Can Vulnerability Scanning Ensure NIS2 Compliance?

As cyberattacks continue to increase, the European Union has stepped up efforts to ensure that critical and essential sectors are well-protected. One of the cornerstones of this effort is the revised NIS2 Directive, designed to boost cybersecurity resilience across member states.

At the heart of this compliance effort is vulnerability scanning, a process that helps organizations detect and address weaknesses in their systems before attackers can exploit them.

But the pressing question remains: Can vulnerability scanning ensure NIS2 compliance?

In this article, we’ll explain the role of vulnerability scanning in the broader framework of NIS 2 vulnerability management, analyze its limitations, and highlight what else is needed to meet the growing demands of NIS2.

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NIS2 and Its Cybersecurity Requirements

The NIS2 Directive (Directive (EU) 2022/2555) is the European Union’s latest legislative response to increasing cyber threats targeting critical infrastructure. It replaces the original NIS Directive and imposes broader, more stringent obligations on a wider set of organizations, including those in energy, transport, healthcare, banking, food, and digital services.

Unlike its predecessor, NIS2 introduces clearer accountability, mandatory risk management practices, stricter enforcement mechanisms, and uniform application across all member states. Its goal is not just to protect IT systems but to build operational resilience across entire sectors.

One of the key components of this directive is the management of NIS vulnerabilities, gaps, or weaknesses in systems that can be exploited by attackers. To address this, organizations are now required to implement risk-based security measures, report security incidents promptly, and apply a continuous, proactive approach to cybersecurity.

The NIS2 framework aligns with NIS v5, which categorizes security requirements into domains such as risk management, operational continuity, and technical and organizational measures. Vulnerability management sits at the core of several of these domains, linking directly to obligations around system hardening, detection, response, and disclosure.

In short, NIS2 demands more than good intentions; it expects well-documented, actively managed, and continuously improved cybersecurity practices. Vulnerability scanning becomes an essential tool within this landscape, but its effectiveness is defined by how well it’s integrated into a broader, structured security approach.

The Role of Vulnerability Scanning in Cybersecurity

Vulnerability scanning is the process of systematically inspecting an organization’s IT infrastructure, networks, systems, applications, for known security weaknesses. These scanners compare system data against a database of known vulnerabilities to flag outdated software, misconfigurations, or weak access controls that could be exploited.

Unlike penetration testing, which simulates an actual attack, vulnerability scanning is more frequent, automated, and scalable. It’s designed to proactively identify risks before they are exploited.

This function is critical in today’s threat landscape, where attackers often use automated tools to discover and exploit vulnerabilities at scale. Without regular scanning, organizations could remain blind to serious weaknesses that expose them to breaches, service disruptions, or regulatory penalties.

Under NIS2, such proactive identification is no longer optional. The directive’s emphasis on nis 2 vulnerability management makes vulnerability scanning a foundational element of any compliant security program. It directly supports:

• Continuous risk assessment – a key NIS2 expectation.
  
• Timely patch management – by identifying outdated systems.
  
• Incident prevention – by uncovering potential attack vectors early.

However, scanning is only as effective as the organization’s ability to act on the results. That’s why it must be tied to a broader vulnerability management lifecycle, discovery, assessment, prioritization, remediation, and reporting.

READ MORE: What Does C2 Mean in Cyber Security?

Vulnerability Scanning Requirements Under NIS2

The NIS2 Directive doesn’t just recommend vulnerability scanning; it expects it as part of a structured approach to security. While it doesn’t list every technical control line by line, it outlines clear principles that translate into specific vulnerability scanning requirements.

Here’s what organizations must ensure:

1. Automated and Regular Scanning

NIS2 requires continuous risk-based assessments, meaning vulnerability scanning cannot be a one-time or annual affair. Organizations are expected to implement automated tools that run regular scans across networks, endpoints, applications, and cloud environments.

2. Comprehensive Asset Coverage

Scanning must cover the full IT asset inventory, including legacy systems, third-party platforms, and shadow IT. This is closely linked to the directive’s demand for asset visibility under the broader NIS 2 vulnerability management framework.

