Will Skipping Phishing Simulations Put Your NIS 2 Audit at Risk?
Most organisations want their next NIS 2 audit to be a quiet win, not a headline stressor, and it’s tempting to rely on annual training modules as a shortcut. In 2024, however, auditors and sector regulators insist on something more: evidence that your people can spot phishing in live scenarios, not just ticked-off e-learning. Why does it matter? ENISA’s research shows staff dependent solely on passive learning miss almost one in five phishing threats, creating hidden audit gaps and, increasingly, derailing tenders and board assurance (ENISA, 2024).
Proving real vigilance-not just awareness-turns audits from cross-examination to confident sign-off.
Procurement teams and external auditors are raising the bar in regulated sectors. In 2023, 43% of high-value tenders required explicit logs of phishing simulations before allowing suppliers to join the table (ENISA Cyber Hygiene, 2024). This mindset-“show me, not just tell me”-is now normal, with audit panels expecting actual simulation cycles, not just policy acknowledgments. ENISA’s audit findings now list missing simulation outcomes as a prime cause of cyber hygiene nonconformance, especially under NIS 2 (NIS2Cybersecurity.org, 2024).
Audits may not immediately penalise skipping simulations, but the evidence gap will eventually emerge: failed tenders, anxious board reviews, or repeat audit queries. It isn’t about chasing a new checkbox; it’s about demonstrating readiness-both for the audit and for the threats.
When Simulation Evidence Comes Up Short
Many organisations relying on basic classroom or e-learning modules face up to 30% more audit requests tied to incident readiness (FTI Consulting, 2024)-costing time and client trust. Every simulated campaign you log not only reduces breach risk; it builds a verifiable story for your auditors and stakeholders, shifting reviews from Are you exposed? to How are you improving?
Momentum check: The difference between passing and thriving lies in logging real, scenario-based vigilance-not just annual declarations.
Book a demoWhat Does “Cyber Hygiene” Mean Under NIS 2 and ENISA’s Guidance?
NIS 2 places a bright spotlight on what counts as real cyber hygiene. Article 21 and Recital 88 both require your organisation to take “appropriate, recurring, and measurable” action (EUR-Lex, 2022). Passive training is yesterday’s minimum. Today, organisations have to show ongoing engagement and improvement cycles, with evidence that stands up to audit review and board scrutiny.
ENISA’s 2024 guidance points directly to simulated phishing campaigns as a core aspect of compliance, not just a best-practise recommendation. Their focus is precise: you must move beyond passive e-learning and perform active, scenario-based user testing at regular intervals (ENISA, 2024). Organisations must log these simulations, track outcomes, and record follow-up actions to meet today’s audit bar (AKD, 2024).
International standards such as ISO 27001:2022 A.6.3 further demand that organisations demonstrate ongoing improvement and actionable proof-not just record attendance (ISO.org, 2023). Put plainly: simulation metrics and follow-up evidence aren’t just best practise-they are exactly the proof auditors expect to see.
Table: Bridging Expectation to Operationalisation
| Expectation | Operationalisation | ISO 27001 / Annex A Ref. |
|---|---|---|
| Staff spot phishing in the wild | Phishing simulation campaigns, click & report logs | A.6.3 Information Security Awareness |
| Measurable, recurring improvement | Simulation review cycles, remedial learning | A.5.30 InfoSec Continuity |
| Audit-ready evidence | Exportable logs, dashboard overlays, SoA linkage | A.9.1 Monitoring/Measurement |
What’s the stark truth? A cyber hygiene programme with nothing but e-learning and passive policy logs is simply non-compliant under this combined regime. Simulations now form the backbone of credible audit evidence.
Moving from evidence of intention to evidence of action-that’s what delivers true audit confidence.
If you want non-negotiable confidence in your next audit or board review, simulated phishing tests aren’t a luxury; they’re foundational.
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Is Phishing Simulation Explicitly Required, or Just Strongly Suggested?
You won’t find “phishing simulation” as a spelled-out clause in NIS 2’s legal text-but in practise, simulations are now table-stakes. ENISA, sector guidelines, and 2024 checklists have made them de facto requirements for trust and audit. It’s how you prove awareness in live conditions, not just theoretical knowledge (ENISA, 2024).
Audit expectations rest on the principle of “reasonable precaution”: if your organisation can show scenario-driven phishing tests with action metrics, you stand on solid ground (ISACA, 2022). If you can only say “our staff completed modules,” recent audit case law considers that insufficient-organisations have failed supply chain audits even with up-to-date e-learning (FTI Consulting, 2024).
