, the CISO, IT, data protection, compliance, and business units
critically evaluate the appropriateness of proposed risk management measures
be familiar with escalation and reporting procedures for significant security incidents
be able to assess the impact on operations, customers, the supply chain, finances, and reputation
be able to distinguish meaningful metrics from mere activity figures
make informed decisions regarding documented risk acceptances
monitor the effectiveness and further development of the measures

A certificate alone does not prove this ability. Training content, dialogue with those responsible, and the connection to real-world business risks are more important than a set of slides that is as comprehensive as possible.

These Topics Belong in a NIS2 Executive Training Course

1. Scope and Responsibilities

Participants need a clear understanding of the context: Why does the company fall within the scope of application? Which national implementation applies? Which responsibilities lie with senior management, and which with operational roles?

The training should correctly explain legal obligations but should not create a false sense of security. It is not a substitute for legal advice regarding individual compliance issues.

2. Cyber Risks in the Company’s Own Business Model

Abstract lists of threats are not enough. Concrete impacts are more relevant:

Failure of critical services
Manipulation of business or production processes
Identity and access risks
Ransomware and data breaches
Social engineering targeting finance, support, or executives
Dependencies on cloud, IT, and supply chain partners

Senior management should understand which scenarios could have existential or regulatory consequences.

3. Risk Management Measures Under NIS2

Article 21 lists a broad range of measures, including incident handling, business continuity, supply chain security, vulnerability management, cyber hygiene, training, cryptography, access control, and multi-factor authentication.

Management training should demonstrate how these areas interact. Awareness is part of this process; it is not a substitute for technical and organizational controls.

4. Incident Management and Reporting Channels

In the event of an incident, senior management must know:

who classifies an incident internally
who makes decisions regarding operations, communication, and external support
what escalation procedures are in place
what information is required for reports and situation assessments
when crisis management or business continuity is activated

A brief tabletop exercise is often more effective than yet another presentation. It reveals whether roles and decision-making processes actually work.

5. Oversight and Effectiveness Monitoring

Senior management needs key metrics to support decision-making. Useful examples include:

Coverage of critical systems by defined controls
Outstanding high-risk measures and their age
Recovery tests and achieved recovery times
Incidents and near misses by cause and impact
Awareness coverage, reporting rate, and time to reporting
Completion and effectiveness of approved improvements

A training completion rate alone does not indicate whether risk management is effective.

Why Standard Employee Training Is Not Enough

A basic training module for employees answers questions such as: How do I recognize a suspicious message? Where do I report it? How should I respond to an unexpected MFA request?

Senior management must make other decisions:

Is the budget commensurate with the risk?
Are responsibilities and escalation procedures clearly defined?
Can critical services continue to operate or be restored after an incident?
Are supplier risks adequately managed?
What residual risks does the company consciously accept?
How is implementation monitored?

For this reason, companies should treat executive training as a separate program rather than simply reassigning the general awareness module.

How often should executive management be trained?

Section 38(3) of the BSIG requires regular participation. A uniform frequency for every company would make little practical sense, as risk, the pace of change, and prior knowledge vary.

A practical model includes:

initial training upon the commencement of the obligation or upon joining the executive management team
regular refresher training at a set interval
event-driven updates in the event of significant legal, threat, or business changes
exercises following major changes to crisis or reporting processes

The frequency should be specified and justified in a policy or training plan. In environments with a high rate of change, a long standard cycle may not be sufficient.

How to Document the Training

Reliable documentation includes more than just names and dates. The following should be documented:

Target audience and participating members of senior management
Learning objectives
Agenda and topics covered
Date, duration, and format
Person responsible for the content or training provider
Version of the training materials used
Certificate of attendance or completion
Open questions and agreed-upon follow-up actions
Schedule or rationale for the next refresher session

If an exercise was part of the training, the results and improvement measures should be documented without unnecessarily disseminating sensitive technical details.

How Awareness Data Belongs in Management Training

Senior management does not need to monitor individual employees. It needs an aggregated view of whether the awareness program is reducing risks and whether reporting channels are functioning properly.

Appropriate information includes, for example:

Percentage of target groups reached
Completion rates and overdue assignments
Trends in reporting rates
Time to the first qualified report
Recurring risk themes
Impact of targeted refresher training
Organizational issues, such as unclear reporting channels

The AutoPhish Training Platform can track training assignments, progress, and simulation-based follow-up. This provides senior management with a concise, aggregated overview of the situation. However, the platform does not replace separate management training on governance, risk, and oversight.

Common Mistakes

Issuing Only a Certificate of Participation

The certificate confirms participation but does not automatically verify relevant content or integration into corporate governance.

Delegating the training entirely to IT

IT can prepare the content, but this does not delegate management’s responsibility.

Focusing solely on legal sanctions

A presentation focused solely on liability rarely leads to better decisions. Corporate risks, measures, and oversight must be the central focus.

Failing to Establish a Connection to Real-World Metrics

Without reference to the company’s own risk register, incidents, tests, and pending measures, the training remains abstract.

Treating Management and Employees Equally

Both groups need awareness training, but with different learning objectives and responsibilities.

FAQ

Who counts as senior management for the purposes of NIS2 implementation?

This depends on the legal form, function, and national implementation. Companies should verify the specific classification legally and not base their decision solely on job titles.

Does every member of management have to participate?

The training requirement applies to members of management at affected organizations. A single “cybersecurity officer” does not automatically replace the need for the other management members to be qualified.

Is an online course sufficient?

An online course can be part of the solution if the learning objectives, content, and proof of completion are appropriate. For company-specific risks and decision-making processes, a moderated discussion or exercise is often additionally beneficial.

Does the training have to take place every year?

The law refers to regular participation, not to a universal annual frequency for every situation. Companies should establish a risk-based schedule and plan for additional updates in the event of significant changes.

Should phishing simulations be included in executive training?

They can serve as a practical element, for example, to test reporting or approval processes. However, they do not replace training on governance, risk management, and oversight.

Conclusion

NIS2 executive training is not merely an extended phishing session. It is designed to empower executives to manage cyber risks as business risks, assess appropriate measures, and monitor their effectiveness.

For the operational part of the awareness program, the AutoPhish Training Platform supports assignment, progress tracking, and targeted follow-up. Management responsibility remains where NIS2 places it: with senior management.