What you need to know about FAA Security Protection Regulations 2024
04
Sep 2024
This blog gives an overview of the proposed FAA regulations for safeguarding aviation systems and their cyber-physical networks. Read more to discover key points, challenges, and potential solutions for each use case.
Overview of FAA Rules 2024
Objective
The goal of the Federal Aviation Administration amended rules is to create new design standards that protect airplane systems from intentional unauthorized electronic interactions (IUEI), which can pose safety risks. The timely motivation for this goal is due to the ongoing trend in aircraft design, which features a growing integration of airplane, engine, and propeller systems, along with expanded connectivity to both internal and external data networks and services.
“This proposed rulemaking would impose new design standards to address cybersecurity threats for transport category airplanes, engines, and propellers. The intended effect of this proposed action is to standardize the FAA’s criteria for addressing cybersecurity threats, reducing certification costs and time while maintaining the same level of safety provided by current special conditions.” (1)
Background
Increasing integration of aircraft systems with internal and external networks raises cybersecurity vulnerability concerns.
Key vulnerabilities include:
Field Loadable Software
Maintenance laptops
Public networks (e.g., Internet)
Wireless sensors
USB devices
Satellite communications
Portable devices and flight bags
Requirements for Applicants
Applicants seeking design approval must:
Provide isolation or protection from unauthorized access
Prevent inadvertent or malicious changes to aircraft systems
Establish procedures to maintain cybersecurity protections
Purpose
“These changes would introduce type certification and continued airworthiness requirements to protect the equipment, systems, and networks of transport category airplanes, engines, and propellers against intentional unauthorized electronic interactions (IUEI)1 that could create safety hazards. Design approval applicants would be required to identify, assess, and mitigate such hazards, and develop Instructions for Continued Airworthiness (ICA) that would ensure such protections continue in service.” (1)
Key points:
Introduce new design standards to address cybersecurity threats for transport category airplanes, engines, and propellers.
Aim to reduce certification costs and time while maintaining safety levels similar to current special conditions
Applicant Responsibilities for Identifying, Assessing, and Mitigating IUEI Risks
The proposed rule requires applicants to safeguard airplanes, engines, and propellers from intentional unauthorized electronic interactions (IUEI). To do this, they must:
Identify and assess risks: Find and evaluate any potential electronic threats that could harm safety.
Mitigate risks: Take steps to prevent these threats from causing problems, ensuring the aircraft remain safe and functional.
Let’s break down each of the requirements:
Performing risk analysis
“For such identification and assessment of security risk, the applicant would be required to perform a security risk analysis to identify all threat conditions associated with the system, architecture, and external or internal interfaces.”(3)
Challenge
The complexity and variety of OT devices make it difficult and time-consuming to identify and associate CVEs with assets. Security teams face several challenges:
Prioritization Issues: Sifting through extensive CVE lists to prioritize efforts is a struggle.
Patch Complications: Finding corresponding patches is complicated by manufacturer delays and design flaws.
Operational Constraints: Limited maintenance windows and the need for continuous operations make it hard to address vulnerabilities, often leaving them unresolved for years.
Inadequate Assessments: Standard CVE assessments may not fully capture the risks associated with increased connectivity, underscoring the need for a contextualized risk assessment approach.
This highlights the need for a more effective and tailored approach to managing vulnerabilities in OT environments.
Assessing severity of risks
“The FAA would expect such risk analysis to assess the severity of the effect of threat conditions on associated assets (system, architecture, etc.), consistent with the means of compliance the applicant has been using to meet the FAA’s special conditions on this topic.” (3)
Challenge
As shown by the MITRE ATT&CK® Techniques for ICS matrices, threat actors can exploit many avenues beyond just CVEs. To effectively defend against these threats, security teams need a broader perspective, considering lateral movement and multi-stage attacks.
Challenges in Vulnerability Management (VM) cycles include:
Initiation: VM cycles often start with email updates from the Cybersecurity and Infrastructure Security Agency (CISA), listing new CVEs from the NIST database.
Communication: Security practitioners must survey and forward CVE lists to networking teams at facilities that might be running the affected assets. Responses from these teams are inconsistent, leading vulnerability managers to push patches that may not fit within limited maintenance windows.