National authorities in Belgium, the Nordics, and sector-specific regulators have begun requiring simulation logs for critical supplier onboarding (Mondaq, 2024). Regulatory best practise becomes audit expectation-meaning that even if the letter of NIS 2 doesn’t yet demand simulations, reality on the ground already does.
Table: Traceability-from Trigger to Logged Evidence
| Trigger | Risk Update | Control / SoA Link | Evidence Logged |
|---|---|---|---|
| Spear-phishing incident | Phishing threat added; review frequency set | A.6.3, SoA linked | Simulation log, staff results |
| Board CSR query | Policy update, simulation cycle increased | A.5.31 | Board approval, simulation record |
| Supplier audit request | Awareness controls benchmarked | A.5.30 | Exported logs, dashboard snapshot |
Your audit dashboard should connect why a simulation was run (trigger), how risks were updated, which control it links to, and what outcome evidence is logged. That’s the proof loop auditors require.
Every time you log the reason for a simulation-and the resulting action-you’re building audit currency that closes regulator and board queries before they interrupt your progress.
What Evidence Will Auditors and Regulators Now Expect for Phishing Awareness?
“Proof of actual improvement” is today’s audit mantra-proof of module attendance is not. ENISA’s own audit guidance ranks simulation logs, follow-up actions, and measurable staff improvements above any record of training participation (ISMS.online, 2023). One in four organisations failing NIS 2 or ISO 27001 audits last year cited a lack of credible simulation evidence as the main cause (arsen.co, 2023).
Boards and auditors aren’t waiting for an incident before they ask for test data. Management reviews must now show simulation calendars, outcome rates, and remedial learning alongside old standards like firewall rule reviews (AKD, 2024). This is reflected in modern compliance platforms-like ISMS.online-where simulation events, pass metrics, and remedials are logged and exportable across audits and tenders (ISO.org, 2023).
Audits are changing: the more improvement cycles you document and can evidence, the fewer anxiety-driven queries you’ll field on the day.
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How Are Leading Sectors and Boards Responding to the New Audit Reality?
Sectors leading in compliance run phishing simulations quarterly-with each result mapped to staff segments and sector benchmarks. Finance, health, and critical infrastructure set this pace and boards demand lateral proof-comparing results to industry averages and requiring visible remedial action for missed tests (FTI Consulting, 2024).
Boards and audit committees have moved from prove you tried to prove you improved.
83% of regulated boardrooms now request logged simulation outcomes for every management review-anything less flags immediate questions (Mondaq, 2024).
Smart organisations close the improvement loop: simulated attack, staff results, remedial action, evidence export, audit review-then benchmarked improvement year-on-year. Compliance has become a discipline of living, visible progress, not just annual renewal.
What Does the Cyber Hygiene Checklist Look Like for Regulators, Auditors, and Boards?
Here’s what’s now essential when presenting your cyber hygiene maturity to any external reviewer:
- Simulation Records-Comprehensive logs: campaign dates, staff click rates, and missed events (ISMS.online, 2023).
- Control Mapping-Direct link to NIS 2 and ISO 27001 controls, fully exportable (ISO.org, 2023).
- Policy & Frequency-Policy statements and logs clarify your minimum benchmarks (Mondaq, 2024).
- Improvement Measurement-Document staff performance before/after simulations and remedial learning cycles (AKD, 2024).
- Remediation Actions-Disclosure of missed or failed simulations, plus follow-up steps (ENISA, 2024).
- Privacy by Design-Ensure simulation records are anonymized and privacy-compliant, especially for multi-framework reuse (europa.eu, 2024).
Scenario Table:
| Action Trigger | Evidence Required | Likely Audit Outcome |
|---|---|---|
| Sim campaign completed | Logs mapped to controls, remedials | Pass (proves real improvement) |
| Missed/failed cycle | Log disclosure, remedial documentation | Pass (gap acknowledged) |
| Board requests benchmarking | Sector metrics, dashboard export | Positive board review |
The key: it’s not about paperwork volume, but about improvement evidence-mapped directly to risks and sector expectations.
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Readiness Scenarios: Tools, Dashboards, and Evidence to Prepare (with ISMS.online)
A compliance programme that’s living can answer “yes” to each of these:
- Completed a phishing simulation in last 6 months?: (Logs and anonymous records, ready to export.)
