NIS2 in Greece (Law 5160/2024): a technical checklist for teams on AWS

· 5 min read · security · compliance

The legal guides tell you what NIS2 requires. They rarely tell the engineer what to switch on. This is the mapping we use from the directive's security measures to concrete controls on AWS.

Not legal advice. This post covers the technical side. Whether your company is in scope, and as which type of entity, is a legal question; check the official guidance from the National Cybersecurity Authority and talk to your lawyer.

Greece transposed the EU NIS2 Directive (2022/2555) into national law with Law 5160/2024. It widens the set of companies with cybersecurity obligations well beyond the old NIS rules: energy, transport, banking, health, digital infrastructure, ICT service management, public administration, manufacturing of critical products and more. It also makes management personally accountable for approving and overseeing cybersecurity measures.

Most of the published guidance is written for lawyers and boards. This post is for the engineers who have to make it real.

Are you in scope?

Broadly, NIS2 applies to medium and large companies (around 50+ employees or €10 million+ turnover) in the sectors listed in the directive's annexes, with some providers in scope regardless of size, for example certain digital infrastructure providers. Entities are classed as essential or important; both have the same security duties, with different supervision and fines. In Greece, entities register through the National Cybersecurity Authority's NIS2 registry.

Even if you are not in scope yourself, you may feel NIS2 through your customers. In-scope companies must manage supply-chain risk, so expect security questionnaires and contract clauses if you sell software or services to them.

What the law asks for, in engineering terms

Article 21 of the directive lists the minimum risk-management measures. Here is what each one means on an AWS estate.

1. Risk analysis and information security policies

2. Incident handling

3. Business continuity, backups and crisis management

4. Supply-chain security

5. Secure development and vulnerability handling

6. Assessing whether the measures work

7. Cyber hygiene and training

8. Cryptography and encryption

9. Access control, HR security and asset management

10. Multi-factor authentication and secure communications

Incident reporting: 24 hours, 72 hours, one month

For a significant incident, NIS2 sets a reporting timeline to the national CSIRT or competent authority: an early warning within 24 hours of becoming aware, an incident notification within 72 hours with an initial assessment, and a final report within one month. Your on-call process has to be able to produce that information under pressure:

Write a reporting template into your incident runbook now, with a named person who decides whether an incident is significant. Logs that are centralised, retained and searchable are what make the 72-hour report possible; keeping them in the EU keeps GDPR happy at the same time.

The evidence pack

When a supervisor or a customer asks how you comply, you want to hand over evidence, not promises. Keep these up to date:

If you already have ISO 27001 or SOC 2

Much of the work overlaps. ISO 27001 controls cover most of Article 21, and SOC 2 evidence such as access reviews, change management and incident response is reusable. The gaps are usually the NIS2-specific ones: the 24/72-hour reporting flow, management training and accountability, and registration with the national authority.

Where to start

  1. Confirm with your legal adviser whether you are in scope, and register if you are.
  2. Run a baseline review of your cloud estate against the ten areas above.
  3. Fix the high-impact gaps first: MFA and SSO, centralised logging, tested backups, and the incident reporting runbook.
  4. Turn on continuous checks so you know when something drifts.

Penalties under NIS2 can reach €10 million or 2% of worldwide turnover for essential entities and €7 million or 1.4% for important ones, but in practice the bigger risk for most companies is losing a customer who can't accept your answers to their security questionnaire.

Frequently asked questions

What are the NIS2 incident reporting deadlines?

For significant incidents: an early warning within 24 hours of becoming aware, an incident notification within 72 hours, and a final report within one month.

Does using AWS make us NIS2 compliant?

No. AWS secures the underlying cloud, but you are responsible for how you configure and operate your accounts: identity, logging, backups, patching and incident response.

Which Greek law implements NIS2?

Law 5160/2024 transposes the NIS2 Directive (EU) 2022/2555 into Greek law. The National Cybersecurity Authority publishes guidance and runs the registry for in-scope entities.