Asset Tracking: At many OT locations, determining if a company is running a specific firmware version can be extremely time-consuming. Teams often rely on spreadsheets and must perform manual checks by physically visiting production floors ("sneaker-netting").
Coordination: Plant engineers and centralized security teams must exchange information to validate asset details and manually score vulnerabilities, further complicating and delaying remediation efforts.
Determine likelihood of exploitation
“Such assessment would also need to analyze these vulnerabilities for the likelihood of exploitation.” (3)
Challenge
Even when a vulnerability is identified, its actual impact can vary significantly based on the specific configurations, processes, and technologies in use within the organization. This creates challenges for OT security practitioners:
Risk Assessment: Accurately assessing and prioritizing the risk becomes difficult without a clear understanding of how the vulnerability affects their unique systems.
Decision-Making: Practitioners may struggle to determine whether immediate action is necessary, balancing the risk of operational downtime against the need for security.
Potential Consequences: This uncertainty can lead to either leaving critical systems exposed or causing unnecessary disruptions by applying measures that aren't truly needed.
This complexity underscores the challenge of making informed, timely decisions in OT security environments.
Vulnerability mitigation
“The proposed regulation would then require each applicant to 'mitigate' the vulnerabilities, and the FAA expects such mitigation would occur through the applicant’s installation of single or multilayered protection mechanisms or process controls to ensure functional integrity, i.e., protection.” (3)
Challenge
OT security practitioners face a constant challenge in balancing security needs with the requirement to maintain operational uptime. In many OT environments, especially in critical infrastructure, applying security patches can be risky:
Risk of Downtime: Patching can disrupt essential processes, leading to significant financial losses or even safety hazards.
Operational Continuity vs. Security: Practitioners often prioritize operational continuity, sometimes delaying timely security updates.
Alternative Strategies: To protect systems without direct patching, they must implement compensating controls, further complicating security efforts.
This delicate balance between security and uptime adds complexity to the already challenging task of securing OT environments.
Establishing procedures/playbooks
“Finally, each applicant would be required to include the procedures within their instructions for continued airworthiness necessary to maintain such protections.” (3)
Challenge
SOC teams typically have a lag before their response, leading to a higher dwell time and bigger overall costs. On average, only 15% of the total cost of ransomware is affiliated with the ransom itself (2). The rest is cost from business interruption. This means it's crucial that organizations can respond and recover earlier.
Darktrace / OT enabling compliance and enhanced cybersecurity
Darktrace's OT solution addresses the complex challenges of cybersecurity compliance in Operational Technology (OT) environments by offering a comprehensive approach to risk management and mitigation.
Key risk management features include:
Contextualized Risk Analysis: Darktrace goes beyond traditional vulnerability scoring, integrating IT, OT, and CVE data with MITRE techniques to map critical attack paths. This helps in identifying and prioritizing vulnerabilities based on their exposure, difficulty of exploitation, and network impact.
Guidance on Remediation: When patches are unavailable, Darktrace provides alternative strategies to bolster defenses around vulnerable assets, ensuring unpatched systems are not left exposed—a critical need in OT environments where operational continuity is essential.
AI-Driven Adaptability: Darktrace's AI continuously adapts to your organization as it grows; refining incident response playbooks bespoke to your environment in real-time. This ensures that security teams have the most up-to-date, tailored strategies, reducing response times and minimizing the impact of security incidents.
Ready to learn more?
Darktrace / OT doesn’t just offer risk management capabilities. It is the only solution that leverages Self-Learning AI to understand your normal business operations, allowing you to detect and stop insider, known, unknown, and zero-day threats at scale.
Dive deeper into how Darktrace / OT secures critical infrastructure organizations with in-depth insights on its advanced capabilities. Download the Darktrace / OT Solution Brief to explore the technology behind its AI-driven protection and see how it can transform your OT security strategy.
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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.
An Advanced Persistent Threat (APT) describes an adversary with sophisticated levels of expertise and significant resources, with the ability to carry out targeted cyber campaigns. These campaigns may penetrate an organization and remain undetected for long periods, allowing attackers to gather intelligence or cause damage over time.