3. Integration With Risk Prioritization

NIS2 implies that scanning results must feed into a prioritization matrix. Not all vulnerabilities carry equal risk. Therefore, organizations should rank them based on severity, exploitability, and potential business impact.

4. Reporting and Traceability

Scanned results must be documented for audit and incident reporting purposes. If a vulnerability leads to a breach, organizations need to show that they had active measures in place, scanning included, to detect and respond. This is directly tied to NIS2 vulnerability disclosure obligations.

5. Linkage With Incident Response

Detected vulnerabilities, especially those that are critical or already being exploited in the wild, must trigger an incident management protocol, which NIS2 mandates for all Essential and Important entities.

6. Application to the Supply Chain

DORA and NIS2 both extend the requirement to third-party systems. That means scanning external-facing interfaces, APIs, and vendor assets is part of the compliance equation.

These requirements reinforce that vulnerability scanning isn’t just a technical task, it’s a regulatory obligation. And how well it’s executed could be the difference between meeting compliance or facing enforcement.

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Can Vulnerability Scanning Alone Ensure Compliance?

The short answer is no, vulnerability scanning alone cannot ensure full NIS2 compliance. While it is an essential practice, it represents just one part of the broader NIS 2 vulnerability management lifecycle.

Here’s why scanning on its own falls short:

1. Scanning Detects, It Doesn’t Resolve

Vulnerability scanners identify issues, but they don’t fix them. If critical vulnerabilities are discovered but not patched or mitigated, your organization is still non-compliant and vulnerable. NIS2 expects not just detection but action.

2. Context Matters

NIS2 requires a risk-based approach. That means you must assess the context in which a vulnerability exists, its exploitability, the value of the affected asset, and the potential business impact. Vulnerability scanning tools can’t always evaluate these factors on their own.

3. Human Oversight Is Required

Scans can generate false positives or miss configuration issues that require deeper analysis. NIS2 compliance involves policies, processes, and human-led assessments, not just automated reports.

4. Broader Governance Is Mandatory

Compliance is tied to organizational behavior: documented policies, defined responsibilities, regular training, incident response drills, and external reporting. A scanner won’t cover your vulnerability disclosure policy, nor ensure your incident response plan is tested.

5. Lack of Follow-Through Equals Non-Compliance

A key part of NIS2 is proving that you’re not just identifying vulnerabilities, but managing them effectively. That includes remediation timelines, patch management processes, and escalation paths. Without these, vulnerability scanning is an incomplete defense.

In essence, vulnerability scanning provides the eyes, but compliance requires the hands and feet the ability to move swiftly, decide wisely, and document thoroughly.

ALSO SEE: NIST Framework Implementation: A Comprehensive Guide

NIS2 Vulnerability Disclosure Requirements

One of the major evolutions introduced by NIS2 is the formal emphasis on vulnerability disclosure. The directive requires organizations to establish clear, structured processes for reporting and managing discovered security weaknesses, both internally and externally.

This is where NIS2 vulnerability disclosure becomes a critical piece of the compliance puzzle.

1. Mandatory Reporting of Significant Vulnerabilities

If a vulnerability is considered serious, meaning it could lead to a substantial security incident, organizations must report it to the relevant national authority or CSIRT (Computer Security Incident Response Team) without undue delay. This goes beyond just breaches; even high-risk weaknesses that haven’t yet been exploited may trigger reporting obligations.

2. Establishing a Disclosure Policy

Organizations must have a vulnerability disclosure policy that:

• Encourages ethical hackers or security researchers to report vulnerabilities responsibly.
  
• Defines timelines for acknowledging, triaging, and remediating reported issues.
  
• Protects the identity and legal safety of good-faith reporters.
  
• Outlines communication protocols for internal teams, regulators, and, if necessary, the public.

3. How Vulnerability Scanning Supports Disclosure

Vulnerability scanning, when done correctly and continuously, helps:

• Identify vulnerabilities early, reducing the chances of an external party discovering and disclosing them first.
  
• Create a paper trail of detection, triage, and remediation, helpful in demonstrating compliance during audits or investigations.
  
