Implications of NIS2 on cybersecurity and AI

Explore the key aspects of the NIS2 Directive, the latest EU cyber security legislation coming into effect in 2024. Learn how it impacts AI and security teams.
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Darktrace cyber analysts are world-class experts in threat intelligence, threat hunting and incident response, and provide 24/7 SOC support to thousands of Darktrace customers around the globe. Inside the SOC is exclusively authored by these experts, providing analysis of cyber incidents and threat trends, based on real-world experience in the field.
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John Allen
SVP, Field CISO
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The NIS2 Directive requires member states to adopt laws that will improve the cyber resilience of organizations within the EU. It impacts organizations that are “operators of essential services”. Under NIS 1, EU member states could choose what this meant. In an effort to ensure more consistent application, NIS2 has set out its own definition. It eliminates the distinction between operators of essential services and digital service providers from NIS1, instead defining a new list of sectors:

  • Energy (electricity, district heating and cooling, gas, oil, hydrogen)
  • Transport (air, rail, water, road)
  • Banking (credit institutions)
  • Financial market infrastructures
  • Health (healthcare providers and pharma companies)
  • Drinking water (suppliers and distributors)
  • Digital infrastructure (DNS, TLD registries, telcos, data center providers, etc.)
  • ICT service providers (B2B): MSSPs and managed service providers
  • Public administration (central and regional government institutions, as defined per member state)
  • Space
  • Postal and courier services
  • Waste management
  • Chemicals
  • Food
  • Manufacturing of medical devices
  • Computers and electronics
  • Machinery and equipment
  • Motor vehicles, trailers and semi-trailers and other transport equipment
  • Digital providers (online market places, online search engines, and social networking service platforms) and research organizations.

With these updates, it becomes harder to try and find industry segments not included within the scope. NIS2 represents legally binding cyber security requirements for a significant region and economy. Standout features that have garnered the most attention include the tight timelines associated with notification requirements. Under NIS 2, in-scope entities must submit an initial report or “early warning” to the competent national authority or computer security incident response team (CSIRT) within 24 hours from when the entity became aware of a significant incident. This is a new development from the first iteration of the Directive, which used more vague language of the need to notify authorities “without undue delay”.

Another aspect gaining attention is oversight and regulation – regulators are going to be empowered with significant investigation and supervision powers including on-site inspections.

The stakes are now higher, with the prospect of fines that are capped at €10 million or 2% of an offending organization’s annual worldwide turnover – whichever is greater. Added to that, the NIS2 Directive includes an explicit obligation to hold members of management bodies personally responsible for breaches of their duties to ensure compliance with NIS2 obligations – and members can be held personally liable.  

The risk management measures introduced in the Directive are not altogether surprising – they reflect common best practices. Many organizations (especially those that are newly in scope for NIS2) may have to expand their cyber security capabilities, but there’s nothing controversial or alarming in the required measures.  For organizations in this situation, there are various tools, best practices, and frameworks they can leverage.  Darktrace in particular provides capabilities in the areas of visibility, incident handling, and reporting that can help.

NIS2 and Cyber AI

The use of AI is not an outright requirement within NIS2 – which may be down to lack of knowledge and expertise in the area, and/or the immaturity of the sector. The clue to this might be in the timing: the provisional agreement on the NIS2 text was reached in May 2022 – six months before ChatGPT and other open-source Generative AI tools propelled broader AI technology into the forefront of public consciousness. If the language were drafted today, it's not far-fetched to imagine AI being mentioned much more prominently and perhaps even becoming a requirement.

NIS2 does, however, very clearly recommend that “member states should encourage the use of any innovative technology, including artificial intelligence”[1].  Another section speaks directly to essential and important entities, saying that they should “evaluate their own cyber security capabilities, and where appropriate, pursue the integration of cyber security enhancing technologies, such as artificial intelligence or machine learning systems…”[2]

One of the recitals states that “member states should adopt policies on the promotion of active cyber protection”.  Where active cyber protection is defined as “the prevention, detection, monitoring, analysis and mitigation of network security breaches in an active manner.”[3]  

From a Darktrace perspective, our self-learning Cyber AI technology is precisely what enables our technology to deliver active cyber protection – protecting organizations and uplifting security teams at every stage of an incident lifecycle – from proactively hardening defenses before an attack is launched, to real-time threat detection and response, through to recovering quickly back to a state of good health.  

The visibility provided by Darktrace is vital to understanding the effectiveness of policies and ensuring policy compliance. NIS2 also covers incident handling and business continuity, which Darktrace HEAL addresses through AI-enabled incident response, readiness reports, simulations, and secure collaborations.