Over the last few decades, the term APT has evolved from being almost exclusively associated with nation-state actors to a broader definition that includes highly skilled, well-resourced threat groups. While still distinct from mass, opportunistic cybercrime or "spray and pray" attacks, APT now refers to the elite tier of adversaries, whether state-sponsored or not, who demonstrate advanced capabilities, persistence, and a clear strategic focus. This shift reflects the growing sophistication of cyber threats, where non-state actors can now rival nation-states in executing covert, methodical intrusions to achieve long-term objectives.
These attacks are resource-intensive for threat actors to execute, but the potential rewards—ranging from financial gain to sensitive data theft—can be significant. In 2020, Business Email Compromise (BEC) attacks netted cybercriminals over $1.8 billion.1
And recently, the advent of AI has helped to automate launching these attacks, lowering the barriers to entry and making it more efficient to orchestrate the kind of attack that might previously have taken weeks to create. Research shows that AI can do 90% of a threat actor’s work2 – reducing time-to-target by automating tasks rapidly and avoiding errors in phishing communications. Email remains the most popular vector for initiating these sophisticated attacks, making it a critical battleground for cyber defense.
What makes APTs so successful?
The success of Advanced Persistent Threats (APTs) lies in their precision, persistence, and ability to exploit human and technical vulnerabilities. These attacks are carefully tailored to specific targets, using techniques like social engineering and spear phishing to gain initial access.
Once inside, attackers move laterally through networks, often remaining undetected for months or even years, silently gathering intelligence or preparing for a decisive strike. Alternatively, they might linger inside an account within the M365 environment, which could be even more valuable in terms of gathering information – in 2023 the average time to identify a breach in 2023 was 204 days.3
The subtle and long-term outlook nature of APTs makes them highly effective, as traditional security measures often fail to identify the subtle signs of compromise.
How Darktrace’s approach is designed to catch the most advanced threats
Luckily for our customers, Darktrace’s AI approach is uniquely equipped to detect and neutralize APTs. Unlike the majority of email security solutions that rely on static rules and signatures, or that train their AI on previous known-bad attack patterns, Darktrace leverages Self-Learning AI that baselines normal patterns of behavior within an organization, to immediately detect unusual activity that may signal an APT in progress.
But in the modern era of email threats, no email security solution can guarantee 100% effectiveness. Because attackers operate with great sophistication, carefully adapting their tactics to evade detection – whether by altering attachments, leveraging compromised accounts, or moving laterally across an organization – a siloed security approach risks missing these subtle, multi-domain threats. That’s why a robust defense-in-depth strategy is essential to mitigate APTs.
Real-world threat finds: Darktrace / EMAIL in action
Let’s take a look at some real-world scenarios where Darktrace / EMAIL stopped tactics associated with APT campaigns in their tracks – from adversary-in-the-middle attacks to suspicious lateral movement.
1: How Darktrace disrupted an adversary-in-the-middle attack by identifying abnormal login redirects and blocking credential exfiltration
In October 2024, Darktrace detected an adversary-in-the-middle (AiTM) attack targeting a Darktrace customer. The attack began with a phishing email from a seemingly legitimate Dropbox address, which contained multiple link payloads inviting the recipient to access a file. Other solutions would have struggled to catch this attack, as the initial AitM attack was launched through delivering a malicious URL through a trusted vendor or service. Once compromised, the threat actor could have laid low on the target account, gathering reconnaissance, without detection from the email security solution.
Darktrace / EMAIL identified the abnormal login redirects and flagged the suspicious activity. Darktrace / IDENTITY then detected unusual login patterns and blocked credential exfiltration attempts, effectively disrupting the attack and preventing the adversary from gaining unauthorized access. Read more.
Figure 1: Overview of the malicious email in the Darktrace / EMAIL console, highlighting Dropbox associated content/link payloads
2: How Darktrace stopped lateral movement to block NTLM hash theft
In early 2024, Darktrace detected an attack by the TA577 threat group, which aimed to steal NTLM hashes to gain unauthorized access to systems. The attack began with phishing emails containing ZIP files that connected to malicious infrastructure.