• Provide the technical details needed to substantiate a disclosure report to authorities when required.

4. Link to Incident Response

Disclosure isn’t just about sending an email. It must be tied to an actionable incident response process. Vulnerabilities should flow from detection → triage → risk evaluation → disclosure decision → communication → remediation → closure.

Without a structured vulnerability disclosure mechanism, even frequent scanning cannot ensure NIS2 compliance. It’s not just what you find, it’s what you report, how you act, and when you act.

MORE: Red Team Vs Penetration Tester: Best Guide for Professionals

Common Pitfalls and Challenges in Relying Solely on Scanning

Many organizations mistakenly assume that having a vulnerability scanner in place checks the box for NIS2 compliance. While scanning is important, relying on it without a supporting strategy can lead to serious gaps and regulatory exposure.

Here are some of the most common pitfalls:

1. Incomplete Asset Coverage

If you don’t know what assets you have, your scanner won’t know what to scan. Many organizations lack an up-to-date, centralized asset inventory, leaving large portions of their systems unmonitored. This violates key NIS 2 vulnerability management expectations around visibility and documentation.

2. Overwhelming False Positives

Vulnerability scanners often return thousands of findings, many of which are not exploitable in your environment. Without skilled analysts to validate and prioritize these results, teams can waste time chasing low-risk alerts while missing high-impact threats.

3. No Risk-Based Prioritization

NIS2 requires that vulnerabilities be assessed and remediated based on risk, not just severity scores. But scanning tools alone don’t understand your business context, operational dependencies, or regulatory obligations. That judgment must come from internal teams applying NIS v5-aligned frameworks.

4. Failure to Act on Findings

Scanning uncovers the problem, but if your team doesn’t have the time, budget, or authority to address the findings, the risk remains. Worse, in an audit or breach investigation, failure to remediate known vulnerabilities can be used as evidence of negligence.

5. Lack of Integration

Scanners that operate in isolation disconnected from SIEMs, ticketing systems, or patch management tools, introduce friction. For NIS2 compliance, vulnerability data must flow through your broader security and IT processes in a trackable, reportable way.

6. No Link to Disclosure or Reporting

Even organizations that scan regularly often lack a formal process for determining when a vulnerability is serious enough to be reported to authorities. This breaks the chain required under NIS2 vulnerability disclosure rules and can result in late or missed disclosures.

In summary, vulnerability scanning without a strategic implementation plan creates a false sense of security. The tool is powerful, but only when matched with people, process, and policy.

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Best Practices to Make Vulnerability Scanning NIS2-Compliant

To move beyond basic scanning and meet NIS2 compliance requirements, organizations must treat vulnerability scanning as a strategic function, not just a technical task. Below are best practices to ensure your scanning efforts align with the directive and support a resilient security posture.

1. Maintain a Centralized and Dynamic Asset Inventory

Start with a clear picture of your environment. Maintain a centralized system that dynamically tracks all hardware, software, virtual, and cloud assets. This ensures full scan coverage and helps meet core NIS 2 vulnerability management requirements tied to visibility and risk ownership.

2. Automate and Schedule Scanning

Set up automated scans to run on a recurring schedule (e.g., weekly or monthly) across all network zones, endpoints, and applications. Complement this with on-demand scanning after significant changes like new deployments or patch rollouts.

3. Prioritize Vulnerabilities Based on Risk, Not Volume

Implement a risk-based prioritization model, consider exploitability, potential impact, asset criticality, and business context. This aligns with the risk assessment principle in NIS v5 and avoids the trap of reacting to high-volume but low-impact issues.

4. Integrate with Broader Security Infrastructure

Connect your vulnerability scanner to:

• SIEM tools for threat correlation
  
• ITSM/ticketing platforms for tracking remediation
  
• Patch management systems for closing the loop.

This ensures that vulnerability findings trigger real actions and don’t sit idle in a report.

5. Establish a Formal Vulnerability Disclosure Policy

Create and publish a NIS2 vulnerability disclosure policy. Define roles, communication flows, response timelines, and escalation paths. Make it easy for researchers or users to report vulnerabilities responsibly and safely.

