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NIS2 & CyFun

Difference Between NIS2 & CyFun

NIS2 is the European legislation that requires organizations to strengthen their cybersecurity, while CyFun (CyberFundamentals) is the practical framework, developed by the CCB, to meet those requirements. NIS2 defines what must be done, CyFun shows how.

NIS2 CyFun
Type Legislation Framework / Tool
Focused on Obligations, risk management, incident reporting Concrete measures, standards and roadmaps
Approach Legal and results-oriented Technical, practical and implementation-oriented

In summary

  • NIS2: The why and what (legal obligation)
  • CyFun: The how (concrete implementation)
  • CyFun is the Belgian translation/implementation of NIS2, developed by the CCB.

Threat Landscape

Geopolitical Context

Cybercrime is closely tied to geopolitical instability. In regions such as KK Park, Myanmar — politically unstable after a coup, high corruption, no extradition treaties — cybercrime has become a logical choice due to impunity.

  • An estimated 23,000 hackers and scammers active in a single city
  • Fully professionally organized: HR, managers, targets, daily operations
  • Countries without an extradition treaty = impossible to prosecute
  • The FBI has a list full of 'most wanted' hackers, knowing exactly where they are, but powerless to act

Geopolitical tension = increased cyber risk

The greater the geopolitical tension between countries, the greater the motivation for state-sponsored and criminal hackers. Cyberattacks are the "easiest way to wage war."

Cybercrime as a Professional Industry

  • Cybercriminals have become organized, professional entities
  • 547 known hacking groups, including Lockbit, Medusa, Play Hacking Group
  • Leaked data is used in 4 ways:
    1. Guessing passwords more easily (credential stuffing)
    2. Identity fraud
    3. Spear phishing
    4. Sale on the dark web

Who would even want to hack me?

Knowing who was attacked often only becomes clear after the breach. Attackers only look afterward at what the potential loot or impact could be. Everyone is a potential target.


Known Cases

Case 1 — Limburg.net (Medusa, 2023)

  • November 14: first login attempts with valid passwords → blocked by MFA
  • November 17: an RDP session without MFA → successful breach
  • Only a month later, when file encryption started, did Limburg.net realize they'd been hacked

Would CyFun have prevented this? MFA on all services (including RDP) is a baseline requirement in CyFun.

Case 2 — City of Antwerp (Play Hacking Group)

  • The City of Antwerp was down for 2 years after the attack
  • Recovery costs: ±100 million euros, aside from any potential fine

Case 3 — Salesforce Connected App

  • The attacker created a new "Connected App" in Salesforce via social engineering (phone call)
  • Looked harmless, but granted full access → game over

NIS2 Guidelines

Critical vs. Highly Critical Entities

Category Maximum downtime
Highly critical Less than 1 day
Critical Less than 1 week

Supply Chain

One of the most important additions in NIS2 is the supply chain obligation:

If you park a service with a supplier, you must contractually enforce cybersecurity requirements and actively monitor compliance.

Liability of Governing Bodies

Board members can be held jointly and severally liable, up to and including imprisonment.

Vastamo Case

Vastamo was a Finnish psychotherapy center. The CEO was sentenced to 3 months, suspended because basic measures weren't taken after a data breach in which patient records were stolen.


CyFun Audit Methodology

Phases

Phase Contents
Phase 1 Gap analysis and interviews
Phase 2 Addressing issues: writing policies, acquiring tools, etc.
Phase 3 Preparing a claim via self-assessment

Risk of self-scoring

If your organization marks something as "pass," and an external auditor later disagrees, you bear full responsibility. Be conservative in your scoring.

Way of Work (Interview)

  • During the interview: note everything, don't score yet
  • The client may send supporting evidence afterward
  • Notes serve as the consultant's personal guide

Maturity Levels

Every measure gets a score on both implementation and documentation. Always start with documentation.

Score Meaning
1 No policy documents (signed by management) present
2 A policy document exists, but hasn't been updated in the last 2 years
2.5 The measure is deliberately excluded with justification (max. 1 per assessment, well substantiated)
3 Documented and implemented
4+ Optimized / continuously improved

Important for key measures

For a score above 3, the auditor will check much more strictly. In practice, give key measures at most a 3, unless you can back it up with rock-solid evidence.

Policy document vs. execution: - The policy document shows the minimum requirements set by management - The contract/SLA with the vendor is the proof that this is actually carried out that way

Audit Sheet vs. Gap Analysis

Document Purpose
Audit Sheet Purely the findings — technical, complete, objective
Gap Analysis A strategic overview for management — explains what, why and how (plan of action)

The recipient's language

The gap analysis must be written in the language of the recipient. Non-IT profiles need a different approach than technical profiles.


Final note

In the end, what counts isn't the consultant's score, or the client's — it's the score of the body that carries out the final audit.