A traditional email security solution would have likely missed this attack by focusing too heavily on analyzing the zip file payloads or relying on reputation analysis to understand whether the infrastructure was registered as bad before this activity was a recognized IoC.
Because it correlates activity across domains, Darktrace identified unusual lateral movement within the network and promptly blocked the attempts to steal NTLM hashes, effectively preventing the attackers from accessing sensitive credentials and securing the network. Read more.
Figure 2: A summary of anomaly indicators seen for a campaign email sent by TA577, as detected by Darktrace / EMAIL
3: How Darktrace prevented the WarmCookie backdoor deployment embedded in phishing emails
In mid-2024, Darktrace identified a phishing campaign targeting organizations with emails impersonating recruitment firms. These emails contained malicious links that, when clicked, deployed the WarmCookie backdoor.
These emails are difficult to detect, as they use social engineering tactics to manipulate users into engaging with emails and following the embedded malicious links – but if a security solution is not analysing content and context, these could be allowed through.
In several observed cases across customer environments, Darktrace detected and blocked the suspicious behavior associated with WarmCookie that had already managed to evade customers’ native email security. By using behavioral analysis to correlate anomalous activity across the digital estate, Darktrace was able to identify the backdoor malware strain and notify customers. Read more.
Conclusion
These threat examples highlight a key principle of the Darktrace approach – that a backwards-facing approach grounded in threat intelligence will always be one step behind.
Most threat actors operate in campaigns, carefully crafting attacks and testing them across multiple targets. Once a campaign is identified, good defenders and traditional security solutions quickly update their defenses with new threat intelligence, rules, and signatures. However, APTs have the resources to rapidly adapt – spinning up new infrastructure, modifying payloads and altering their attack footprint to evade detection.
This is where Darktrace / EMAIL excels. Only by analyzing each user, message and interaction can an email security solution hope to catch the types of highly-sophisticated attacks that have the potential to cause major reputational and financial damage. Darktrace / EMAIL ensures that even the most subtle threats are detected and blocked with autonomous response, before causing impact – helping organizations remain one step ahead of increasingly adaptive threat actors.
Discover the most advanced cloud-native AI email security solution to protect your domain and brand while preventing phishing, novel social engineering, business email compromise, account takeover, and data loss.
Gain up to 13 days of earlier threat detection and maximize ROI on your current email security
Experience 20-25% more threat blocking power with Darktrace / EMAIL
Stop the 58% of threats bypassing traditional email security
NIS2 Compliance: Interpreting 'State-of-the-Art' for Organisations
NIS2 Background
17 October 2024 marked the deadline for European Union (EU) Member States to implement the NIS2 Directive into national law. The Directive aims to enhance the EU’s cybersecurity posture by establishing a high common level of cybersecurity for critical infrastructure and services. It builds on its predecessor, the 2018 NIS Directive, by expanding the number of sectors in scope, enforcing greater reporting requirements and encouraging Member States to ensure regulated organisations adopt ‘state-of-the-art' security measures to protect their networks, OT and IT systems.
Figure 1: Timeline of NIS2
The challenge of NIS2 & 'state-of-the-art'
Preamble (51) - "Member States should encourage the use of any innovative technology, including artificial intelligence, the use of which could improve the detection and prevention of cyberattacks, enabling resources to be diverted towards cyberattacks more effectively."
Article 21 - calls on Member States to ensure that essential and important entities “take appropriate and proportionate” cyber security measures, and that they do so by “taking into account the state-of-the-art and, where applicable, relevant European and international standards, as well as the cost of implementation.”
Regulartory expectations and ambiguity of NIS2
While organisations in scope can rely on technical guidance provided by ENISA1 , the EU’s agency for cybersecurity, or individual guidelines provided by Member States or Public-Private Partnerships where they have been published,2 the mention of ‘state-of-the-art' remains up to interpretation in most Member States. The use of the phrase implies that cybersecurity measures must evolve continuously to keep pace with emerging threats and technological advancements without specifying what ‘state-of-the-art’ actually means for a given context and risk.3
This ambiguity makes it difficult for organisations to determine what constitutes compliance at any given time and could lead to potential inconsistencies in implementation and enforcement. Moreover, the rapid pace of technological change means that what is considered "state-of-the-art" today will become outdated, further complicating compliance efforts.
