The NIS2 Directive marks a big change in how cybersecurity is regulated across the EU. It expands coverage to include around 160,000 organizations across a wide range of sectors, with stricter enforcement and an emphasis on the human side of security.
Organizations should be prepared to demonstrate that required security measures are in place, and that they’re not just a list of policies. It includes essential services like energy and healthcare, as well as important entities such as manufacturing and digital providers.
There’s one thing that is clear from Article 21, and that is, people are important. Developer awareness and training are central to meeting the directive’s requirements.
What NIS2 Expects
NIS2 (Network and Information Security 2) is the EU’s updated framework for managing cybersecurity risk. Compared to the original NIS Directive, it has more stringent requirements, and there are now penalties for non-compliance to think about.
With these penalties reaching up to €10 million or 2% of global annual turnover for essential entities, organizations are under pressure to make compliance a priority.
Alongside enforcement, NIS2 also shifts the focus from merely having controls listed for compliance to proving that they work in practice.
Another point worth remembering is that NIS2 puts emphasis on proportionality. The security measures that are put in place should align with the level of risk, rather than applying the same controls to every system.
Broadly speaking, NIS2 requires organizations to demonstrate:
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Risk analysis and security for network and information systems.
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Secure system acquisition, development, and maintenance.
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Vulnerability handling and disclosure.
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Incident prevention, detection, and response.
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Supply chain risk management.
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Accountability at both management and operational levels.
In practice, this means showing that security is embedded throughout the software development lifecycle (SDLC), including design, development, and maintenance.
Basically, every decision development teams make can affect whether the organization will meet NIS2 requirements, which include writing secure code and choosing safe dependencies.
Something to note for financial organizations is that DORA’s sector-specific requirements take precedence over NIS2. While the two frameworks share similar security principles, DORA has more detailed rules for the financial sector.
Why Developers are Central to NIS2 Compliance
Much of the time, security incidents start with poor design and implementation decisions, such as insecure integrations and misconfigured trust boundaries. These decisions can all increase risk. It’s for that reason that the directive includes secure development as a primary risk management measure.
Organizations need development teams who can:
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Recognize security-relevant design decisions.
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Understand common attack paths.
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Write code securely and avoid introducing preventable vulnerabilities.
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Assess risk across services, APIs, and dependencies.
Security teams can define standards and controls, but developers are the ones who apply them. Without proper developer security training, it’s difficult to meet NIS2 requirements consistently, or to prove that you can.
Mapping Developer Security Training to NIS2 Requirements
Before getting into individual requirements, there are two ideas that run through much of NIS2:
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Secure-by-design principles ensure systems are designed and built with security in mind from the very beginning.
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Secure coding practices make sure those designs are implemented safely and consistently in code.
Developer security training is what connects them. Security already starts from the design phase, so developers need to understand that the decisions they make at this stage will impact risk. They then need to implement the design correctly and safely in their codebases, using the languages and frameworks they work with.
Let’s check out how developer-focused security training supports specific NIS2 requirements.
1. Risk Analysis and Security Measures
NIS2 requires organizations to do risk analysis and implement security measures that reduce exposure based on that.
With training, developers learn how to:
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Identify assets, trust boundaries, and entry points.
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Understand how individual components combine into attack paths.
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Assess the security impact of design and implementation choices.
It’s important for risk to be seen as more system-wide rather than at the level of individual components. Security decisions can then be made earlier in the SDLC, which supports NIS2’s emphasis on preventing risks, rather than making reactive fixes.
For example, when building a customer portal, a trained team can use threat modeling to identify authentication as a critical trust boundary. They can then map likely attack paths, such as privilege escalation, and design ways to mitigate them into the architecture (before any code is even written).
Training that includes threat modeling concepts, secure architecture patterns, and attack path thinking makes risk analysis part of development rather than yet another compliance task.
Even though NIS2 doesn’t mention threat modeling by name, it is a well-established method to show secure-by-design practices under Article 21.
2. Secure Development and Maintenance of Systems
Under NIS2, security needs to be considered from system acquisition through development and long-term maintenance. In software-led organizations, this makes secure development a main engineering responsibility.
Security training enables developers to implement security controls correctly and consistently in code. They should:
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Apply secure coding best practices for their languages and frameworks.
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Avoid common vulnerability classes such as injection flaws and broken access control.
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Use secure defaults and configurations that reduce risk.