Reporting is integral to NIS2 and organizations can leverage Darktrace’s incident reporting features to present the necessary technical details of an incident and provide a jump start to compiling a full report with business context and impact.  

What’s next for NIS2

We don’t yet know the details for how EU member states will transpose NIS2 into national law – they have until 17th October 2024 to work this out. The Commission also commits to reviewing the functioning of the Directive every three years. Given how much our overall understanding and appreciation for not only the dangers of AI but also its power (perhaps even necessity in the realm of cyber security) is changing, we may see many member states will leverage the recitals’ references to AI in order to make a strong push if not a requirement that essential and important organizations within their jurisdiction leverage AI.

Organizations are starting to prepare now to meet the forthcoming legislation related to NIS2. Download our CISO’s Guide to NIS2 Preparedness, which includes everything you need to know to get ahead of the directive.

[1] (51) on page 11
[2]
(89) on page 17
[3]
(57) on page 12

Inside the SOC
Darktrace cyber analysts are world-class experts in threat intelligence, threat hunting and incident response, and provide 24/7 SOC support to thousands of Darktrace customers around the globe. Inside the SOC is exclusively authored by these experts, providing analysis of cyber incidents and threat trends, based on real-world experience in the field.
Written by
John Allen
SVP, Field CISO

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April 24, 2026

Email-Borne Cyber Risk: A Core Challenge for the CISO in the Age of Volume and Sophistication

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The challenge for CISOs

Despite continuous advances in security technologies, humans continue to be exploited by attackers. Credential abuse and social actions like phishing are major factors, accounting for around 60% of all breaches. These attacks rely less on technical vulnerabilities and more on exploiting human behavior and organizational processes. 

From my perspective as a former CISO, protecting humans concentrates three of today’s most pressing challenges: the sheer volume of email-based threats, their increasing sophistication, and the limitations of traditional employee awareness programs in moving the needle on risk. 

My personal experience of security awareness training as a CISO

With over 20 years’ experience as an ICT and Cybersecurity leader across various international organizations, I’ve seen security awareness training (SAT) in many guises. And while the cyber landscape is evolving in every direction, the effectiveness of SAT is reaching a plateau.  

Most programs I’ve seen follow a familiar pattern. Training is delivered through a combination of eLearning modules and internal sessions designed to reinforce IT policies. Employees are typically required to complete a slide deck or video, followed by a multiple-choice quiz. Occasional phishing simulations are distributed throughout the year.

The content is often static and unpersonalized, based on known threats that may already be outdated. Every employee regardless of role or risk exposure receives the same training and the same simulated phishing templates, from front-desk staff to the CEO.

The problem with traditional SAT programs

The issue with the approach to SAT outlined above is that the distribution of power is imbalanced. Humans will always be fallible, particularly when faced with increasingly sophisticated attacks. Providing generic, low-context training risks creating false confidence rather than genuine resilience. Let’s look at some of the problems in detail.

Timing and delivery

Employees today operate under constant cognitive load, making lots of rapid decisions every day to reduce their email volumes. Yet if employees are completing training annually, or on an ad hoc basis, it becomes a standalone occurrence rather than a continuous habit.  

As a result, retention is low. Employees often forget the lessons within weeks, a phenomenon known as the ‘Ebbinghaus Forgetting Curve.’

The graph illustrates that when you first learn something, the information disappears at an exponential rate without retention. In fact, according to the curve, you forget 50% of all new information within a day, and 90% of all new information within a week.  

Simultaneously, most training is conducted within a separate interface. Because it takes place away from the actual moment of decision-making, the "teachable moment" is lost. There is a cognitive disconnect between the action (clicking a link in Outlook) and the education (watching a video in a browser). 

People

In the context of professional risk management, the risks faced by different users are different. Static learning such as everyone receiving the same ‘Password Reset’ email doesn’t help users prepare for the specific threats they are likely to face. It also contributes to user fatigue, driven by repetitive training. And if users receive tests at the same time, news spreads among colleagues, hurting the efficacy of the test.  

Staff turnover introduces further risk. In many organizations, new employees gain access to systems before receiving meaningful training, reducing onboarding to little more than policy acknowledgment.

Measuring success

In my experience, solutions are standalone, without any correlation to other tools in the security stack. In some cases, the programs are delivered by HR rather than the security team, creating a complete silo.  

As a result, SAT is often perceived as a compliance exercise rather than a capability building function. The result is that poor-quality training does little to reduce the likelihood of compromise, regardless of completion rates or quiz performance.