However, this is not unique to NIS regulation. As EU scholars have noted, while “state-of-the-art" is widely referred to in legal text relating to technology, there is no standardised legal definition of what it actually constitutes.4
Defining state-of-the-art cybersecurity
In this blog, we outline technical considerations for state-of-the-art cybersecurity. We draw from expertise within our own business and in academia as well as guidelines and security standards set by national agencies, such as Germany’s Federal Office for Information Security (BSI) or Spain’s National Security Framework (ENS), to put forward five criteria to define state-of-the-art cybersecurity.
The five core criteria include:
Continuous monitoring
Incident correlation
Detection of anomalous activity
Autonomous response
Proactive cyber resilience
These principles build on long-standing security considerations, such as business continuity, vulnerability management and basic security hygiene practices.
Although these considerations are written in the context of the NIS2 Directive, they are likely to also be relevant for other jurisdictions. We hope these criteria help organisations understand how to best meet their responsibilities under the NIS2 Directive and assist Competent Authorities in defining compliance expectations for the organisations they regulate.
Ultimately, adopting state-of-the-art cyber defences is crucial for ensuring that organisations are equipped with the best tools to combat new and fast-growing threats. Leading technical authorities, such as the UK National Cyber Security Centre (NCSC), recognise that adoption of AI-powered cyber defences will offset the increased volume and impact of AI on cyber threats.5
State of the art cybersecurity in the context of NIS2
1. Continuous monitoring
Continuous monitoring is required to protect an increasingly complex attack surface from attackers.
First, organisations' attack surfaces have expanded following the widespread adoption of hybrid or cloud infrastructures and the increased adoption of connected Internet of Things (IoT) devices.6 This exponential growth creates a complex digital environment for organisations, making it difficult for security teams to track all internet-facing assets and identify potential vulnerabilities.
Second, with the significant increase in the speed and sophistication of cyber-attacks, organisations face a greater need to detect security threats and non-compliance issues in real-time.
Continuous monitoring, defined by the U.S. National Institute of Standards and Technology (NIST) as the ability to maintain “ongoing awareness of information security, vulnerabilities, and threats to support organizational risk management decisions,”7 has therefore become a cornerstone of an effective cybersecurity strategy. By implementing continuous monitoring, organisations can ensure a real-time understanding of their attack surface and that new external assets are promptly accounted for. For instance, Spain’s technical guidelines for regulation, as set forth by the National Security Framework (Royal Decree 311/2022), highlight the importance of adopting continuous monitoring to detect anomalous activities or behaviours and to ensure timely responses to potential threats (article 10).8
This can be achieved through the following means:
All assets that form part of an organisation's estate, both known and unknown, must be identified and continuously monitored for current and emerging risks. Germany’s BSI mandates the continuous monitoring of all protocol and logging data in real-time (requirement #110).9 This should be conducted alongside any regular scans to detect unknown devices or cases of shadow IT, or the use of unauthorised or unmanaged applications and devices within an organisation, which can expose internet-facing assets to unmonitored risks. Continuous monitoring can therefore help identify potential risks and high-impact vulnerabilities within an organisation's digital estate and eliminate potential gaps and blind spots.
Organisations looking to implement more efficient continuous monitoring strategies may turn to automation, but, as the BSI notes, it is important for responsible parties to be immediately warned if an alert is raised (reference 110).10 Following the BSI’s recommendations, the alert must be examined and, if necessary, contained within a short period of time corresponding with the analysis of the risk at hand.
Finally, risk scoring and vulnerability mapping are also essential parts of this process. Looking across the Atlantic, the US’ National Institute of Standards and Technology (NIST) defines continuous monitoring as “maintaining ongoing awareness of information security, vulnerabilities, and threats to support organizational risk management decisions”.11 Continuous monitoring helps identify potential risks and significant vulnerabilities within an organisation's digital assets, fostering a dynamic understanding of risk. By doing so, risk scoring and vulnerability mapping allows organisations to prioritise the risks associated with their most critically exposed assets.