3. Vulnerability Handling and Reduction
Organizations also need to manage vulnerabilities across the entire lifecycle, including finding and fixing them, and disclosing them when required.
Training supports this process in:
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Helping developers understand how vulnerabilities arise.
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Reducing reintroduction of the same vulnerability patterns.
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Improving the quality and speed of remediation.
When developers understand how vulnerabilities work at the root, remediation becomes more effective. Fixes are less likely to be superficial or incomplete, which reduces long-term exposure.
Whereas an untrained developer might only patch a single vulnerability where it’s seen, such as an SQL injection, a trained developer will better understand the root cause and can then fix it across the entire codebase.
4. Incident Prevention and Impact Reduction
While incident response plans are essential, NIS2 places equal importance on preventing incidents and limiting their impact.
With proper security training, teams can:
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Prevent vulnerabilities from reaching production environments.
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Build systems with security-first defaults and defensive architectures.
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Strengthen error handling, security logging, and system resilience.
If there are fewer vulnerabilities, then it follows that there are fewer viable attack paths. When incidents do occur, systems built with security in mind tend to fail more gracefully.
Another point is that trained developers will know how to log security-relevant events without exposing passwords, customer data, or system secrets. When there’s a security incident, this secure logging helps teams to quickly understand what happened and contain the damage.
5. Supply Chain and Third-Party Risk
Supply chain security is now a major concern, so it’s no wonder that NIS2 places importance on it, which includes third-party services and software dependencies. Developers should be able to manage supply chain risks, so training can help them:
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Assess the security impact of third-party libraries and services.
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Understand how vulnerabilities can propagate through dependencies.
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Apply secure configurations and keep external components up to date.
There have been damaging attacks on third-party packages in recent months, so it’s essential that developers always check them for known vulnerabilities, review maintenance activity, inspect dependencies, and verify package integrity.
NIS2 also recommends keeping a software bill of materials (SBOM) and doing vendor assessments to help prevent supply chain attacks.
6. Accountability and Demonstrable Due Diligence
NIS2 expects accountability at the management level. How does developer security training play a role? Aside from showing that your organization is taking its responsibilities seriously, it helps ensure that:
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Security responsibilities are clearly assigned.
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Teams have the skills and knowledge to do their jobs securely.
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Secure development practices are an ongoing part of workflows.
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Progress and performance are measurable, providing evidence of continuous capability.
Why Traditional Security Training Often Fails
Many organizations already run security awareness or annual compliance training. Unfortunately, this isn’t enough for NIS2.
The problem is that traditional training has:
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Generic content that doesn’t reflect real codebases.
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One-off sessions with no reinforcement.
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Little connection between training and development work.
Developer Security Training for NIS2
NIS2 expects security to be embedded into workflows, so training needs to be:
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Role-specific: Training should reflect the responsibilities of different team members. Frontend developers, backend engineers, DevOps, and cloud engineers all face different risks, so they need learning based on what they do.
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Hands-on: Developers learn best in practical settings, such as labs and interactive exercises, where they can practice finding and fixing vulnerabilities in the code and environments they work with.
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Continuous: Training should be integrated throughout the SDLC and be done regularly, reinforcing knowledge over time and keeping current with new threats and technologies.
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Environment-specific: Training needs to encompass the environments, languages, frameworks, and cloud platforms teams are already using, so lessons can be put into practice straight away.
How SecureFlag Supports NIS2 Compliance in Practice
Part of meeting NIS2 requirements means being able to show that developers can apply secure coding practices, not just that they’ve watched a video or passed a multiple-choice test.
SecureFlag is built around the idea that prevention is better than reactive fixes and that security should be embedded across the SDLC. A huge part of our training is ensuring developers learn by doing, through hands-on labs.
When it comes to meeting compliance, SecureFlag helps organizations:
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Apply secure-by-design principles through automated threat modeling with ThreatCanvas.
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Make secure coding part of everyday development, not just an occasional check.
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Build practical skills across the technologies and environments teams use.
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Monitor training progress and track team competency over time.
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Enhance security awareness through programs like security champions and coding tournaments.
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Provide audit-ready evidence to show Article 21 requirements are being met.
At the end of the day, a major part of NIS2 is about organizations proving their security capabilities. Developer security training that includes secure design, threat modeling, and secure coding helps make compliance continuous, rather than just a deadline.
Looking to enhance your NIS2 compliance posture?