What a modern SAT solution should look like

For today’s CISO, email represents the convergence point of high-volume, high-impact, and human-centric threats. Despite significant security investments, it remains one of the most difficult channels to secure effectively. Given these constraints, CISOs must evolve their approach to SAT.

Success lies in a balanced strategy one that combines advanced technology, attack surface reduction, and pragmatic user enablement, without over-relying on human vigilance as the final line of defense.

This means moving beyond traditional SAT toward continuous, contextual awareness, realistic simulations, and tight integration with security outcomes.

Three requirements for a modern SAT solution

  • Invisible protection: The optimum security solution is one that assists users without impeding their experience. The objective is to enhance human capabilities, rather than simply delivering a lecture. 
  • Real-time feedback: Rather than a monthly quiz, the ideal system would provide a prompt or warning when a user is about to engage with something suspicious. 
  • Positive culture: Shifting the focus away from a "gotcha" culture, which is a contributing factor to a resentment, and instead empowers employees to serve as "sensors" for the company. 

Discover how personalized security coaching can strengthen your human layer and make your email defenses more resilient. Explore Darktrace / Adaptive Human Defense.

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About the author
Karim Benslimane
VP, Field CISO

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April 21, 2026

How a Compromised eScan Update Enabled Multi‑Stage Malware and Blockchain C2

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The rise of supply chain attacks

In recent years, the abuse of trusted software has become increasingly common, with supply chain compromises emerging as one of the fastest growing vectors for cyber intrusions. As highlighted in Darktrace’s Annual Threat Report 2026, attackers and state-actors continue to find significant value in gaining access to networks through compromised trusted links, third-party tools, or legitimate software. In January 2026, a supply chain compromise affecting MicroWorld Technologies’ eScan antivirus product was reported, with malicious updates distributed to customers through the legitimate update infrastructure. This, in turn, resulted in a multi‑stage loader malware being deployed on compromised devices [1][2].

An overview of eScan exploitation

According to eScan’s official threat advisory, unauthorized access to a regional update server resulted in an “incorrect file placed in the update distribution path” [3]. Customers associated with the affected update servers who downloaded the update during a two-hour window on January 20 were impacted, with affected Windows devices subsequently have experiencing various errors related to update functions and notifications [3].

While eScan did not specify which regional update servers were affected by the malicious update, all impacted Darktrace customer environments were located in the Europe, Middle East, and Africa (EMEA) region.

External research reported that a malicious 32-bit executable file , “Reload.exe”, was first installed on affected devices, which then dropped the 64-bit downloader, “CONSCTLX.exe”. This downloader establishes persistence by creating scheduled tasks such as “CorelDefrag”, which are responsible for executing PowerShell scripts. Subsequently, it evades detection by tampering with the Windows HOSTS file and eScan registry to prevent future remote updates intended for remediation. Additional payloads are then downloaded from its command-and-control (C2) server [1].

Darktrace’s coverage of eScan exploitation

Initial Access and Blockchain as multi-distributed C2 Infrastructure

On January 20, the same day as the aforementioned two‑hour exploit window, Darktrace observed multiple devices across affected networks downloading .dlz package files from eScan update servers, followed by connections to an anomalous endpoint, vhs.delrosal[.]net, which belongs to the attackers’ C2 infrastructure.

The endpoint contained a self‑signed SSL certificate with the string “O=Internet Widgits Pty Ltd, ST=SomeState, C=AU”, a default placeholder commonly used in SSL/TLS certificates for testing and development environments, as well as in malicious C2 infrastructure [4].

Utilizing a multi‑distributed C2 infrastructure, the attackers also leveraged domains linked with the Solana open‑source blockchain for C2 purposes, namely “.sol”. These domains were human‑readable names that act as aliases for cryptocurrency wallet addresses. As browsers do not natively resolve .sol domains, the Solana Naming System (formerly known as Bonfida, an independent contributor within the Solana ecosystem) provides a proxy service, through endpoints such as sol-domain[.]org, to enable browser access.

Darktrace observed devices connecting to blackice.sol-domain[.]org, indicating that attackers were likely using this proxy to reach a .sol domain for C2 activity. Given this behavior, it is likely that the attackers leveraged .sol domains as a dead drop resolver, a C2 technique in which threat actors host information on a public and legitimate service, such as a blockchain. Additional proxy resolver endpoints, such as sns-resolver.bonfida.workers[.]dev, were also observed.

