Organisations preparing for NIS2 can strengthen credential security with seven practical steps: map identities, remove obsolete accounts, limit shared access, separate administrator accounts, enable MFA for privileged users, protect authentication secrets, and train staff. These measures support NIS2’s risk-based security requirements, but completing them is not, by itself, proof of compliance.
What NIS2 says about passwords and MFA
NIS2 requires in-scope organisations to take appropriate and proportionate technical, operational, and organisational measures to manage cybersecurity risks. Article 21 includes access-control policies and, where appropriate, multi-factor authentication (MFA) or continuous authentication. It does not prescribe one universal password policy, MFA product, or checklist. Directive (EU) 2022/2555, Article 21.
Scope matters. NIS2 is implemented through Member State law, so applicability, supervision, and detailed obligations depend on the organisation, its sector, and its jurisdiction. Commission Implementing Regulation (EU) 2024/2690 sets technical and methodological requirements for specified digital infrastructure, digital provider, and ICT service management entities; it is not a blanket set of technical rules for every organisation covered by NIS2. Commission Implementing Regulation (EU) 2024/2690 and ENISA’s NIS Directive 2 overview.
ENISA’s June 2025 Technical implementation guidance provides advisory implementation context for relevant entities. ENISA explicitly states: “This document is not legally binding and is only of an advisory character.” Use the guidance alongside the law that applies in your country and your competent authority’s instructions. ENISA, Technical implementation guidance, June 2025, version 1.0.
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Seven low-cost steps to secure credentials
1. Inventory identities and accounts
Build a current list of the identities that can access your systems: employees, contractors, suppliers, administrators, service accounts, and other non-human identities. Record which systems each identity can reach and what it can do there. A simple spreadsheet can be a starting point if it has an owner and is kept current; the essential task is to see who or what has access, including access held by external entities. The regulation’s access-control provisions address access by persons, external entities, and network and information systems. Implementing Regulation (EU) 2024/2690.
2. Deactivate accounts that are no longer needed
Connect account removal to staff departures, contract endings, role changes, and service retirement. Assign responsibility for confirming access removal, then review active accounts on a schedule appropriate to your risks. The regulation says identities no longer needed should be deactivated without delay. Implementing Regulation (EU) 2024/2690.
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3. Reduce shared accounts
Use individual identities where possible so actions can be attributed to a person. If a shared identity is operationally necessary, document why, obtain explicit approval, and control who can use it. Avoid letting a shared password become a permanent substitute for assigning individual access. The regulation treats shared identities as exceptional: they should be justified, approved, and documented. Implementing Regulation (EU) 2024/2690.
4. Separate administrator access from everyday work
Give people who administer systems dedicated accounts for that work, separate from the accounts they use for email, browsing, and routine tasks. Grant only the privileges needed for each role, and restrict administrative access as much as possible. This reduces exposure of high-impact permissions during ordinary work. Implementing Regulation (EU) 2024/2690.
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5. Enable MFA for privileged accounts first
Start with accounts that administer systems or hold elevated privileges, then extend MFA according to risk and asset classification. For those privileged and administration accounts, the regulation calls for strong identification and authentication, such as MFA, as well as authorisation procedures. A FIDO2 hardware security key may be an option for compatible services, but it is not mandated by NIS2 or the regulation. Check service support and establish recovery and replacement procedures before relying on any MFA method. Implementing Regulation (EU) 2024/2690.
6. Protect authentication secrets
Define how passwords, recovery codes, tokens, and other secret authentication information are issued, stored, recovered, and revoked. Limit access to these secrets and keep them confidential. A business password manager can help implement controlled storage, but the regulation does not require a password manager or name a particular product. Authentication strength should be appropriate to the classification of the asset being protected. Implementing Regulation (EU) 2024/2690.
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7. Train staff on the credentials they actually use
Make training specific to the accounts, sign-in methods, devices, and phishing risks staff encounter. Explain how to report suspected credential theft, handle unexpected authentication prompts, and protect recovery information. NIS2 includes basic cyber hygiene and cybersecurity training among its risk-management measures. Directive (EU) 2022/2555, Article 21.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.How to choose an MFA method
The legislation establishes security outcomes, not a product ranking. Compare options against your systems and operating needs rather than choosing on purchase price alone.
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- Protection: Consider the method’s resistance to phishing and account takeover.
- Compatibility: Confirm that the identity provider and services your organisation uses support it.
- Recovery: Decide how users regain access after losing a device or factor, and how lockouts are handled.
- Administration: Check whether administrators can see enrolment, revoke factors, and respond when access must be removed.
- Cost and setup: Include per-user costs and the work needed to configure and support the method.
- Usability: Account for employees, contractors, and emergency access without creating avoidable workarounds.
These are decision criteria, not a ranking established by the legislation. A hardware security key is only useful where the relevant service supports it and the organisation can manage enrolment, spare or replacement keys, and recovery.
Turn the steps into a proportionate programme
Use the seven steps as a practical starting point, then assess the controls against your organisation’s assets, risks, sector, applicable national transposition, and regulator guidance. The implementing regulation applies to specified categories of entities, and national competent authorities oversee obligations within their jurisdictions. ENISA’s guidance can help with implementation, but it is advisory rather than binding. ENISA, Technical implementation guidance.
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