2. Correlation of incidents across your entire environment
Viewing and correlating incident alerts when working with different platforms and tools poses significant challenges to SecOps teams. Security professionals often struggle to cross-reference alerts efficiently, which can lead to potential delays in identifying and responding to threats. The complexity of managing multiple sources of information can overwhelm teams, making it difficult to maintain a cohesive understanding of the security landscape.
This fragmentation underscores the need for a centralised approach that provides a "single pane of glass" view of all cybersecurity alerts. These systems streamline the process of monitoring and responding to incidents, enabling security teams to act more swiftly and effectively. By consolidating alerts into a unified interface, organisations can enhance their ability to detect and mitigate threats, ultimately improving their overall security posture.
To achieve consolidation, organisations should consider the role automation can play when reviewing and correlating incidents. This is reflected in Spain’s technical guidelines for national security regulations regarding the requirements for the “recording of activity” (reinforcement R5).12 Specifically, the guidelines state that:
"The system shall implement tools to analyses and review system activity and audit information, in search of possible or actual security compromises. An automatic system for collection of records, correlation of events and automatic response to them shall be available”.13
Similarly, the German guidelines stress that automated central analysis is essential not only for recording all protocol and logging data generated within the system environment but also to ensure that the data is correlated to ensure that security-relevant processes are visible (article 115).14
Correlating disparate incidents and alerts is especially important when considering the increased connectivity between IT and OT environments driven by business and functional requirements. Indeed, organisations that believe they have air-gapped systems are now becoming aware of points of IT/OT convergence within their systems. It is therefore crucial for organisations managing both IT and OT environments to be able to visualise and secure devices across all IT and OT protocols in real-time to identify potential spillovers.
By consolidating data into a centralised system, organisations can achieve a more resilient posture. This approach exposes and eliminates gaps between people, processes, and technology before they can be exploited by malicious actors. As seen in the German and Spanish guidelines, a unified view of security alerts not only enhances the efficacy of threat detection and response but also ensures comprehensive visibility and control over the organisation's cybersecurity posture.
3. Detection of anomalous activity
Recent research highlights the emergence of a "new normal" in cybersecurity, marked by an increase in zero-day vulnerabilities. Indeed, for the first time since sharing their annual list, the Five Eyes intelligence alliance reported that in 2023, the majority of the most routinely exploited vulnerabilities were initially exploited as zero-days.15
To effectively combat these advanced threats, policymakers, industry and academic stakeholders alike recognise the importance of anomaly-based techniques to detect both known and unknown attacks.
As AI-enabled threats become more prevalent,16 traditional cybersecurity methods that depend on lists of "known bads" are proving inadequate against rapidly evolving and sophisticated attacks. These legacy approaches are limited because they can only identify threats that have been previously encountered and cataloged. However, cybercriminals are constantly developing new, never-before-seen threats, such as signatureless ransomware or living off the land techniques, which can easily bypass these outdated defences.
The importance of anomaly detection in cybersecurity can be found in Spain’s technical guidelines, which states that “tools shall be available to automate the prevention and response process by detecting and identifying anomalies17” (reinforcement R4 prevention and automatic response to "incident management”).
Similarly, the UK NCSC’s Cyber Assessment Framework (CAF) highlights how anomaly-based detection systems are capable of detecting threats that “evade standard signature-based security solutions” (Principle C2 - Proactive Security Event Discovery18). The CAF’s C2 principle further outlines:
“The science of anomaly detection, which goes beyond using pre-defined or prescriptive pattern matching, is a challenging area. Capabilities like machine learning are increasingly being shown to have applicability and potential in the field of intrusion detection.”19
By leveraging machine learning and multi-layered AI techniques, organisations can move away from static rules and signatures, adopting a more behavioural approach to identifying and containing risks. This shift not only enhances the detection of emerging threats but also provides a more robust defence mechanism.
A key component of this strategy is behavioral zero trust, which focuses on identifying unauthorized and out-of-character attempts by users, devices, or systems. Implementing a robust procedure to verify each user and issuing the minimum required access rights based on their role and established patterns of activity is essential. Organisations should therefore be encouraged to follow a robust procedure to verify each user and issue the minimum required access rights based on their role and expected or established patterns of activity. By doing so, organisations can stay ahead of emerging threats and embrace a more dynamic and resilient cybersecurity strategy.