- Privacy-compliant logs for sector and ISO audits?: (Anonymize and retains granular click data.)
- Evidence exportable by framework (NIS 2, ISO 27001, sector)?: (Unified dashboards fit any review.)
- Management reviews with remedials properly documented?: (Action logging triggers reminders and captures oversight.)
- Plan in place for audit gaps?: (Scenario-based, transparent gap and corrective action reporting.)
Trust rides on visibility of improvement, not mere training completion.
With ISMS.online’s environment, you operationalise, document, and evidence every cycle-making audit and board review a confident, continuous process.
Start Continuous, Audit-Ready Cyber Hygiene with ISMS.online Today
When you embed phishing simulations-and document cycles of improvement-in a platform built for audit resilience, regulatory uncertainty is replaced by operational clarity and trust. ISMS.online integrates simulation management, privacy-aligned anonymization, multi-standard exports, and board-level dashboards into a single, auditable environment.
Explore a 30-minute ISMS.online walkthrough and experience mapped simulation logs, live privacy controls, evidence exports, and real-time dashboards that demonstrate your compliance story. Equip your team to monitor improvement rates, meet every board and procurement query with proof, and ensure privacy data never leaks in pursuit of compliance.
Leadership is proven by improvement, not mere completion. Your compliance narrative sets the standard when audit-readiness is lived, logged, and demonstrable.
With a compliance backbone validated across frameworks, your organisation becomes the trust benchmark others aspire to meet.
Frequently Asked Questions
Who decides if phishing simulations are mandatory for NIS 2 cyber hygiene compliance?
National and sectoral authorities-not just the NIS 2 Directive-ultimately determine if phishing simulations are mandatory for your organisation. While Article 21 of NIS 2 broadly requires “cyber hygiene and awareness measures,” actual expectations are set by each EU Member State’s cyber-security authority (such as the BSI in Germany or CCB in Belgium), sector regulators (like DORA for finance), and audit practise shaped by ENISA and local standards. For example, ENISA’s guidance and sectoral guidance often make recorded phishing simulations a practical minimum for audit-readiness, even if not listed verbatim in legal text (ENISA, 2022). Many organisations discover that, regardless of the base law, failing to meet their regulator’s (or auditor’s) operational standard for proven, recurring simulation campaigns leads to compliance gaps. The real test: what does your supervising authority expect to see in practise?
How do regulatory expectations become operational requirements?
National bodies and sectoral law can turn guidance into direct mandates, so review current circulars, published frameworks, and audit checklists. Where regulators or auditors expect documented simulations, these effectively become mandatory. Consulting your regulator or following sector-specific minimums is the safest route to a defensible cyber hygiene programme.
Regulators shape the test, but audit practise determines the grade-plan for both.
What evidence do audits require for phishing simulations under NIS 2 or ISO 27001?
Auditors require more than completed awareness training-they expect complete, risk-linked documentation of your phishing simulations. This includes campaign schedules/calendar, anonymized outcome metrics (like click and report rates), participation and coverage records, logs of remedial actions (e.g., extra training for those who click), management review minutes referring to simulation outcomes, and clear risk/control mapping (e.g., to ISO 27001 clauses A.6.3 and A.5.30). GDPR compliance is essential: data should be pseudonymized, with a clear record of lawful processing and retention (ENISA, 2023). Platforms like ISMS.online help automate these linked records and exports, but you must curate the evidence chain for both the NIS 2 regulatory regime and ISO 27001’s audit rigour.
What components make up a robust audit evidence pack?
- Dated campaign logs: Frequency, target group, campaign themes.
- Anonymized outcome metrics: Clicks, reports, trends, by group.
- Participation records: Proof of staff inclusion (pseudonymous).
- Remedial logs: Additional training or review for failed simulations.
- Risk and control mapping: Trace each campaign to a current risk or ISO/NIS 2 control.
- Management review minutes: Leadership discussion, decisions, actions.
- GDPR proof points: Anonymization, retention, purpose limitation, staff notice records.
Strong evidence is traceable end-to-end: from campaign idea to actual risk reduction.
Do national and sector rules make phishing simulation campaigns stricter than NIS 2 alone?
