NIS2 Categorization: A Compliance Requirement or a Strategic Opportunity?

The deadline for communicating the information required by NIS2 has passed. Many organizations have completed the document, listed the activities, assigned the categories, and transmitted the information to the competent authorities. However, the real work begins now.

The Risk of Considering Categorization a Formal Compliance

In many organizations, there is a reassuring feeling of completed work: the box has been checked, the file is in order. It is exactly in this feeling that the greatest risk lies. Considering categorization a closed practice means:

• Reducing a potentially strategic activity to an administrative requirement;
• Having built, with effort, a representation of the organization's functions and their relevance, only to let it age in a folder without that knowledge improving the security system by a millimeter.

Two Possible Paths

After communicating the information, every organization finds itself at a crossroads:

1. The Path of Preservation

Preserving categorization as an autonomous document, separate from internal assessments. Although simple, this solution is the weakest because it produces two parallel representations of the same organization: what has been communicated to the Authority and what the organization actually uses to assess risks and decide how to protect itself.

2. The Path of Integration

Using categorization as an element of the management system. This path requires initial work but returns a benefit that is worth the investment because it reduces the distance between what the organization declares and what the organization does.

Integration means creating relationships. Each activity or service must be able to be linked to processes, information, assets, people, suppliers, events, measures adopted, residual risks, and decisions made.

What Can Be Achieved by Taking the Second Path?

A well-used categorization improves a surprising number of decisions because:

• It helps establish which activities require greater attention and directs the updating of the risk analysis;
• It highlights critical services that the internal system did not adequately represent;
• It guides operational continuity tests, the frequency of checks, investments, and the quality of information destined for the top management.

The most valuable result concerns the management of priorities. No organization has unlimited resources: it is necessary to decide where to intervene first, and a clear representation of the relevance of activities protects against two specular errors.

What Categorization Is Not

The delicate point is understanding what categorization is not. It is not a risk analysis. The relevance category describes the potential severity of a compromise but does not consider the probability of events, the presence of vulnerabilities, the effectiveness of measures already adopted, or the residual risk.

The two assessments must dialogue; they do not necessarily have to produce the same number. Confusing the relevance category with the internal risk level generates artificial correspondences and can compromise the coherence of the entire system.

The Model for Listing, Characterization, and Categorization

Determinazione ACN n. 155238 of April 20, 2026 defined the model for listing, characterizing, and categorizing the activities and services of NIS subjects: ten macro-areas within which to organize what the organization does, and four relevance categories – minimal impact, low, medium, high – with which to qualify it.

The category expresses the impact that the compromise of an activity or service could produce on the subject's ability to perform its functions or continue to provide its services.

The value of the work done will not depend on the formal quality of what has been transmitted. It will depend on the use that each organization decides to make of it. The answers to the questions about the future of categorization will distinguish the organizations that have complied from those that have understood.