4. Autonomous response
The speed at which cyber-attacks occur means that defenders must be equipped with tools that match the sophistication and agility of those used by attackers. Autonomous response tools are thus essential for modern cyber defence, as they enable organisations to respond to both known and novel threats in real time.
These tools leverage a deep contextual and behavioral understanding of the organisation to take precise actions, effectively containing threats without disrupting business operations.
To avoid unnecessary business disruptions and maintain robust security, especially in more sensitive networks such as OT environments, it is crucial for organisations to determine the appropriate response depending on their environment. This can range from taking autonomous and native actions, such as isolating or blocking devices, or integrating their autonomous response tool with firewalls or other security tools to taking customized actions.
Autonomous response solutions should also use a contextual understanding of the business environment to make informed decisions, allowing them to contain threats swiftly and accurately. This means that even as cyber-attacks evolve and become more sophisticated, organisations can maintain continuous protection without compromising operational efficiency.
Indeed, research into the adoption of autonomous cyber defences points to the importance of implementing “organisation-specific" and “context-informed” approaches.20 To decide the appropriate level of autonomy for each network action, it is argued, it is essential to use evidence-based risk prioritisation that is customised to the specific operations, assets, and data of individual enterprises.21
By adopting autonomous response solutions, organisations can ensure their defences are as dynamic and effective as the threats they face, significantly enhancing their overall security posture.
5. Proactive cyber resilience
Adopting a proactive approach to cybersecurity is crucial for organisations aiming to safeguard their operations and reputation. By hardening their defences enough so attackers are unable to target them effectively, organisations can save significant time and money. This proactive stance helps reduce business disruption, reputational damage, and the need for lengthy, resource-intensive incident responses.
Proactive cybersecurity incorporates many of the strategies outlined above. This can be seen in a recent survey of information technology practitioners, which outlines four components of a proactive cybersecurity culture: (1) visibility of corporate assets, (2) leveraging intelligent and modern technology, (3) adopting consistent and comprehensive training methods and (4) implementing risk response procedures.22 To this, we may also add continuous monitoring which allows organisations to understand the most vulnerable and high-value paths across their architectures, allowing them to secure their critical assets more effectively.
Alongside these components, a proactive cyber strategy should be based on a combined business context and knowledge, ensuring that security measures are aligned with the organisation's specific needs and priorities.
This proactive approach to cyber resilience is reflected in Spain’s technical guidance (article 8.2): “Prevention measures, which may incorporate components geared towards deterrence or reduction of the exposure surface, should eliminate or reduce the likelihood of threats materializing.”23 It can also be found in the NCSC’s CAF, which outlines how organisations can achieve “proactive attack discovery” (see Principle C2).24 Likewise, Belgium’s NIS2 transposition guidelines mandate the use of preventive measures to ensure the continued availability of services in the event of exceptional network failures (article 30).25
Ultimately, a proactive approach to cybersecurity not only enhances protection but also lowers regulatory risk and supports the overall resilience and stability of the organisation.
Looking forward
The NIS2 Directive marked a significant regulatory milestone in strengthening cybersecurity across the EU.26 Given the impact of emerging technologies, such as AI, on cybersecurity, it is to see that Member States are encouraged to promote the adoption of ‘state-of-the-art' cybersecurity across regulated entities.
In this blog, we have sought to translate what state-of-the-art cybersecurity may look like for organisations looking to enhance their cybersecurity posture. To do so, we have built on existing cybersecurity guidance, research and our own experience as an AI-cybersecurity company to outline five criteria: continuous monitoring, incident correlation, detection of anomalous activity, autonomous response, and proactive cyber resilience.
By embracing these principles and evolving cybersecurity practices in line with the state-of-the-art, organisations can comply with the NIS2 Directive while building a resilient cybersecurity posture capable of withstanding evolutions in the cyber threat landscape. Looking forward, it will be interesting to see how other jurisdictions embrace new technologies, such as AI, in solving the cybersecurity problem.
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