6. Ensure Proper Logging and Reporting

Maintain a robust logging system to record all scan results, remediation activities, and disclosure communications. This provides a compliance trail during audits and proves that you’re fulfilling your obligations under NIS2.

7. Regularly Train Your Security Team

Equip your security staff with the latest training in vulnerability assessment, exploit trends and regulatory requirements. NIS2 expects competent personnel, not just tools, to manage evolving risks.

8. Continuously Review and Update Your Processes

NIS2 is not a “set it and forget it” directive. Continually evaluate your vulnerability management processes, especially after incidents or regulatory changes, and refine them to remain aligned with compliance expectations.

By embedding these best practices into daily operations, your organization can move from compliance on paper to compliance in action, significantly reducing risk while satisfying both auditors and stakeholders.

SEE: SAST Vs DAST Vs Penetration Testing​: A Detailed Analysis

Aligning Vulnerability Scanning with Broader Frameworks

While NIS2 outlines specific principles for security and risk management, many organizations already operate within other established compliance frameworks. The good news? You don’t have to start from scratch. 

Your vulnerability scanning strategy can be aligned with existing standards like ISO 27001, SOC 2, and FedRAMP, making NIS2 compliance more efficient and seamless.

1. ISO 27001

This international standard emphasizes a risk-based approach to information security, much like NIS2. Key ISO controls such as A.12.6 (technical vulnerability management) and A.16 (information security incident management) align closely with NIS2’s requirements.

How it helps:

• Encourages routine vulnerability scans.
  
• Promotes documentation, risk assessment, and formal incident handling.
  
• Supports compliance with NIS 2 vulnerability management obligations through structured controls.

2. SOC 2

Organizations pursuing SOC 2 reports (especially those handling sensitive customer data) already implement continuous system monitoring, access controls, and vulnerability remediation processes.

How it helps:

• Aligns with vulnerability scanning requirements in NIS2.
  
• Reinforces evidence collection for both technical and procedural compliance.
  
• Builds a culture of accountability and transparency—important for NIS2 vulnerability disclosure.

3. FedRAMP

For cloud service providers, FedRAMP mandates continuous monitoring through vulnerability scanning, patching, and system reporting. The structure mirrors many of the expectations under NIS2 and NIS v5.

How it helps:

• Encourages automated scanning with centralized dashboards.
  
• Reinforces third-party and supply chain security, a shared concern with NIS2 and DORA.
  
• Supports the ongoing nature of compliance, rather than a one-time certification model.

4. Bridging the Gap

By mapping your vulnerability scanning and reporting functions to these broader frameworks:

• You minimize redundant effort.
  
• You speed up your path to NIS2 readiness.
  
• You gain credibility and trust with regulators, clients, and stakeholders.

Rather than viewing NIS2 as an entirely new burden, organizations can position it as an opportunity to strengthen and align their security programs with industry best practices already in motion.

Final Thoughts

Vulnerability scanning is a cornerstone of modern cybersecurity and an indispensable tool in the pursuit of NIS2 compliance. It enables organizations to proactively identify weaknesses, manage risk, and fulfill key obligations around technical and organizational security.

But as we’ve seen throughout this article, scanning alone is not enough.

To truly meet the expectations of the NIS2 Directive, especially in areas like NIS2 vulnerability disclosure, incident response, and NIS 2 vulnerability management, organizations must go beyond detection.

The role of NIS v5 in organizing cybersecurity domains also reinforces the need for maturity across process, people, and technology, not just tools. Vulnerability scanning, when aligned with broader frameworks like ISO 27001, SOC 2, or FedRAMP, becomes a powerful enabler of cross-standard compliance.

Vulnerability scanning can ensure NIS2 compliance, but only if it’s treated as a living process, not a technical checkbox. Organizations that invest in people, governance, and integration alongside automated tools won’t just avoid penalties. They’ll build resilience, protect their assets, and strengthen trust with stakeholders.

As cyber threats grow, compliance isn’t about checking off a rule. It’s about staying ready. Vulnerability scanning is where readiness begins, but not where it ends.

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