Solana transactions are transparent, allowing all activity to be viewed publicly. When Darktrace analysts examined the transactions associated with blackice[.]sol, they observed that the earliest records dated November 7, 2025, which coincides with the creation date of the known C2 endpoint vhs[.]delrosal[.]net as shown in WHOIS Lookup information [4][5].

WHOIS Look records of the C2 endpoint vhs[.]delrosal[.]net.
Figure 1: WHOIS Look records of the C2 endpoint vhs[.]delrosal[.]net.
 Earliest observed transaction record for blackice[.]sol on public ledgers.
Figure 2: Earliest observed transaction record for blackice[.]sol on public ledgers.

Subsequent instructions found within the transactions contained strings such as “CNAME= vhs[.]delrosal[.]net”, indicating attempts to direct the device toward the malicious endpoint. A more recent transaction recorded on January 28 included strings such as “hxxps://96.9.125[.]243/i;code=302”, suggesting an effort to change C2 endpoints. Darktrace observed multiple alerts triggered for these endpoints across affected devices.

Similar blockchain‑related endpoints, such as “tumama.hns[.]to”, were also observed in C2 activities. The hns[.]to service allows web browsers to access websites registered on Handshake, a decentralized blockchain‑based framework designed to replace centralized authorities and domain registries for top‑level domains. This shift toward decentralized, blockchain‑based infrastructure likely reflects increased efforts by attackers to evade detection.

In outgoing connections to these malicious endpoints across affected networks, Darktrace / NETWORK recognized that the activity was 100% rare and anomalous for both the devices and the wider networks, likely indicative of malicious beaconing, regardless of the underlying trusted infrastructure. In addition to generating multiple model alerts to capture this malicious activity across affected networks, Darktrace’s Cyber AI Analyst was able to compile these separate events into broader incidents that summarized the entire attack chain, allowing customers’ security teams to investigate and remediate more efficiently. Moreover, in customer environments where Darktrace’s Autonomous Response capability was enabled, Darktrace took swift action to contain the attack by blocking beaconing connections to the malicious endpoints, even when those endpoints were associated with seemingly trustworthy services.

Conclusion

Attacks targeting trusted relationships continue to be a popular strategy among threat actors. Activities linked to trusted or widely deployed software are often unintentionally whitelisted by existing security solutions and gateways. Darktrace observed multiple devices becoming impacted within a very short period, likely because tools such as antivirus software are typically mass‑deployed across numerous endpoints. As a result, a single compromised delivery mechanism can greatly expand the attack surface.

Attackers are also becoming increasingly creative in developing resilient C2 infrastructure and exploiting legitimate services to evade detection. Defenders are therefore encouraged to closely monitor anomalous connections and file downloads. Darktrace’s ability to detect unusual activity amidst ever‑changing tactics and indicators of compromise (IoCs) helps organizations maintain a proactive and resilient defense posture against emerging threats.

Credit to Joanna Ng (Associate Principal Cybersecurity Analyst) and Min Kim (Associate Principal Cybersecurity Analyst) and Tara Gould (Malware Researcher Lead)

Edited by Ryan Traill (Content Manager)

Appendices

Darktrace Model Detections

  • Anomalous File::Zip or Gzip from Rare External Location
  • Anomalous Connection / Suspicious Self-Signed SSL
  • Anomalous Connection / Rare External SSL Self-Signed
  • Anomalous Connection / Suspicious Expired SSL
  • Anomalous Server Activity / Anomalous External Activity from Critical Network Device

List of Indicators of Compromise (IoCs)

  • vhs[.]delrosal[.]net – C2 server
  • tumama[.]hns[.]to – C2 server
  • blackice.sol-domain[.]org – C2 server
  • 96.9.125[.]243 – C2 Server

MITRE ATT&CK Mapping

  • T1071.001 - Command and Control: Web Protocols
  • T1588.001 - Resource Development
  • T1102.001 - Web Service: Dead Drop Resolver
  • T1195 – Supple Chain Compromise

References

[1] https://www.morphisec.com/blog/critical-escan-threat-bulletin/

[2] https://www.bleepingcomputer.com/news/security/escan-confirms-update-server-breached-to-push-malicious-update/

[3] hxxps://download1.mwti.net/documents/Advisory/eScan_Security_Advisory_2026[.]pdf

[4] https://www.virustotal.com/gui/domain/delrosal.net

[5] hxxps://explorer.solana[.]com/address/2wFAbYHNw4ewBHBJzmDgDhCXYoFjJnpbdmeWjZvevaVv

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About the author
Joanna Ng
Associate Principal Analyst
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