Yes-national agencies and sectoral regulators often require more frequent and detailed phishing simulations than the high-level NIS 2 Directive implies. For instance, DORA now obliges quarterly campaigns for financial firms across the EU, while bodies like Germany’s BSI and Belgium’s CCB set at least annual campaigns as a compliance baseline for critical sectors (Mondaq, 2024). ENISA recommends at least annual simulations for all, but sectoral rules may be more prescriptive.
Example simulation requirements across Europe
| Regulator/Authority | Sector | Status | Minimum Frequency |
|---|---|---|---|
| DORA (EU) | Finance | Mandatory | Quarterly |
| BSI (Germany) | Critical Infra | Mandatory | Annually |
| CCB (Belgium) | Public, Infra | Strong Rec. | Annually |
| ENISA | Broad | Recommended | Annually |
If your organisation operates across borders or critical sectors, always harmonise your simulation cadence to the strictest standard you face.
What KPIs and metrics actually prove your phishing simulations are reducing risk, not just box-ticking?
Regulators and auditors increasingly focus on evidence of improvement, not just activity. This means tracking-and being able to prove-a reduction in click rates, an increase in report rates, effective remediation for risky users, and senior management attention to trends. Metrics like time-to-detect (MTTD), time-to-remediate (MTTR), and overall participation rates also carry real audit value (Keepnet Labs, 2024). In audit, trendlines matter more than snapshots.
Core effectiveness metrics for phish simulation programmes
| Metric | What It Proves | Audit/CISO Use |
|---|---|---|
| Click rate | User susceptibility | Risk register input, remediation depth |
| Report rate | Detection/alertness | Board/management review visibility |
| MTTD, MTTR | Response maturity | Time-based improvement benchmarking |
| Remediation uptake | Knowledge closure | Continuous improvement evidence |
| Participation rate | Reach/coverage | Control effectiveness, policy proof |
What gets measured, improves-documenting upward trends signals proactive risk management.
How do you operationalise phishing simulations to satisfy both NIS 2 and ISO 27001?
Anchor your entire programme on a compliance platform that natively logs every campaign, outcome, and follow-up-linking them to your risk register and mapped ISO/NIS 2 controls. Begin by aligning your simulation calendar to the strictest frequency from your sector or jurisdiction, and automate reminders, anonymization, and reporting. Make sure every result ends up cross-referenced to risks and management reviews, with GDPR compliance enforced throughout. ISMS.online is engineered for this: providing workflows, dashboards, and exports tailored for both NIS 2 and ISO 27001 standards (ISO.org, 2024). Rehearse your evidence export prior to audit to guarantee completeness.
Checklist: Running a bulletproof phish simulation programme
- Schedule: by strictest applicable rule (e.g., DORA if in finance).
- Log: all campaigns and outcomes with anonymization and clear timelines.
- Link: each to corresponding risks and controls in your registers.
- Document: remediation and management review discussions.
- Export: mapped, traceable evidence packs for auditors.
- Review: GDPR and sector-specific data requirements for every cycle.
The difference between passing and failing audits is the ability to show the full story, from scheduling through to management action.
What audit mistakes or pitfalls cause phishing simulation failures, and how can you prevent them?
The most common audit failures stem from gaps in your documentation trail: incomplete logs, missing risk/control mapping, absent or informal remediation records, storing unmasked personal data (GDPR breach), or simply skipping scheduled campaigns. Relying on siloed email threads or spreadsheets-rather than a dedicated compliance platform-creates blind spots auditors are trained to find. Lastly, leadership “rubber-stamping” management reviews rather than engaging real improvement cycles is a persistent risk.
How to bulletproof your compliance against audit failure
- Log every campaign, result, and follow-up in a single, auditable system.
- Ensure all logs are anonymized, with GDPR-safe data flows.
- Map campaigns to current risks and controls.
- Schedule recurring reviews with real leadership engagement-record their decisions.
- Practise evidence export in advance, not on audit day.
Organisational leadership is proven by documenting progress, not just reporting tasks. Your audit record is your reputation.
What’s your actionable next step for an audit-ready phishing simulation programme?
Move all simulation, remediation, and evidence workflows onto a compliance platform like ISMS.online to centralise logs, automate reminders, and tie every campaign directly to your risks, controls, and management reviews. Schedule an evidence review ahead of your next audit-don’t wait for a finding that reveals a gap. When auditors (and your board) request proof, you’ll have a complete, defensible trail showing not just activity, but improvement. Trusted compliance isn’t just about ticking boxes-it’s about showing resilience in action, one record at a time.
